Fluoride: The Ultimate Cluster Flux Folder 3A

Fluoride: The Ultimate Cluster-Flux

And the Players Involved

A Compilation of Documents and Articles

Relating to Fluoride

This collection is dedicated to those who wrote the original works and

made them available on the internet. I have spent countless hours

searching for information on fluoride and it is my wish, by assembling

these works, to enable others to save time looking and make available

more time for them to ‘do’.

If you are sickened and appalled by the approved use of fluoride in

food, beverage and other consumer products then I ask that you spread

this knowledge on to others and contact your local representatives in the

hopes that one day fluoride will be more strictly regulated or, banned

altogether.

These documents are listed in roughly the order I found them. It would

be nearly impossible to group them in some kind of order since they are

all linked together – a cluster-flux of monumental proportions.

I would like to thank (or curse) Christopher Bryson whose excellent

book, The Fluoride Deception, opened my eyes to fluoride and started

me on this journey of uncovering the truth.

For more information on fluoride, I would recommend the Fluoride Action

Network (FAN) http://www.fluoridealert.org/ as a good place to start.

NOTICE

In accordance with Title 17 U.S.C., section 107, some material on this web site is provided without permission from the copyright owner, only for purposes of criticism, comment, news reporting,

teaching, scholarship and research under the "fair use" provisions of federal copyright laws. These materials may not be distributed further, except for "fair use" non-profit educational purposes,

without permission of the copyright owner.

About Phosphogypsum – EPA http://www.epa.gov/radiation/neshaps/subpartr/about.html

General Information

How much phosphogypsum is being produced?

Since the mid-eighties, the annual production rate of phosphogypsum has been in the range of

40 to 47 million metric tons per year. The total amount generated in the United States from

1910 to 1981 was about 7.7 billion metric tons.

In Central Florida, one of the major phosphoric acid producing areas, the industry generates

about 32 million tons of phosphogypsum each year. They have a current stockpile in stacks of

nearly 1 billion metric tons.

Why is so much phosphogypsum produced?

The agriculture industry uses large amounts of chemical fertilizers to replenish and

supplement the nutrients that growing plants take up from the soil. The demand for fertilizers

and animal feed additives accounts for about 95% of the 8-10 million metric tons of

phosphoric acid that is made each year. The production of each ton of phosphoric acid is

accompanied by the production of 4½ tons of the by-product calcium sulfate, also known as

phosphogypsum.

Phosphate rock, which is processed to make phosphoric acid, contains concentrations of

naturally occurring radioactive elements (radionuclides). Even high grade ores, which contain

about 70% calcium phosphate, also contain a large number of impurities, such as calcium

fluoride, chlorides, chromium, rare earths, and radionuclides. At the end of the production

process, the radionuclides end up in the phosphogypsum.

Processing Phosphate Rock

Where does the phosphate rock come from?

In the United States, main deposits of phosphate rock are in Florida, Tennessee, and North

Carolina. There are also deposits that can be mined in Idaho. The phosphate rock, which

eventually yields the phosphogypsum by-product, is recovered by open pit mining. The rock is

transported to a washing facility, where it is separated from accompanying soil, stones, etc.

and processed. The desired phosphorus content of the phosphate rock is in a form (calcium

phosphate) that will not dissolve in water and so cannot be taken up by crops. As a result,

phosphate processors must solve the problem of getting it into a water-soluble form.

The most common solution to the problem is converting the calcium phosphate to phosphoric

acid. There are wet and dry processes for doing the conversion. U.S. production facilities

utilize a wet process in which the prepared rock is treated with sulfuric acid to produce the

phosphoric acid. Phosphoric acid is water soluble so it can be taken up by crops. It can also be

concentrated, as desired, by evaporating water from the mixture.

The by-product remaining after the acid conversion is largely calcium sulfate and has been

given the name phosphogypsum. (Gypsum is the common trade name for hydrated calcium

sulfate, a common building material.)

How many facilities are producing phosphoric acid and

phosphogypsum?

As of September 1989, the phosphoric acid production industry consisted of 21 active facilities

that use the wet-acid production process. The majority of the 21 facilities are located in the

southeast, with 12 in Florida, three in Louisiana, and one in North Carolina.

Stacks

The phosphogypsum, separated from the phosphoric acid, is in the form of a solid/water

mixture (slurry) which is stored in open-air storage areas known as stacks. The stacks form as

the slurry containing the by-product phosphogypsum is pumped onto a disposal site. Over

time the solids in the slurry build up and a stack forms. The stacks are generally built on

unused or mined out land on the processing site.

As the stack grows, the phosphogypsum slurry begins to form a small pond (gypsum pond) on

top of the stack. Workers dredge gypsum from the pond to build up the dike around it and the

pond gradually becomes a reservoir for storing and supplying process water. A total of 63

phosphogypsum stacks were identified nationwide in 1989. They were in 12 different states,

but the majority, two-thirds, were in Florida, Texas, Illinois, and Louisiana.

The surface area covered by stacks ranges from about 5 to 740 acres. The height ranges from

about 10 to 200 feet. In 1989, the total surface area covered by stacks was about 8,500

acres. More than half that acreage is in Florida.

The tops of operating phosphogypsum stacks (ones that are still receiving phosphogypsum)

are covered by ponds and ditches containing process water. "Beaches," saturated land

masses, protrude into the ponds. These surface features may cover up to 75 percent of the

top of the stack. Other surface features include areas of loose, dry materials; access roads;

and thinly crusted stack sides. (The crust thickens and hardens when the stacks become

inactive and no longer receive process slurry.)

Radioactivity in Phosphogypsum

How much radioactivity is in the phosphogypsum?

The concentrations of uranium and radium-226 in phosphogypsum samples taken in central

Florida were about 10 times the background levels in soil for uranium and 60 times the

background levels in soil for radium-226.

The radium-226 concentration in phosphogypsum varies significantly at different sampling

locations on a single stack and also in phosphogypsum from different stacks within the same

geographical area.

How are people exposed to the radiation from phosphogypsum

stacks if they don’t go near them?

Radionuclides that are small particles (i.e., radionuclide dust) can become airborne as wind-

blown dust or as dust thrown up into the air by cars and trucks. The radionuclides, uranium

and radium-226, are present in the phosphogypsum and can become airborne. Once these

radionuclides are in the air, people and animals can breathe them and they can settle out onto

ponds and agricultural areas. Radon-222, a decay product of radium-226, is a gas and so may

become airborne by diffusing into the air. EPA has determined, however, that the risks

associated with stacking phosphogypsum are in line with acceptable risk practices.

Other Phosphogypsum Constituents of Concern

In addition to the radiation health hazards covered by Subpart R, phosphogypsum contains

some trace metals in concentrations that EPA believes may pose a chemical hazard to human

health and the environment. Analysis of samples from various facilities contained arsenic,

lead, cadmium, chromium, fluoride, zinc, antimony, and copper at concentrations that may

pose significant health risks. The concentrations of these contaminants vary by more than

three orders of magnitude among samples taken from various locations. These trace metals

may also be leached from phosphogypsum and migrate to nearby surface and groundwater

resources.

The presence of these trace metals in phosphogypsum is mentioned here in order to provide a

more complete description of phosphogypsum, but they are not to be addressed in the risk

assessment.

Adverse Effects Sodium fluosilicate CAS No. 16893-85-9 http://www.fluoridealert.org/pesticides/epage.sodium.fluosilicate.htm Activity: Insecticide, Wood preservative, US EPA List 3 Inert (Inorganic) Structure:

Adverse Effects: Anemia Apoptosis Ataxia Bladder Blood Body Weight Decrease (including Cachexia, Wasting, Anorexia) Bone Dermal Heart Kidney Liver Lung Spleen Poisoning Incident

The major use is as a fluoridation agent for drinki ng water.

• Some common synonymns: Sodium Silicofluroide and Sodium Hexafluorosilicate

• "Sodium fluosilicate (sodium silico fluoride) has b een used to control ectoparasites on livestock, as well as crawling ins ects in homes and work buildings. It is approximately as toxic as sod ium fluoride [highly toxic to all plant and animal life]. All uses in th e U.S. have been cancelled." Ref: Recognition and Management of Pesticide Poisonings, 5th Edition, Chapter 8. The Office of Pesticide Programs, US EPA http://www.epa.gov/oppfead1/safety/healthcare/handb ook/Chap08.pdf

• The major use of sodium hexafluorosilicate and fl uorosilicic acid is as fluoridation agents for drinking water. Sodium hexafluorosilicate has also been used for caries control as part of a sili cophosphate cement, an acidic gel in combination with monocalcium phosp hate monohydrate, and a two-solution fluoride mouth rins e. Both chemicals are also used as a chemical intermediate (raw mater ial) for aluminum trifluoride, cryolite (Na3AlF6), silicon tetrafluor ide, and other fluorosilicates and have found applications in comm ercial laundry. Other applications for sodium hexafluorosilicate in clude its use in

enamels/enamel frits for china and porcelain, in op alescent glass, metallurgy (aluminum and beryllium), glue, ore flot ation, leather and wood preservatives , and in insecticides and rodenticides . It has been used in the manufacture of pure silicon, as a gelli ng agent in the production of molded latex foam, and as a fluorinat ing agent in organic synthesis to convert organodichlorophosphorus compo unds to the corresponding organodifluorophosphorus compound. In veterinary practice, external application of sodium hexafluoro silicate combats lice and mosquitoes on cattle, sheep, swine, and poultry , and oral administration combats roundworms and possibly whip worms in swine and prevents dental caries in rats . Apparently, all pesticidal products had their registrations cancelled or they were discontinued by the early 1990s... Exposure to sodium hexafluoro silicate is possible from its use to control crawling insects in homes and work build ings . The chemical has "high inherent toxicity," and chil dren may ingest the material from crawling on the floors of treated hou ses (U.S. EPA, 1999).

Ref: Toxicological Summary for Sodium Hexafluorosil icate [CASRN 16893-85-9] and Fluorosilicic Acid [CASRN 16961-83- 4]. Review of Toxicological Literature. October 2001. Prepared fo r Scott Masten, Ph.D. National Institute of Environmental Health Sc iences. http://ntp-server.niehs.nih.gov/htdocs/Chem_Backgro und/ExSumPDF/Fluorosilicates.pdf

NOTE FROM FAN: Sodium hexafluorosilicate is a US EPA List 3 Inert, which means it is currently used in pesticidal formulations in the US . Due to the absurdities of US EPA policy on "Inerts", the publi c is not allowed to know which inerts are used in pesticides. Inerts ca n account for as much as 99.9 % of a pesticidal formulation. US EPA' s practice on "Inerts" is wholly unscientific and an insult to a democatic society. Toxicological data on the majority of Inerts is not available, because they have not been studied, and most likely many ar e industrrial toxic waste products. And it is these chemicals tha t we grow our food with in the United States.

This chemical is unique in that it has received som e public examination because of the fluoridation issue. This is because it is used as a "fluoridating chemical" in the US, and th e issue of "dissassociation" arose which has forced EPA to beg in a first-time study of it. In April 2002, US EPA put out a Reques t for Proposals for this study. EC.

Oborova norma ON 653130, Ministry of Industry, Prag ue, Czechoslovakia, 7 pages, 1969

Commercial Sodium Silicofluoride

Anonymous Sodium-silicofluoride (Na2SiF6), used mainly in the glass industry, in building construction and in the production of inse cticides and foam rubber, is a toxic substance. The threshold limit value is 1 milligram per cubic meter, and the emergency exposure limit, 2 milligrams per

cubic meter. Workers should avoid all direct contact; they shoul d wear goggles, respirators, protective clothing and glove s. Drinking and smoking are forbidden during work. (Czech)

Anemia (click on for all fluorinated pesticides)

Toxicological Data Human Data Chronic exposure to s odium hexafluorosilicate dust at levels above the eight-hour TWA can result in severe calcificati on of the ribs, pelvis, and spinal column ligaments; effects on the enzyme system; pulmonary fibrosis; stiffness; irritation of the eyes, skin, and mucous membranes; weight loss; anorexia; anemia ; cachexia; wasting; and dental effects. Long-term or repeated exposure to the skin can resu lt in skin rash. A probable oral lethal dose of 50-500 mg/kg, classified as very toxic, has been repor ted for a 150-pound (70-kg) person receiving between 1 teaspoon and 1 ounce of sodium hexafluoro silicate. Ref: Review of Toxicological Literature. October 20 01. Sodium Hexafluorosilicate [CASRN 16893-85-9] and Fluorosilicic Acid [CASRN 16961-83-4]. Prepa red for Scott Masten, Ph.D. National Institute of Environmental Health Sciences P.O. Box 12233 Resear ch Triangle Park, North Carolina 27709. Contract No. N01-ES-65402. Submitted by Karen E. Ha neke, M.S. (Principal Investigator) Bonnie L. Carson, M.S. (Co-Principal Investigator) Integrated Laboratory Systems P.O. Box 13501 Research Triangle Park, North Carolina 27709. http://www.fluoridealert.org/pesticides/fluorosilic ates.nih.2001.pdf

Apoptosis (click on for all fluorinated pesticides)

SUMMARY: Although potential toxic effects of sodium fluoride on early progenitor and stem cells have been reported previously, surprisin gly few investigations have examined the effects of fluoride on human leukemic cells. To address this need, four different human leukemic cell lines (HL-60, HEL, TF-1, and K562) we re exposed to increasing levels (0, 0.24, and 1.19 mM F) of two forms of fluoride: sodium flu oride (NaF) and sodium hexafluorosilicate (Na2SiF6). Because of its widesp read use in water fluoridation, Na2SiF6 was investigated in addition to NaF . The early response effect of Na2SiF6 was greater, and in several cases significantly greater, than NaF on clonogenic growth and the induction of apoptosis in all four cell lines. These findings show that human leukemic cells can b e influenced and damaged by fluorine compounds. THE INFLUENCE OF SODIUM FLUORIDE AND SODIUM HEXAFLU OROSILICATE ON HUMAN LEUKEMIC CELL LINES. By B Machalinski et al. Fluoride Vol. 36 No. 4 231-240 2003. Full free report available at: http://www.fluoride-journal.com/03-36-4/364-231.pdf

Ataxia (click on for all fluorinated pesticides)

-- Mouse strain, 70 mg/ kg (LD 50 ; 0.37 mmol/ kg); Toxic effects were observed in the peripheral nerves and sensation (flaccid paralysis without ane sthesia, generally neuromuscular blockage) and in behavior ( ataxia and muscle contraction or spasticity). RTECS* (199 7) Ref: Review of Toxicological Literature. October 20 01. Sodium Hexafluorosilicate [CASRN 16893-85-9] and Fluorosilicic Acid [CASRN 16961-83-4]. Prepa red for Scott Masten, Ph.D. National Institute of Environmental Health Sciences P.O. Box 12233 Resear ch Triangle Park, North Carolina 27709. Contract No. N01-ES-65402. Submitted by Karen E. Ha neke, M.S. (Principal Investigator) Bonnie L. Carson, M.S. (Co-Principal Investigator) Integrated Laboratory Systems P.O. Box 13501 Research Triangle Park, North Carolina 27709. http://www.fluoridealert.org/pesticides/fluorosilic ates.nih.2001.pdf

Bladder (click on for all fluorinated pesticides)

-- Mice orally given sodium hexafluorosilicate (70 mg/kg; 0.37 mmol/kg) exhibited toxic effects in the peripheral nerves, sensation, and in behavior. In r ats, an oral dose (248 mg/kg; 1.32 mmol/kg) administered intermittently for one month produced toxic effects in the kidney, ureter, and/or bladder, as well as musculoskeletal and biochemical effects (RTECS, 1997). Using guinea pigs,

inhalation experiments (13-55 mg/m 3 [1.7-7.2 ppm] sodium hexafluorosilicate in air for ¥6 hours) resulted in pulmonary irritation; the lowest concen tration that caused death was 33 mg/m 3 (4.3 ppm) (Patty, 1963; cited by HSDB, 2000b). -- Rats, oral; 248 mg/ kg (1.32 mmol/ kg) for 30 da ys intermittent; Toxic effects in the kidney, ureter, and/ or bladder (other changes in urine composition) were observed . Musculoskeletal (other changes) and biochemical (enzyme inhibition, induct ion, or changes in blood or tissue [phosphatases] levels) effects were seen. RTECS* (1 997) -- Rats, 70 mg/ kg (LD Lo ; 0.37 mmol/ kg); Fatty l iver degeneration and other changes in the liver an d toxic effects in the kidney, ureter, and bladder primarily changes in glomeruli were observed. RTECS* (1997) Ref: Review of Toxicological Literature. October 20 01. Sodium Hexafluorosilicate [CASRN 16893-85-9] and Fluorosilicic Acid [CASRN 16961-83-4]. Prepa red for Scott Masten, Ph.D. National Institute of Environmental Health Sciences P.O. Box 12233 Resear ch Triangle Park, North Carolina 27709. Contract No. N01-ES-65402. Submitted by Karen E. Ha neke, M.S. (Principal Investigator) Bonnie L. Carson, M.S. (Co-Principal Investigator) Integrated Laboratory Systems P.O. Box 13501 Research Triangle Park, North Carolina 27709. http://www.fluoridealert.org/pesticides/fluorosilic ates.nih.2001.pdf

Blood (click on for all fluorinated pesticides)

-- Rats, oral; 248 mg/ kg (1.32 mmol/ kg) for 30 da ys intermittent; Toxic effects in the kidney, urete r, and/ or bladder (other changes in urine composition ) were observed. Musculoskeletal (other changes) and biochemical (enzyme inhibition, induct ion, or changes in blood or tissue [phosphatases] levels) effects were seen. RTECS* (1 997) -- Sheep, Awassi breed, 1- to 3- yr- old, 5F techni cal sodium hexafluorosilicate, 25, 50, 200, 1500, a nd 2000 mg/ kg (0.13, 0.27, 1.06, 7.976, and 10.63 mmo l/ kg) suspended in water; duration and observation period n. p. With the 25- and 50- mg/ k g doses, animals exhibited grinding of teeth (an indication of pain), dullness, and mild diarrhea. A t 200 mg/ kg, additional symptoms were experienced and included staggering and severe diar rhea. Animals died on day 6. With the two higher doses, licking of the lips, kicking of the b elly, grinding of the teeth, falling down (after 1. 5 h), frothing at the mouth, congested conjunctiva, protr udation of the tongue, forced and labored breathing, fever, and increased respiration and hea rt rates were observed. Animals died 3 h after administration of 1500 mg/ kg and 2.5 h after admin istration of 2000 mg/ kg. Post- mortem examination showed serous pericardial fluid (few mi lliliters), a slightly friable liver, mild edema in the lungs, and froth in the trachea. Hemorrhages occurr ed on the spleen and mucosal folds of the abomasum, and a gelatinous fluid was present in the colon. For the 1500 mg/ kg- dose group, the change in GOT went from 132% (of pretreatment activ ity) at 1.5 hours to 230% at 2.5 hours . For LDH, the change was 158% at death. The serum ICDH [isoci trate dehydrogenase] change increased from 168% after one hour to 984% at death . Egyed and Shlosberg (1975) Ref: Review of Toxicological Literature. October 20 01. Sodium Hexafluorosilicate [CASRN 16893-85-9] and Fluorosilicic Acid [CASRN 16961-83-4]. Prepa red for Scott Masten, Ph.D. National Institute of Environmental Health Sciences P.O. Box 12233 Resear ch Triangle Park, North Carolina 27709. Contract No. N01-ES-65402. Submitted by Karen E. Ha neke, M.S. (Principal Investigator) Bonnie L. Carson, M.S. (Co-Principal Investigator) Integrated Laboratory Systems P.O. Box 13501 Research Triangle Park, North Carolina 27709. http://www.fluoridealert.org/pesticides/fluorosilic ates.nih.2001.pdf

Body Weight Decrease (click on for all fluorinated pesticides)

Toxicological Data. Human Data . Chronic exposure to sodium hexafluorosilicate dus t at levels above the eight-hour TWA can result in severe calcification of the ribs, pelvis, and spina l column ligaments; effects on the enzyme system; pulmonary fibrosis; stiffness; irritation of the eyes, skin, and mucous membranes ; weight loss; anorexia ; anemia; cachexia; wasting ; and dental effects. Long-term or repeated exposure to the skin can resu lt in skin rash. A probable oral lethal dose of 50-500 mg/kg, classified as very toxic, has been repor ted for a 150-pound (70-kg) person receiving between 1 teaspoon and 1 ounce of sodium hexafluoro silicate. Cases of sodium hexafluorosilicate ingestion reported symptoms such as acute respirato ry failure, ventricular tachycardia and fibrillation, hypocalcemia, facial numbness, diarrh ea, tachycardia, enlarged liver, and cramps of the palms, feet, and legs. ---- [Note from FAN. see: Case definition of AIDS as cachexia is cited.]

Ref: Sodium Hexafluorosilicate [CASRN 16893-85-9] a nd Fluorosilicic Acid [CASRN 16961-83-4]. Review of Toxicological Literature. October 2001. P repared for Scott Masten, Ph.D. National Institute of Environmental Health Sciences P.O. Box 12233 Res earch Triangle Park, North Carolina 27709 Contract No. N01-ES-65402. Submitted by Karen E. Ha neke, M.S. (Principal Investigator) Bonnie L. Carson, M.S. (Co-Principal Investigator) Integrated Laboratory Systems P.O. Box 13501 Research Triangle Park, North Carolina 27709. http://www.fluoridealert.org/pesticides/fluorosilic ates.nih.2001.pdf

Bone (click on for all fluorinated pesticides)

-- Toxicological Data. Human Data . Chronic exposure to sodium hexafluorosilicate dus t at levels above the eight-hour TWA can result in severe calcification of the ribs, pelvis, and spin al column ligaments; effects on the enzyme system; pulmonary fibrosis; stiffness; irritation of the eyes, skin, and mucous membranes; weight loss; anorexia; anemia ; cachexia; wasting; and dental effects. Long-term or repeated exposure to the skin can resu lt in skin rash. A probable oral lethal dose of 50-500 mg/kg, classified as very toxic, has been repor ted for a 150-pound (70-kg) person receiving between 1 teaspoon and 1 ounce of sodium hexafluoro silicate. Cases of sodium hexafluorosilicate ingestion reported symptoms such as acute respirato ry failure, ventricular tachycardia and fibrillation, hypocalcemia, facial numbness, diarrh ea, tachycardia, enlarged liver, and cramps of the palms, feet, and legs. -- Mice orally given sodium hexafluorosilicate (70 mg/kg; 0.37 mmol/kg) exhibited toxic effects in the peripheral nerves, sensation, and in behavior. In r ats, an oral dose (248 mg/kg; 1.32 mmol/kg) administered intermittently for one month produced toxic effects in the kidney, ureter, and/or bladder, as well as musculoskeletal and biochemical effects (RTECS, 1997). Using guine a pigs, inhalation experiments (13-55 mg/m 3 [1.7-7.2 ppm] sodium hexafluorosilicate in air for ¥6 hours) resulted in pulmonary irritation; the lowest concen tration that caused death was 33 mg/m 3 (4.3 ppm) (Patty, 1963; cited by HSDB, 2000b). Ref: Sodium Hexafluorosilicate [CASRN 16893-85-9] a nd Fluorosilicic Acid [CASRN 16961-83-4]. Review of Toxicological Literature. October 2001. P repared for Scott Masten, Ph.D. National Institute of Environmental Health Sciences P.O. Box 12233 Res earch Triangle Park, North Carolina 27709 Contract No. N01-ES-65402. Submitted by Karen E. Ha neke, M.S. (Principal Investigator) Bonnie L. Carson, M.S. (Co-Principal Investigator) Integrated Laboratory Systems P.O. Box 13501 Research Triangle Park, North Carolina 27709. http://www.fluoridealert.org/pesticides/fluorosilic ates.nih.2001.pdf

Dermal (click on for all fluorinated pesticides)

-- Within one week after beginning work in a foam r ubber plant, a 23-year-old man exhibited skin lesions consisting of "diffuse, poorly delineated, erythematous plaques with lichenoid papules and large pustules " on his arms, wrists, thighs, and trunk. Although scratch and patch tests with sodium hexafluorosilicate (2% aqueous) were negative, anim al testing showed the compound to be a pustulogen . When rabbits received topical application of a 1, 5, 10, and 25% solution of sodium hexafluorosilicate in petroleum, pustules occurred on normal skin only with the high concentration, while all concentrations produced pustules on stabbed skin (Dooms-Goossens et al., 1985). -- -- Rabbits, New Zealand; 0.5 mL (4 mol) to the i ntact and abraded skin for 1, 24, or 72 h Severe erythema and edema were observed, indicating the material to be a pri mary irritant. Rhone- Poulenc Inc. (1971) Ref: Review of Toxicological Literature. October 20 01. Sodium Hexafluorosilicate [CASRN 16893-85-9] and Fluorosilicic Acid [CASRN 16961-83-4]. Prepa red for Scott Masten, Ph.D. National Institute of Environmental Health Sciences P.O. Box 12233 Resear ch Triangle Park, North Carolina 27709. Contract No. N01-ES-65402. Submitted by Karen E. Ha neke, M.S. (Principal Investigator) Bonnie L. Carson, M.S. (Co-Principal Investigator) Integrated Laboratory Systems P.O. Box 13501 Research Triangle Park, North Carolina 27709. http://www.fluoridealert.org/pesticides/fluorosilic ates.nih.2001.pdf

• Definition for Erythema - abnormal redness of the skin resulting from dilation of blood vessels (as in sunburn or inflammation)

Heart (click on for all fluorinated pesticides)

-- Toxicological Data. Human Data . Chronic exposure to sodium hexafluorosilicate dus t at levels above the eight-hour TWA can result in severe calcification of the ribs, pelvis, and spina l column ligaments; effects on the enzyme system; pulmonary fibrosis; stiffness; irritation of the eyes, skin, and mucous membranes; weight loss; anorexia; anemia ; cachexia; wasting; and dental effects. Long-term or repeated exposure to the skin can resu lt in skin rash. A probable oral lethal dose of 50-500 mg/kg, classified as very toxic, has been repor ted for a 150-pound (70-kg) person receiving between 1 teaspoon and 1 ounce of sodium hexafluoro silicate. Cases of sodium hexafluorosilicate ingestion reported symptoms such as acute respiratory failure, ventricular tachycardia and fibrillation , hypocalcemia, facial numbness, diarrhea, tachycardia , enlarged liver, and cramps of the palms, feet, and legs. -- -- Guinea pigs, 13- 55 mg/ m 3 (1.2- 7.2 ppm) in air for ¥ 6 h; Pulmonary irritation was observed. The lowest concentration that caused death when inhaled for 6 h was 33 mg/ m 3 . Patty (1963; cited by HSDB, 2000b) -- -- Mice orally given sodium hexafluorosilicate ( 70 mg/kg; 0.37 mmol/kg) exhibited toxic effects in the peripheral nerves, sensation, and in behavior. In rats, an oral dose (248 mg/kg; 1.32 mmol/kg) administered intermittently for one month produced toxic effects in the kidney, ureter, and/or bladder, as well as musculoskeletal and biochemical effects (RTECS, 1997). Using guinea pigs, inhalation experiments (13-55 mg/m 3 [1.7-7.2 ppm] sodium hexafluorosilicate in air for ¥6 hours) resulted in pulmonary irritation ; the lowest concentration that caused death was 33 mg/m 3 (4.3 ppm) (Patty, 1963; cited by HSDB, 2000b). Ref: Sodium Hexafluorosilicate [CASRN 16893-85-9] a nd Fluorosilicic Acid [CASRN 16961-83-4]. Review of Toxicological Literature. October 2001. P repared for Scott Masten, Ph.D. National Institute of Environmental Health Sciences P.O. Box 12233 Res earch Triangle Park, North Carolina 27709 Contract No. N01-ES-65402. Submitted by Karen E. Ha neke, M.S. (Principal Investigator) Bonnie L. Carson, M.S. (Co-Principal Investigator) Integrated Laboratory Systems P.O. Box 13501 Research Triangle Park, North Carolina 27709. http://www.fluoridealert.org/pesticides/Fluorosilic ates.NIH.2001.pdf

Kidney (click on for all fluorinated pesticides)

-- Mice orally given sodium hexafluorosilicate (70 mg/kg; 0.37 mmol/kg) exhibited toxic effects in the peripheral nerves, sensation, and in behavior. In r ats, an oral dose (248 mg/kg; 1.32 mmol/kg) administered intermittently for one month produced toxic effects in the kidney, ureter, and/or bladder, as well as musculoskeletal and biochemical effects (RTECS, 1997). Using guinea pigs, inhalation experiments (13-55 mg/m 3 [1.7-7.2 ppm] sodium hexafluorosilicate in air for ¥6 hours) resulted in pulmonary irritation; the lowest concen tration that caused death was 33 mg/m 3 (4.3 ppm) (Patty, 1963; cited by HSDB, 2000b). -- Mouse strain, 70 mg/ kg (LD 50 ; 0.37 mmol/ kg); Toxic effects were observed in the peripheral nerves and sensation (flaccid paralysis without ane sthesia, generally neuromuscular blockage) and in behavior (ataxia and muscle contraction or spast icity). RTECS* (1997) -- Rats, oral; 248 mg/ kg (1.32 mmol/ kg) for 30 da ys intermittent; Toxic effects in the kidney, ureter, and/ or bladder (other changes in urine composition ) were observed. Musculoskeletal (other changes) and biochemical (enzyme inhibition, induct ion, or changes in blood or tissue [phosphatases] levels) effects were seen. RTECS* (1 997) -- Rats, 70 mg/ kg (LD Lo ; 0.37 mmol/ kg); Fatty l iver degeneration and other changes in the liver an d toxic effects in the kidney, ureter, and bladder primarily changes in glomeruli were observed. RTECS* (1997) Ref: Review of Toxicological Literature. October 20 01. Sodium Hexafluorosilicate [CASRN 16893-85-9] and Fluorosilicic Acid [CASRN 16961-83-4]. Prepa red for Scott Masten, Ph.D. National Institute of Environmental Health Sciences P.O. Box 12233 Resear ch Triangle Park, North Carolina 27709. Contract No. N01-ES-65402. Submitted by Karen E. Ha neke, M.S. (Principal Investigator) Bonnie L. Carson, M.S. (Co-Principal Investigator) Integrated Laboratory Systems P.O. Box 13501 Research Triangle Park, North Carolina 27709. http://www.fluoridealert.org/pesticides/gluorosilic ates.nih.2001.pdf

Liver (click on for all fluorinated pesticides)

Sheep, Awassi breed, 1- to 3- yr- old, 5F technical sodium hexafluorosilicate, 25, 50, 200, 1500, and 2000 mg/ kg (0.13, 0.27, 1.06, 7.976, and 10.63 mmo l/ kg) suspended in water; duration and observation period n. p. With the 25- and 50- mg/ k g doses, animals exhibited grinding of teeth (an

indication of pain), dullness, and mild diarrhea. A t 200 mg/ kg, additional symptoms were experienced and included staggering and severe diar rhea. Animals died on day 6. With the two higher doses, licking of the lips, kicking of the b elly, grinding of the teeth, falling down (after 1. 5 h), frothing at the mouth, congested conjunctiva, protr udation of the tongue, forced and labored breathing, fever, and increased respiration and hea rt rates were observed. Animals died 3 h after administration of 1500 mg/ kg and 2.5 h after administration of 2000 mg/ kg. Post- morte m examination showed serous pericardial fluid (few mi lliliters), a slightly friable liver , mild edema in the lungs, and froth in the trachea. Hemorrhages occurr ed on the spleen and mucosal folds of the abomasum, and a gelatinous fluid was present in the colon. For the 1500 mg/ kg- dose group, the change in GOT went from 132% (of pretreatment activ ity) at 1.5 hours to 230% at 2.5 hours. For LDH, the change was 158% at death. The serum ICDH [isoci trate dehydrogenase] change increased from 168% after one hour to 984% at death. Egyed and Shl osberg (1975) -- Toxicological Data. Human Data . Chronic exposure to sodium hexafluorosilicate dus t at levels above the eight-hour TWA can result in severe calcification of the ribs, pelvis, and spina l column ligaments; effects on the enzyme system; pulmonary fibrosis; stiffness; irritation of the eyes, skin, and mucous membranes; weight loss; anorexia; anemia ; cachexia; wasting; and dental effects. Long-term or repeated exposure to the skin can resu lt in skin rash. A probable oral lethal dose of 50-500 mg/kg, classified as very toxic, has been repor ted for a 150-pound (70-kg) person receiving between 1 teaspoon and 1 ounce of sodium hexafluoro silicate. Cases of sodium hexafluorosilicate ingestion reported symptoms such as acute respirato ry failure, ventricular tachycardia and fibrillation, hypocalcemia, facial numbness, diarrh ea, tachycardia, enlarged liver , and cramps of the palms, feet, and legs. Ref: Sodium Hexafluorosilicate [CASRN 16893-85-9] a nd Fluorosilicic Acid [CASRN 16961-83-4]. Review of Toxicological Literature. October 2001. P repared for Scott Masten, Ph.D. National Institute of Environmental Health Sciences P.O. Box 12233 Res earch Triangle Park, North Carolina 27709 Contract No. N01-ES-65402. Submitted by Karen E. Ha neke, M.S. (Principal Investigator) Bonnie L. Carson, M.S. (Co-Principal Investigator) Integrated Laboratory Systems P.O. Box 13501 Research Triangle Park, North Carolina 27709. http://www.fluoridealert.org/pesticides/fluorosilic ates.nih.2001.pdf

Lung (click on for all fluorinated pesticides)

-- Toxicological Data. Human Data . Chronic exposure to sodium hexafluorosilicate dus t at levels above the eight-hour TWA can result in severe calcification of the ribs, pelvis, and spina l column ligaments; effects on the enzyme system; pulmonary fibrosis ; stiffness; irritation of the eyes, skin, and mucous membranes; weight loss; anorexia; anemia ; cachexia; wasting; and dental effects. Long-term or repeated exposure to the skin can resu lt in skin rash. A probable oral lethal dose of 50-500 mg/kg, classified as very toxic, has been repor ted for a 150-pound (70-kg) person receiving between 1 teaspoon and 1 ounce of sodium hexafluoro silicate. Cases of sodium hexafluorosilicate ingestion reported symptoms such as acute respiratory failure , ventricular tachycardia and fibrillation, hypocalcemia, facial numbness, diarrh ea, tachycardia, enlarged liver, and cramps of the palms, feet, and legs. -- -- Guinea pigs, 13- 55 mg/ m 3 (1.2- 7.2 ppm) in air for ¥ 6 h; Pulmonary irritation was observed. The lowest concentration that caused death when inhaled for 6 h was 33 mg/ m 3 . Patty (1963; cited by HSDB, 2000b) -- -- Mice orally given sodium hexafluorosilicate ( 70 mg/kg; 0.37 mmol/kg) exhibited toxic effects in the peripheral nerves, sensation, and in behavior. In rats, an oral dose (248 mg/kg; 1.32 mmol/kg) administered intermittently for one month produced toxic effects in the kidney, ureter, and/or bladder, as well as musculoskeletal and biochemical effects (RTECS, 1997). Using guinea pigs, inhalation experiments (13-55 mg/m 3 [1.7-7.2 ppm] sodium hexafluorosilicate in air for ¥6 hours) resulted in pulmonary irritation ; the lowest concentration that caused death was 33 mg/m 3 (4.3 ppm) (Patty, 1963; cited by HSDB, 2000b). Ref: Sodium Hexafluorosilicate [CASRN 16893-85-9] a nd Fluorosilicic Acid [CASRN 16961-83-4]. Review of Toxicological Literature. October 2001. P repared for Scott Masten, Ph.D. National Institute of Environmental Health Sciences P.O. Box 12233 Res earch Triangle Park, North Carolina 27709 Contract No. N01-ES-65402. Submitted by Karen E. Ha neke, M.S. (Principal Investigator) Bonnie L. Carson, M.S. (Co-Principal Investigator) Integrated Laboratory Systems P.O. Box 13501 Research Triangle Park, North Carolina 27709. http://www.fluoridealert.org/pesticides/fluorosilic ates.nih.2001.pdf

Poisoning Incident

A 2 1/2 year old colored girl was brought to the em ergency room with progressive vomiting and lethargy of about six hours' duration. The respirat ory rate was only 6 to 8 breaths per minute. The child had a disconjugate gaze with coarse horizonta l nystagmus and muscular fasciculation throughout the body. A soft systolic ejection murmu r was audible at the left sternal border. The child had been playing with a laundry powder ca lled "Rayline Brand Laundry Sout" (manufactured by BASF, Wyandotte Corporation in Mic higan) which contained sodium silicofluoride . Na2S4F6 as its major ingredient. Laboratory data showed a BUN of 31 mg/100 ml, 2 + p rotein and 40 red blood cells/high power field. The plasma sodium was 138 mEq/liter, potassium 6.7, bicarbonate 13 and chloride 107. Serum calcium was 3.4 mg/100 ml, the lowest ever re ported in fluoride poisoning. The EKG showed peaked t-waves which were inverted in the chest leads. After admission the patient developed acute respira tory failure which required assisted ventilation for 48 hours. Repeated episodes of ventricular tach ycardia and fibrillation were treated with lidocaine and eight separate courses of direct curr ent cardioversion. The hypocalcemia was treated with three intravenous infusions of 10% calcium chl oride (0.3 gms) followed by calcium gluconate and 0.1% calcium hydroxide (lime water) and aluminu m hydroxide by nasogastric tube which brought the serum calcum up to 13 mg/100 ml. Aspira tion pneumonia required penicillin, kanamycin, and dexamethasone. Peritoneal dialysis was institut ed with a calcium concentration of 10 mg/100 ml and continued for 48 hours. The patient became responsive 18 hours after admiss ion and returned to full consciousness two days later. There were no mucosal burns or ulcerati ons and the upper gastrointestinal examination was normal. The serum fluoride levels were extremely high (14 m g/liter) but dropped to 1.8 mg/liter after 11 hours and to 0.1 mg/liter 21 hours after the ingestion of the poison. Urinary fluoride excretion amounted to 24.8 mg over the first three days. The average fluoride clearance was 98 ml/min/1.73 s q m. In view of the fact serum levels above 3 mg/liter had been fatal in oth er cases , the authors attributed the improvement mainly to the gastric lavage with calci um salts and to the maintanence of a urinary output. Peritoneal dialysis resulted in no signific ant removal of fluoride. The fluoride level of the effluent was less than the fluoride level of the bo ttled dialysate, which had evidently been prepared from fluoridated water. Ref: Yolken R, Konecny P, McCarthy P (1976). Acute fluoride poisoning . Pediatrics 1976; 58:90-93. As abstracted in Fluoride 1977; 10(1):38-39

Spleen (click on for all fluorinated pesticides)

-- Sheep, Awassi breed, 1- to 3- yr- old, 5F techni cal sodium hexafluorosilicate, 25, 50, 200, 1500, a nd 2000 mg/ kg (0.13, 0.27, 1.06, 7.976, and 10.63 mmo l/ kg) suspended in water; duration and observation period n. p. With the 25- and 50- mg/ k g doses, animals exhibited grinding of teeth (an indication of pain), dullness, and mild diarrhea. A t 200 mg/ kg, additional symptoms were experienced and included staggering and severe diar rhea. Animals died on day 6. With the two higher doses, licking of the lips, kicking of the b elly, grinding of the teeth, falling down (after 1. 5 h), frothing at the mouth, congested conjunctiva, protr udation of the tongue, forced and labored breathing, fever, and increased respiration and hea rt rates were observed. Animals died 3 h after administration of 1500 mg/ kg and 2.5 h after admin istration of 2000 mg/ kg. Post- mortem examination showed serous pericardial fluid (few mi lliliters), a slightly friable liver, mild edema in the lungs, and froth in the trachea. Hemorrhages occurred on the spleen and mucosal folds of the abomasum, and a gelatinous fluid was present in the colon. For the 1500 mg/ kg- dose group, the change in GOT went from 132% (of pretreatment activ ity) at 1.5 hours to 230% at 2.5 hours. For LDH, the change was 158% at death. The serum ICDH change increased from 168% after one hour to 984% at death. Egyed and Shlosberg (1975) Ref: Review of Toxicological Literature. October 20 01. Sodium Hexafluorosilicate [CASRN 16893-85-9] and Fluorosilicic Acid [CASRN 16961-83-4]. Prepa red for Scott Masten, Ph.D. National Institute of Environmental Health Sciences P.O. Box 12233 Resear ch Triangle Park, North Carolina 27709. Contract No. N01-ES-65402. Submitted by Karen E. Ha neke, M.S. (Principal Investigator) Bonnie L. Carson, M.S. (Co-Principal Investigator) Integrated Laboratory Systems P.O. Box 13501 Research Triangle Park, North Carolina 27709. http://www.fluoridealert.org/pesticides/fluorosilic ates.nih.2001.pdf

Sept., 1938

American Journal of Public Healthand THE NATION'S HEALTH

Official Monthly Publication of the American Public Health Association

Volume 28 September, 1938 Number 9

MAZYCK P. RAVENEL, M.D., Editor AUGUSTA JAY, Editorial AssociateREGINALD M. ATWATER, M.D., Managing Editor

Editorial BoardTHE MANAGING EDITOR, ChairmanPROF. IRA V. HIscocKKENNETH F. MAXCY, M.D.ARTHUR P. MILLER, C.E.HARRY S. MUSTARD, M.D.

THE NEW FEDERAL LAWS RELATING TO FOODS,DRUGS, AND COSMETICS

A FTER five years of consideration,' the Congress of the United States hasX finally adopted two important new laws to amend and strengthen the moreor less obsolescent Federal Food and Drug Act of 1906. One of these measures,giving the Federal Trade Commission jurisdiction over false advertising of foods,drugs, devices, and cosmetics, was signed by the President on March 21, 1938,to become effective 60 days from that date; the other measure, a new FederalFood, Drug, and Cosmetic Act, was signed on June 25, 1938, and becomeseffective one year from that date, except that several sections, including one(Sec. 701) authorizing the Secretary of Agriculture to hold hearings and promul-gate regulations for the enforcement of the act became effective on the date ofapproval of the law. The Secretary is also authorized to designate prior to theeffective date food having common or usual names and exempt such food from therequirement of the act, but only for a reasonable time to permit the formulation,promulgation, and effective application of definitions and standards of identity.

Under the terms of the first law mentioned, which is officially designated asPublic-No. 447-75th Congress, and is popularly known as the Wheeler-LeaAct, the jurisdiction of the Federal Trade Commission is extended to the adver-tising of all foods, drugs, diagnostic and therapeutic devices, and cosmetics(except soap) in interstate and foreign commerce, or through the mails. When-ever the Commission believes that any person, partnership, or corporation isengaged in, or is about to engage in, the dissemination of false advertising, definedas " an advertisement, other than labeling, which is misleading in a materialrespect," the Commission may bring suit in a federal district court to enjoin thedissemination of the advertisement. If the commodity advertised is injuriousto health because of its use in accordance with its advertising, or the advertisingis intended to defraud or mislead, the advertiser may be haled -to court andprosecuted criminally without previous notice. Ordinarily, however, false adver-tising is regarded as an unfair or deceptive trade practice, with the advertisersubject to a proceeding by the Commission consisting of notice, a hearing, and,if the findings justify it, the issuance of a cease and desist order, which may

[11141

EDITORIALS

be appealed to a federal circuit court of appeals, and finally to the SupremeCourt.

In determining whether an advertisement is false, the law states that thereshall be taken into account (among other things) not only representations madeor suggested by statement, word, design, device, sound, or any combinationthereof, but also the extent to which the advertisement fails to reveal materialfacts. Advertisements of drugs are not deemed false when disseminated onlyto the medical profession, provided they disclose the formula and contain nofalse representation of material facts. Publishers, radio-broadcast licensees, andadvertising agencies will not be liable for the false advertising of manufacturersand sellers if they furnish to the Commission on request the name and addressof the person responsible for the advertisement.

This somewhat drastic law, if reasonably enforced, should have a salutaryeffect upon the nature of food, drug, device, and cosmetic advertising in inter-state commerce, although it seems likely that the law will give rise to muchtime consuming litigation. It is also unfortunate that there should have beenthe division of authority between the Federal Trade Commission and the U. S.Dqpartment of Agriculture, which has had and continues to have jurisdictionover the labeling and the adulteration of these same products. Not only is thisdepartment equipped by training and experience to carry out the necessary admin-istrative duties, but it has adequate laboratory and technical facilities for thepurpose.2

Under the terms of the new Federal Food, Drug, and Cosmetic Act (Public-No. 717-75th Congress), the adulteration or misbranding of any food, drug,diagnostic or therapeutic device, or cosmetic (except soap) in interstate com-merce is prohibited. This act not only gives administrative jurisdiction to theSecretary of Agriculture over devices and cosmetics, which were not included inthe law of 1906, but it also provides for injunction proceedings in federal districtcourts to enjoin adulteration and misbranding of foods, drugs, devices, andcosmetic, as well as providing for the customary criminal actions for violations,and for seizures and destruction by court action of dangerous and fraudulentcommodities. In order to carry out the purposes of the act, the Secretary ofAgriculture is authorized to promulgate necessary regulations.

Since the law is a lengthy one, and it is difficult to review all of its manyspecific provisions within the limited space of an editorial, it is suggested thathealth officals and other interested sanitarians secure copies of the act from theU. S. Department of Agriculture, for careful study.

In general, however, it may be stated that the new law contains comprehensiveand somewhat broadened definitions of adulteration and misbranding of thevariouis products, so as to include in the former category not only the presence ofpoisonous or deleterious substances that are injurious to health, but the absenceof valuable constituents, the substitution of inferior materials, and, in the caseof drugs, substandard quality, purity, or strength. Under misbranding is includednot only false and misleading labels, but improper imitations of labels of otherproducts, misleading containers, and in cases of foods for special dietary uses,failure to give information as to vitamin, mineral, and other dietary properties.Special labels are required on drugs containing habit-forming narcotics, withadequate directions for use and suitable warnings on such labels. In the sectionon cosmetics there is a provision that coal-tar hair dyes must be labelled with a

1115Vol. 28

1116 AMERICAN JOURNAL OF PUBLIC HEALTH Sept., 1938

caution against their use for dyeing eyebrows and eyelashes, and the statementthat such use may cause blindness.

An important section of the law requires that new drugs can be introducedin interstate commerce only after filing an application, with submission of evi-dence and data, and the securing of a permit from the Secretary. Refusal bythe Secretary of such a permit may be appealed to the federal courts. If thisprovision of the law had been in effect a year ago, the series of unfortunatedeaths from the use of an elixir of sulfanilamide probably would not haveoccurred.

The new law does not cover meat and meat food products, which are stillsubject to the Meat Inspection Act of 1907, as amended. It also keeps in effectvarious other existing laws, such as the Butter Standards Act of 1923, the FilledCheese Act of 1896, the Filled Milk Act of 1923, and the Import Milk Act of1927.

The Federal Food, Drug, and Cosmetic Act of 1938, as sponsored by the lateSenator Royal S. Copeland, represents a noteworthy advance over its 32 year oldprecursor, the Federal Food and Drug Act of 1906, as occasionally but inade-quately amended. The enforcement of this law after June 25, 1939, should domuch to aid in the protection and promotion of public health in this country.

REFERENCES1. Editorial. The Copeland Bill. A.J.P.H., 25:961 (Aug.), 1935.

E,ditorial. Federal Legislation to Control Foods, Drugs, and Cosmetics. The Copeland Bill. A.J.P.H.,27:381 (Apr.), 1937.

2. Editorial. Wheeler-Lea Bill Giving Federal Trade Commission Jurisdiction Over Foods, Drugs,Devices and Cosmetics Becomes a Law. J.A.M.A., 110:1112 (Apr. 2), 1938.

THE AIRPLANE AND YELLOW FEVERT HE rapid multiplication of airplanes of all types and the tremendous increase

in their use for personal transportation has necessarily been a matter ofgreat concern to all nations. A number of reports have been made and effortsare under way to bring about international agreements and methods for inspectionof passengers and for disinsectization of the planes. The increase in the use ofplanes is shown to some extent by a report' of the examinations made atKhartoum: 287 in 1935; 667 in 1936; and 364 up to July 2, 1937. IndeedKhartoum is now a modern city and the crossroads for airships coming from manydifferent directions. Its airport is the stopping place for night for all of thegreat lanes. Apparently this gives an abundance of time for disinsectization andinspection, which requires a longer or shorter time, according to the arrange-ments of the interior and the number of insects which it is necessary to capture.At least one-half hour is required for inspection. The work of the Customofficers and of the Postal service should be delayed until the planes have beencleared of insects. It is interesting to note that in the Sudan until 1936 theinsecticides employed were " Flit " and " Shelltox," widely used in this country,but since then a cheaper mixture made on the spot is used, which has the addedadvantage of being practically noninflammable.*

Mosquitoes are found chiefly in the compartments occupied by passengers,but also in the baggage compartments, especially in those planes in which theseare reached by a separate door at the side. So far no mosquitoes have been

* Extract of pyrethrum......... 5.8 per cent Tetrachloride of carbon........ 49 per centEssence of citronella ...........2 per cent Kerosene ..... 43.2 per cent

ALCOA Inc Needed Electricity

http://www.cityofalcoa-tn.gov/content/view/full/817

The Little Tennessee River and its hydroelectric potential brought the Alcoa Inc. to East Tennessee in the early 1900’s. In that way, the role of electricity has played a major part in the City of Alcoa and all

of Blount County.

In February 1886, Charles Martin Hall discovered that cryolite, a sodium aluminum

fluoride, in molten state will dissolve aluminum oxide. Using a carbon crucible, Hall isolated aluminum by passing an electric current through the molten mass. He was

issued a patent for this process in April 1889. By the end of that year, his company, the Pittsburgh Reduction Company and the predecessor to Alcoa Inc., became a

multi-million-dollar company.

To produce one pound of aluminum required 10 kilowatts (the amount to burn a 40-watt bulb for 10 days). Thus, Alcoa Inc. created a massive plan for developing the entire watershed of the Little Tennessee River in 1910, and built six major dams over several decades. Cheoah Dam, at 230 feet, the highest in the world at the time it was built in 1919, is located on the Little Tennessee River just

upstream from the mouth of the Cheoah River.

Then, Santeelah Dam was constructed in 1926. Located nine miles from the mouth of the Cheoah River, its powerhouse is located three miles above Cheoah Dam. A five-mile conduit transports water to the powerhouse. Calderwood Dam, a 230-foot arch type dam nine miles downstream from Cheoah Dam followed in 1930. A pressure tunnel one-half mile long transports water from the reservoir to the Cheoah powerhouse. By 1937, the combined output of Cheoah, Santeelah and Calderwood at 330,000

horsepower was 265,000 KVA.

Although Alcoa Inc. also built two dams in North Carolina, Chilhowee Dam was the last Alcoa Inc. dam in Tennessee completed in 1957. The project relocated more than three miles of Highway 129, and the

lake covers 1,750 acres with a 30-mile shoreline. This dam measures 88 feet high and 1,370 feet long.

In 1941, Alcoa Inc. relinquished approximately 1,500 acres to TVA, which built Fontana Dam. In addition, TVA took over the regulation of the water flow at all of Alcoa Inc.’s facilities on the Little Tennessee River. In return, Alcoa Inc.’s benefits included a better-integrated system, property retention

and credit for the electricity generated by the plants. In 1957, some of the transmission lines for this

system were transferred to the City of Alcoa’s Blount Electric System, known today as the City of Alcoa Electric Department.

Meanwhile, in 1913, Alcoa Inc. opened its smelter, which would turn alumina into molten aluminum.

The first fabricating operation, known as the West Plant, opened in 1920 to produce items ranging from aluminum pie plates and siding to aluminum for patio furniture and pots and pans.

As the United States was on the verge of entering World War II, Alcoa Inc. experienced a 600 percent production increase and a $300 million expansion. By 1942, the North Plant fabricating facility was in

operation, making aluminum sheet for the 300,000 airplanes built for the war.

In 1943, the aluminum industry was the largest single electricity user in the U.S., consuming 22 billion kilowatts annually. By 1945, the company’s power plants in East Tennessee and West North Carolina were furnishing 50 percent of Alcoa Inc.’s power, with the other 50 percent purchased from TVA.

In 1965, the company entered a new market for aluminum – the beverage can. The Tennessee Operations and its sister plant in Evansville, Indiana, were chosen to lead the effort in can sheet production. However, to handle the millions of aluminum cans already being recycled in the U.S., Alcoa Inc. opened a can reclamation facility at Tennessee Operations in 1975.

In 1989, the West Plant was shut down. In 1990, the WWII vintage hotline was replaced with a state-of-the-art, five-stand mill. Tennessee Operations continues to produce molten metal in its smelter, and the company is considered a world benchmark in the production of high quality aluminum can sheet.

http://goliath.ecnext.com/coms2/gi_0199-4464657/Alc oa-subsidiary-receives-long-term.html

Alcoa subsidiary receives long term contract from L ockheed Martin and Northrop Grumman awarded Global Hawk con tract. Article Excerpt M2 PRESSWIRE-13 July 2005-US Financial Network: Alc oa subsidiary receives long term contract from Lockheed Martin and Northrop Grumman awarded G lobal Hawk contract(C)1994-2005 M2 COMMUNICATIONS LTD RDATE:13072005 City of Industry, CA - Defense industry news provid ed by Financial News... USA (OTC: FNWU). A subsidiary of aluminum giant Alc oa Inc. has agreed to a long-term deal to supply fasteners for the Lockheed...

EPA Cites Alcoa Subsidiary for Hazardous Waste Violations

Release date: 12/31/2003

Contact Information:

(#03146) NEW YORK, N.Y. -- The U.S. Environmental P rotection Agency (EPA) announced today that it has cited Howmet Corporation, a Dover , New Jersey subsidiary of Alcoa Inc ., for violating numerous hazardous waste regulations. The manufacturing facility shipped hazardous waste to another facility to be used in t he production of fertilizer without properly identifying and managing the material as a hazardous waste, as required by the Resource Conservation and Recovery Act (RCRA) .

"The shipment of hazardous wastes requires proper m anagement to ensure protections," said EPA Regional Administrator Jane M. Kenny. "Tha t's why EPA has strict regulations that must be followed whenever companies handle mat erials that could be harmful to people and the environment."

Howmet failed to identify the used potassium hydrox ide (KOH) sent off-site for use in fertilizer as a hazardous waste and did nothing to ensure that it was managed properly. Neither the trucking company that transported the K OH, nor the facility receiving it was authorized to transport, treat, store, or dispose o f hazardous waste. Howmet did not prepare required manifests for the shipment of KOH. These manifests must identify the type and quantity of the hazardous waste being carr ied and designate where the waste is going, which must be a facility permitted to treat, store, and/or dispose of hazardous waste. Finally, the company did not send or maintai n certified notices to the receiving manufacturing facility detailing whether any treatm ent of the KOH hazardous waste was necessary. Howmet is no longer sending the KOH to f ertilizer manufacturing facilities. The company faces an $180,021 penalty for the violation s, and has 30 days to respond to EPA's complaint. In addition to seeking a penalty, EPA has ordered Howmet to comply with all RCRA requirements for managing hazardous w astes when its used KOH is sent off-site to be used in a manner constituting dispos al, as in the production of fertilizer. The company has the right to contest the complaint and the order.

Strategies for Managing the Nation’s Inventory of Depleted Uranium Hexafluoride The U.S. Department of Energy (DOE) is responsible for managing the nation’s stockpile of depleted uranium hexafluoride (UF6 ), most of which is now stored at three DOE sites. EVS helped DOE formulate and compare various long-term management alternatives and combinations of alternatives. EVS’s effort focused on a programmatic environmental impact statement (PEIS), technical analyses, decision-making tools, and a web site to facilitate information exchange with the public. PROBLEM/OPPORTUNITY The first U.S. uranium enrichment effort began in World War II as part of the Manhattan Project to develop the atomic bomb. Enriched uranium, which is used in nuclear reactors as well as weapons, is produced using the gaseous diffusion process. Depleted UF6 is also produced in this process. The depleted UF6 is currently stored at three DOE facilities at Portsmouth, Ohio; Paducah, Kentucky; and Oak Ridge, Tennessee. Since World War II, 560,000 metric tons (46,422 cylinders) of U.S. Government-produced depleted UF6 has accumulated at these sites. In addition, the management of approximately 140,000 metric tons (11,400 cylinders) of depleted UF6 produced by the United States Enrichment Corporation (which assumed responsibility for U.S. enrichment operations in 1993) is being transferred to DOE over time. Although DOE had been storing the depleted UF6 with the intent of using it, a changing political environment and changing agency mission are forcing DOE to rethink its management strategy.

Since storage began in the early 1950's, many of the cylinders now show evidence of external corrosion. Moreover, there have been eight breached cylinders, with associated releases of hydrogen fluoride (HF) into the environment. The states of Kentucky, and particularly Tennessee and Ohio, have been concerned whether the material is being managed correctly. Therefore, in 1994, DOE began reconsidering its management strategy. To support this activity, DOE has needed integrated planning, environmental, and engineering capabilities. EVS, with its experience in these areas, has helped DOE in many areas of its depleted UF6 management

program, including the PEIS, supporting technical analyses, developing and using decision-making tools, and public information and outreach efforts.

APPROACH EVS’s approach to this management problem focused on developing a “cradle-to-grave” (i.e., source to disposal, conversion, or use) strategy. Different types of activities and information had to be integrated to create a strategy DOE could implement. EVS was responsible for three primary areas: preparing the PEIS and supporting analyses; developing decision-making tools; and facilitating public information and outreach.

The PEIS is constructed from a set of activity modules that can be combined into an infinite variety of alternative management strategies. The modules are based on engineering analysis. Environmental impacts are assessed for each module as well as for collections of modules. This approach provides DOE with the necessary decision-making flexibility.

To conduct the technical analyses, EVS reviewed state-of-the-art models, data, and approaches used to evaluate the health, safety, and environmental impacts associated with uranium and component chemicals. When data and models were inadequate, EVS staff developed new approaches. For example, they designed a new computer model to evaluate depleted UF6 cylinder accidents involving fires, and they estimated how exposure to uranium compounds and chemicals used or manufactured during the processing of depleted UF6 affected human health.

One decision tool developed by EVS is a computer program to facilitate DOE cylinder management

(CMS, Cylinder Management System). Another is the Comment Response Management System (CRMS), a web-based tool that expedited DOE responses to government and public comments about the PEIS. The structure of the CRMS makes it applicable to all other projects requiring environmental impact statements.

RESULTS EVS has been a major participant in helping DOE rethink its depleted UF6 management strategy. The information in the PEIS directly influenced DOE’s initial decisions and will also affect subsequent strategy implementation. By participating in the program, EVS staff have developed expertise to contribute to future DOE material management activities. As the program moves into the implementation phase, EVS will continue its technical support to help DOE assess the environmental, health, and safety risks associated with its chosen depleted UF6 management strategy and communicate its findings to the public and regulators.

FUTURE EVS used web technology to disseminate public information and to facilitate public outreach. It developed the DUF6 web site to explain the program to the public and collect their comments. The use of this site increased the public’s ability to participate in the process and broadened the base of public interest in the program as a whole. In the implementation phase of the DUF6 Program, this site will be used to involve industry and regulators in program activities. (http://web.ead.anl.gov/uranium/)

Typical depleted UF6 storage cylinder (Cylinders are constructed of steel, with the majority of cylinders having a 14-ton capacity).

For more information, contact: J. Gasper • [email protected] • Environmental Science Division EVS2 Argonne National Laboratory, 9700 South Cass Avenue, Bldg. 900, Argonne, IL 60439 • 202-488-2420

JANUARY 11 2005 BECHTEL JACOBS COMPANY LLC New Remediation Contractors at Paducah and Portsmouth

The Department of Energy today named the new remediation contractors at Paducah and Portsmouth. A link to the DOE news releases is provided below.

North Wind Paducah Cleanup Company LLC has been named the Paducah remediation contractor. North Wind is a women-owned small business based in Idaho Falls. Additional information about North Wind, Inc., is available at http://www.nwindenv.com.

The Portsmouth remediation contractor is LATA-Parallax Portsmouth LLC. LATA-Parallax is owned by Los Alamos Technical Associates, Inc. http://www.lata.com/home.html, a New Mexico-based engineering, environmental and nuclear operations services company, and Parallax Inc., http://www.parallaxabq.com/, a Maryland-based engineering, environmental and nuclear operations services company. LATA is a service-disabled veteran owned small business and Parallax is a women-owned, minority owned small business.

DOE has not yet announced an award date for the infrastructure contracts.

We now enter a new phase of our work as we begin the transition that will lead to the turnover of all remediation responsibilities. Your efforts to prepare for this transition has put us in good stead for the weeks ahead. Our work is not finished, and we must maintain our professionalism and our commitment to safety as we assist the new team.

In the coming weeks, we will work closely together to lay the foundation for the workforce transition process. We expect to share additional information through e-mails and employee meetings in the very near future. This period of change is also a period of opportunity, and we intend to do everything we can to assist our employees during this transition. Please ensure that you await direction from our BJC Manager of Transition and the HR Department prior to initiating specific meetings on transition.

I know that you will respond to the challenge ahead with the determination and dedication you have shown since Bechtel Jacobs took on this work in April 1998.

Les Hurst Paducah and Portsmouth Transition

http://www.ohio.doe.gov/pppo_seb/remediation/index.html

HOME | Bechtel Jacobs Company LLC Subcontractor / Supplier Information Center Breaking News Security Statement / Privacy Policy Procurement Web

Bottled Water Pure Drink or Pure Hype?

http://www.nrdc.org/water/drinking/bw/bwinx.asp

1. Isn't bottled water safer than tap water? No, not necessarily. NRDC conducted a four-year rev iew of the bottled water industry and the safety standards that govern it, including a co mparison of national bottled water rules with national tap water rules, and independent test ing of over 1,000 bottles of water. Our conclusion is that there is no assurance that just because water comes out of a bottle it is any cleaner or safer than water from the tap. And i n fact, an estimated 25 percent or more of bottled water is really just tap water in a bottle -- sometimes further treated, sometimes not.

2. Is bottled water actually unsafe? Most bottled water appears to be safe. Of the bottl es we tested, the majority proved to be high quality and relatively free of contaminants. T he quality of some brands was spotty, however, and such products may pose a health risk, primarily for people with weakened immune systems (such as the frail elderly, some inf ants, transplant and cancer patients, or people with HIV/AIDS). About 22 percent of the bran ds we tested contained, in at least one sample, chemical contaminants at levels above stric t state health limits. If consumed over a long period of time, some of these contaminants c ould cause cancer or other health problems.

3. Could the plastic in water bottles pose a health risk? Recent research suggests that there could be cause for concern, and that the issue should be studied closely. Studies have shown that chemica ls called phthalates, which are known to disrupt testosterone and other hormones, can lea ch into bottled water over time. One study found that water that had been stored for 10 weeks in plastic and in glass bottles contained phthalates, suggesting that the chemicals could be coming from the plastic cap or liner. Although there are regulatory standards l imiting phthalates in tap water, there are no legal limits for phthalates in bottled water -- the bottled water industry waged a successful campaign opposing the FDA proposal to se t a legal limit for these chemicals.

4. How can I find out where my bottled water comes from? A few state bottled water programs (e.g., Massachus etts and New York) maintain lists of the sources of bottled water, but many do not. Try calling or writing the bottler to ask what the source is, or call the bottled water program in your state or the state in which the water was bottled to see if they have a record of the sou rce (your state's health or agriculture department is most likely to run the bottled water program). If you choose to buy bottled water and are concerned about its safety, buy brand s with a known protected source and ones that make readily available testing and treatm ent information that shows high water quality.

5. How can I determine if bottled water is really j ust tap water? Often it's not easy. First, carefully check the bot tle label and even the cap -- if it says "from a municipal source" or "from a community water syst em" this means it's derived from tap water. Again, you can call the bottler, or the bott led water program in your state or the state where it was packaged.

6. What actions can I take to improve bottled water safety? Write to your members of Congress, the FDA, and you r governor (see below for contact information) and urge them to adopt strict requirem ents for bottled water safety, labeling, and public disclosure. Specifically, point out to t hese officials that they should:

• set strict limits for contaminants of concern in b ottled water, including arsenic, heterotrophic-plate-count bacteria, E. coli and oth er parasites and pathogens, and synthetic organic chemicals such as "phthalates";

• apply the rules to all bottled water whether carbo nated or not and whether sold intrastate or interstate; and

• require bottlers to display information on their l abels about the levels of contaminants of concern found in the water, the wat er's exact source, how it's been treated, and whether it meets health criteria set by the Environmental Protection Agency and the Centers for Disease Contr ol for killing parasites like cryptosporidium.

Members of Congress and governors should also pass legislation providing the resources for the FDA and state regulators to actually enforc e the law.

To take further action, you can encourage your bott lers and the International Bottled Water Association (a trade organization that includes about 85 perce nt of water bottlers) to voluntarily make labeling disclosures such as those above.

Contact information:

FDA Andrew C. von Eschenbach, M.D. Commissioner, U.S. Food and Drug Administration 5600 Fishers Lane Rockville, MD 20857 Congress/State Legislators Go to our action center to find contact information for your members of Co ngress and state legislators.

7. How does drinking bottled water affect the envir onment? In 2006, the equivalent of 2 billion half-liter bot tles of water were shipped to U.S. ports, creating thousands of tons of global warming pollut ion and other air pollution. In New York City alone, the transportation of bottled wate r from western Europe released an estimated 3,800 tons of global warming pollution in to the atmosphere. In California, 18 million gallons of bottled water were shipped in fr om Fiji in 2006, producing about 2,500 tons of global warming pollution. And while the bottles come from far away, most of t hem end up close to home -- in a landfill. Most bottled water comes in recyclable PE T plastic bottles, but only about 13 percent of the bottles we use get recycled. In 2005 , 2 million tons of plastic water bottles ended up clogging landfills instead of getting recy cled.

8. If I drink tap water should I use a filter and w hat types of filters are most effective? The real long-term solution is to make tap water sa fe for everyone. However, if you know you have a tap water quality or taste problem, or w ant to take extra precautions, you should purchase filters certified by NSF International (800 NSF-MARK). These filters designate which contaminants they remove, and you c an look for one that removes any contaminants of special concern such as cryptospori dium. Such certification is not necessarily a safety guarantee, but it is better th an no certification at all. It is critically important that all filters be maintained and replac ed at least as often as recommended by the manufacturer, or they might make the problem wo rse. See our guide to water filters for more information.

9. How can I obtain test results on my tap water? Under new "right-to-know" provisions in the drinkin g water law, all tap water suppliers must provide annual water quality reports to their customers. To obtain a copy, call your water provider (the one that sends your water bills ).

You also can test your water yourself, though this can be expensive. There are state-certified drinking water laboratories in virtually every state that can test your water. Call your state drinking water program or the EPA Safe D rinking Water Hotline (800 426-4791) for a list of contacts. Standard consumer test pack ages are available through large commercial labs at a relatively reasonable price.

Summary Findings of NRDC's 1999 Bottled Water Repor t While bottled water marketing conveys images of pur ity, inadequate regulations offer no assurance. [En Español]

Sales of bottled water in this country have explode d in recent years, largely as a result of a public perception of purity driven by advertisement s and packaging labels featuring pristine glaciers and crystal-clear mountain spring s. But bottled water sold in the United States is not necessarily cleaner or safer than mos t tap water, according to a four-year scientific study recently made public by NRDC.

NRDC's study included testing of more than 1,000 bo ttles of 103 brands of bottled water. While most of the tested waters were found to be of high quality, some brands were contaminated: about one-third of the waters tested contained levels of contamination -- including synthetic organic chemicals, bacteria, an d arsenic -- in at least one sample that exceeded allowable limits under either state or bot tled water industry standards or guidelines.

A key NRDC finding is that bottled water regulation s are inadequate to assure consumers of either purity or safety, although both the feder al government and the states have bottled water safety programs. At the national level, the F ood and Drug Administration is responsible for bottled water safety, but the FDA's rules completely exempt waters that are packaged and sold within the same state, which acco unt for between 60 and 70 percent of all bottled water sold in the United States (roughl y one out of five states don't regulate these waters either). The FDA also exempts carbonat ed water and seltzer, and fewer than half of the states require carbonated waters to mee t their own bottled water standards.

Even when bottled waters are covered by the FDA's r ules, they are subject to less rigorous testing and purity standards than those which apply to city tap water (see chart below). For example, bottled water is required to be tested less frequently than city tap water for bacteria and chemical contaminants. In addition, bo ttled water rules allow for some contamination by E. coli or fecal coliform (which i ndicate possible contamination with fecal matter), contrary to tap water rules, which p rohibit any confirmed contamination with these bacteria. Similarly, there are no requirement s for bottled water to be disinfected or tested for parasites such as cryptosporidium or gia rdia, unlike the rules for big city tap water systems that use surface water sources. This leaves open the possibility that some bottled water may present a health threat to people with weakened immune systems, such as the frail elderly, some infants, transplant or c ancer patients, or people with HIV/AIDS.

Some Key Differences Between EPA Tap Water and FDA Bottled Water Rules

Water Type

Dis-infection Required?

Confirmed E. Coli & Fecal Coliform Banned?

Testing Frequency for Bacteria

Must Filter to Remove Pathogens, or Have Strictly Protected Source?

Must Test for Crypto-sporidium, Giardia, Viruses?

Testing Frequency for Most Synthetic Organic Chemicals

Bottled Water

No No 1/week No No 1/year

Carbonated or Seltzer Water

No No None No No None

Big City Tap Water (using surface water)

Yes Yes Hundreds/ month

Yes Yes 1/quarter (limited waivers available if clean source)

See Table 1 of NRDC's bottled water report for further comparisons and explanations.

Ironically, public concern about tap water quality is at least partly responsible for the growth in bottled water sales, which have tripled i n the past 10 years. This bonanza is also fueled by marketing designed to convince the public of bottled water's purity and safety, marketing so successful that people spend from 240 to over 10,000 times more per gallon for bottled water than they typically do for tap wa ter.

In fact, about one-fourth of bottled water is actua lly bottled tap water, according to government and industry estimates (some estimates g o as high as 40 percent). And FDA rules allow bottlers to call their product "spring water" even though it may be brought to the surface using a pumped well, and it may be trea ted with chemicals. But the actual source of water is not always made clear -- some bo ttled water marketing is misleading, implying the water comes from pristine sources when it does not. In 1995, the FDA issued labeling rules to prevent misleading claims, but wh ile the rules do prohibit some of the most deceptive labeling practices, they have not el iminated the problem.

Some examples of interesting labels NRDC observed i nclude:

"Spring Water" (with a picture of a lake surrounded by mountains on the label) -- Was actually from an industrial parking lot next to a h azardous waste site.

Alasika™ -- "Alaska Premium Glacier Drinking Water: Pure Glacier Water From the Last Unpolluted Frontier, Bacteria Free" -- Apparently came from a public water supply. This label has since been changed after FDA intervention .

Vals Water -- "Known to Generations in France for i ts Purity and Agreeable Contribution to Health . . . Reputed to Help Restore Energy, Vitali ty, and Combat Fatigue" -- The International Bottled Water Association voluntary c ode prohibits health claims, but some bottlers still make such claims.

NRDC makes the following recommendations for improv ing bottled water safety precautions:

• The FDA should set strict limits for contaminants of concern in bottled water. • The FDA's rules should apply to all bottled water distributed nationally or within a

state, carbonated or not, and bottled water standar ds must be made at least as strict as those applicable to city tap water suppli es.

• Water bottlers should be required to disclose wate r source, treatments and other key information as is now required of tap water sys tems.

• A penny-per-bottle fee should be initiated on bott led water to fund testing, regulatory programs, and enforcement at both state and national levels.

• State bottled water programs should be subject to federal review.

Ultimately, however, while Americans who choose to buy bottled water deserve the assurance that it is safe, the long-term solution t o our drinking water problems is to ensure that safe, clean, good-tasting drinking wate r comes from our taps . Those who are particularly concerned about the quality of their t ap water can take action by 1) calling their state drinking water program or the EPA Safe Drinking Water Hotline (800 426-4791) for a list of state certified labs; and 2) purchasi ng filters certified by NSF International (800 NSF-MARK) to remove the contaminants of special con cern to the consumer (NSF certification is not, however, a complete guarantee of safety).

Based on BOTTLED WATER : Pure Drink or Pure Hype? a March 1999 report by the Natural Resources Defen se Council (which includes a chart of our test results). See a lso the bottled water FAQ.

last revised 4.29.99

Appendix A

SUMMARY OF NRDC'S TEST RESULTS Bottled Water Contaminants Found

Brand(a)

Test #

Water Type

Purchase Location

Source of Water (if listed)

Contaminant & Level Found(b) Number of Bottles Tested

Lab Rep. #

Comments

HPC Bacteria(c) (Guidelines 500 cfu/ml; no enforceable standard) in cfu/ml

Arsenic(d) (CA Prop. 65 Level 5 ppb) in ppb

TTHMs(e) (CA & Industry bottled water standard 10 ppb) in ppb

Chloroform (CA Prop. 65 Level l0 ppb) in ppb

BDCM(f) (CA Prop. 65 Level 2.5 ppb) in ppb

DBCM (g) (CA Prop. 65 Level 3.5 ppb) in ppb

Phthalate (DEHP) (Tap water standard 6 ppb) no bottled water standard

Nitrate (Fed. & CA standard 10 ppm) in ppm

Other

365 1 Natural Spring Water (1.5 liters)

Berkeley, CA

Bottled in Austin, TX

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Results not received

10 (composited)

SA-711-1402

Albertson's A+

1 Natural Spring Water (1 liter)

San Diego/San Marcos, CA

Palomar Mtn. Spring

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

0.8 10 (composited)

SA-712-0390

Alhambra

1 Crystal Fresh Drinking Water (1 gal.)

San Francisco

McKesson Water Prod., Pasadena, CA

45 Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

0.1 Toluene detected at 12.5 ppb o-xylene at 2.7 ppb

3 (1 for each contaminant type)

EQI-1-27-29

Toluene and o-xylene are industrial chemicals found at levels below standards. Bottle claims "purified using. . .filtration, ozonation, reverse osmosis, and/or deionization."

Alhambra

2 Crystal Fresh Drinking Water (1

San Francisco


56 Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected


No toluene or xylene detected

10 (composited)

SA-711-1403

liter) Alhambra

1 Sport Top Crystal Fresh Drinking Water (16.9 fl. oz.)

San Francisco


Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

0.1 3 (1 for each contaminant type)

EQI-1 -33a-f

Alhambra*†

1 Mountain Spring Water, "prepared using filtration and ozone" (1 gal.)

San Francisco


>5700†

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Coliforms found at >200*


EQI-1-30-32

HPC bacteria in excess of guideline, and coliforms in excess of FDA standards.

Alhambra†

2 Mountain Spring Water (1 gallon)

San Francisco


1100† Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected


No coliforms detected

10 (composited)

SA-711-1404

HPC bacteria in excess of guideline.

Apollinaris*

1 Sparkling Mineral Water (1 liter)

Berkeley, CA

Bad Neuenahr-Ahrweiler, Germany

Not Detected

5.6* Not Detected

Not Detected

Not Detected

Not Detected

Not Detected


Fluoride found at 0.37 ppm, below std.

10 (composited)

SA-711-1405

Arsenic level exceeds CA Prop. 65 level.

Apollinaris*

2 Sparkling Mineral Water

No test 7.8* No test

No test

No test

No test

No test No test 10

(composited)

SA-806-2078


Aquafina

1 Purified Drinking Water -- "Purity Guaranteed" Non-Carbonated (1 liter)

Los Angeles

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected


EQI-1-LA6-LA8

Brand(a)

Test #

Water Type

Purchase Location



Lab Rep. #

Comments

HPC Bacteria(c) (Guidelines

Arsenic(d) (CA Prop.

TTHMs(e) (CA & Indus

Chloroform (CA Prop. 65

BDCM(f) (CA Prop. 65

DBCM (g) (CA Prop

Phthalate (DEHP) (Tap water standard 6 ppb) no

Nitrate (Fed. & CA

Other

500 cfu/ml; no enforceable standard) in cfu/ml

65 Level 5 ppb) in ppb

try bottled water standard 10 ppb) in ppb

Level l0 ppb) in ppb

Level 2.5 ppb) in ppb

. 65 Level 3.5 ppb) in ppb

bottled water standard

standard 10 ppm) in ppm

Aquafina

1 Purified Drinking Water -- "Purity Guaranteed" (1 liter)

Berkeley, CA

Laurel Bottling Co, Fresno, CA

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected


10 (composited)

SA-711-1406

Aquafina

1 Purified Drinking Water

Houston, TX

City of Houston Water Supply

Not Detected

Not Detected

4.1 3.5 0.6 Not Detected

5 ppb (just below 6 ppb tap water standard)

Not Detected

Di(2-ethylhexyl) adipate found at 0.9 ppb ( below standard of 400 ppb)

10 (composited)

298808-965 (944-949)

Pthalate (DEHP) is often present as a result of migration from the bottle to the water. The level detected is just below the EPA tap water standard for this chemical, though there is no bottled water standard (see text).

Aquafina


Houston, TX


Not Detected

No test

No test

No test

No test

No test

No test No test 10

bottles, individually

298-808-965 (934-943)

HPC bacteria test, none found in 10 bottles.

Arrowhead

1 Mountain Spring Water

San Francisco

Arrowhead MSW Co., L.A., CA

Not Detected

3.2 Not Detected

Not Detected

Not Detected

Not Detected

Not Detected


EQI-1-37a-f

Arrowhead

2 Mountain Spring Water (1.5 liter)

Berkeley, CA


5 Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected


10 (composited)

SA-711-1407

Arrowhead


Los Angeles

Not noted

Not Detected

Not Detected

4.3 1.9 1.6 0.8 Not Detected

1.0 10 (composited)

SA 712-0807

Arrowh 1 Sparkl San Arrowhe Not 3.1 Not Not Not Not Not 0.8 3 (1 EQI

ead ing Mountain Spring Water (1.5 liter)

Francisco

ad MSW Co., L.A., CA

Detected

Detected

Detected

Detected

Detected

Detected for each contaminant type)

-1-34-36

Arrowhead

2 Sparkling Mountain Spring Water (1.5 liter)

Berkeley, CA

Arrowhead MSW Co., L.A. , CA

Not Detected

Not Detected

1.1 1.1 Not Detected

Not Detected

Not Detected


10 (composited)

SA-711-1408

Beechnut

1 Water, Fluoride Added (1 gallon)

San Dimas, CA

Palomar Mountain, bottled by Famous Ramona, Ramona, CA

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Fluoride at 0.71 ppm

10 (composited)

SA-712-0392

Black Mountain†

1 Distilled Water (1 gallon)

Berkeley, CA

Black Mtn. Wtr.Co., San Carlos, CA


4 1.4 1.8 0.8 Not Detected


10 (composited)

SA-711-1409

Level of HPC bacteria exceeds guideline.

Brand(a)

Test #

Water Type

Purchase Location



Lab Rep. #

Comments









Other

Black Mountain

2 Distilled Water

Not Detected

No test

No test

No test

No test

No test

No test No test

No total coliforms

10 (tested individually)

SA 806-2079

No HPC bacteria detected.

Black Mountain†

1 Fluoridated Water (1 gallon)

Berkeley, CA




Not Detected


Fluoride found at 0.93 ppm* (exceeds standard in warm areas)

10 (composited)

SA-711-1410

Fluoride above standard of 0.8 ppm for added fluoride in areas with average high temp. of 79.3°F. HPC bacteria over

guideline level of 500 cfu/ml.

Black Mountain†

2 Fluoridated Water

18,000† (1bottle) 30 (1 bottle) Not Detected (8 bottles)

No test

No test

No test

No test

No test

No test No test

No total coliforms

10 (individually)

SA 806-2080

1 bottle of 10 contained HPC level well over guideline level.

Black Mountain

3 Fluoridated Water

No test No test

No test

No test

No test

No test

No test No test

Fluoride found at 1.3 ppm (exceeds standard in warm areas)

4 (composited)

901-079

Fluoride above standard of 0.8 ppm for added fluoride in warm weather areas (average high over 79°F).

Black Mountain

1 Purified Water (1 gallon)

Berkeley, CA


Not Detected

Not Detected


Not Detected


10 (composited)

SA-711-1411

Black Mountain*†

1 Spring Water (1 gallon)

San Francisco


>5,700†

3.6 Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

0.2 Total coliform count 27*; Toluene found at 8.9 ppb


EQI-1-19-20

Levels of HPC bacteria exceed guidelines. Coliforms exceed FDA standards. Toluene is a component of gasoline or industrial chemicals.

Black Mountain

2 Spring Water (5 gal.)

San Francisco


330 Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

No total coliforms or toluene detected

10 (composited)

SA-712-0846

Black Mountain


Berkeley, CA


80 Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected


10 (composited)

SA-711-1577

Calistoga


Berkeley, CA

Calistoga MW Co., Calistoga, CA

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

10 (composited)

SA-711-1578

Calistoga


San Francisco


Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected


EQI-1-1a-f

Brand(a)

Test #

Water Type

Purchase Location



Lab Rep. #

Comments









Other

Calistoga†

2 Mountain Spring Water (6 gal.)

Oakland, CA



Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

0.6 10 (composited)

SA-712-0847

HPC bacteria found at levels substantially exceeding guideline.

Calistoga

3 Mountain Spring Water (1 liter)

San Francisco


Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

0.5 10 (composited)

SA-711-1579

Calistoga


Not Detected to 1 cfu/ml

No test

No test

No test

No test

No test

No test No test

No total coliforms

10 (individually)

SA 806-2081

HPC bacteria within guidelines in all bottles tested.

Calistoga*

1 Sparkling Mineral Water, Original Napa Valley (1 liter)

San Francisco

Napa Valley

3 31.8* Not Detected

Not Detected

Not Detected

Not Detected

Not Detected


EQI-1-2-4

Arsenic level exceeds CA Prop. 65 limit.

Calistoga Sparkl

ing Mineral Water, Original Napa Valley

San Francisco

Napa Valley

No test Not Detected

No test

No test

No test

No test

No test No test 8

(composited)

SA-901-0797

Arsenic retest found none

Calistoga


San Francisco


Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

10 (composited)

SA-711-1580

Calistoga

2 Sparkling

No test Not Detec

No test

No test

No test

No test

No test No test 10

(compSA 806-

Mineral Water

ted osited) 2078

Canada Dry

1 Club Soda (1 liter)

Berkeley, CA

Cadbury Beverages Stamford, CT

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

0.6 10 (composited)

SA-711-1581

Canada Dry

1 Sparkling Water (1 liter)

San Francisco


1.0 Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Fluoride found at 0.13 ppm, well below std.

10 (composited)

SA-711-1582

Castle Rock

1 "Spring Water Bottled at the Source" (1 liter)

San Francisco

"The Cascade Mountains"

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected


EQI-1-16-18

Brand(a)

Test #

Water Type

Purchase Location



Lab Rep. #

Comments









Other

Cobb Mountain

1 Natural Spring Water (1.5 liter)

Berkeley, CA

Cobb Mtn. Spring Water Co., Cobb, CA

Not Detected

Not Detected

1.2 Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Bromoform (a trihalomethane) found at 1.2 ppb, below standard

10 (composited)

SA-711-1583

Crystal Geyser*

1 Alpine Spring Water (16.9 oz.)

San Francisco

CG Roxane source, Eastern Sierra, bottled at Olancha, CA

460 17.8* click for update

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected 3 (1

for each contaminant type)

EQI-1-26a-f


Crystal Geyser*

2 Alpine Spring Water (1 liter)

San Francisco

CG Roxane source, Eastern Sierra, Olancha, CA

Not Detected

11* click for update

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Fluoride found at 0.82 ppm

10 (composited)

SA-711-1585

Arsenic level exceeds CA Prop. 65 limit; fluoride level is

below standard of 1.4 ppm in warm areas (if natural) but above the warm area standard of 0.80 ppm if added.

Crystal Geyser*

3 Alpine Spring Water

No test 12* click for update

No test

No test

No test

No test

No test No test 10

(composited)

SA 806-2078

Arsenic exceeds Prop. 65 limit and WHO/EU standard.

Crystal Geyser*

1 Napa Valley Sparkling Mineral Water Bottled at the Source (12 fl. oz.)

San Francisco

Napa Valley


Not Detected

Not Detected

Not Detected

Not Detected

Not Detected


EQI-1-25a-f

Arsenic exceeds Prop. 65 limit.

Crystal Geyser

2 Napa Valley Sparkling Mineral Water


No test

No test

No test

No test

No test No test 10

(composited)

SA 806-2078

No arsenic detected.

Crystal Geyser*


No test 14 ppb click for update

No test

No test

No test

No test

No test No test

No test 10 (composited)

SA-901-0798

Arsenic exceeds CA Prop. 65 limit and WHO/EU standard.

Crystal Geyser


Berkeley, CA

Crystal Geyser Water Company, Calistoga, CA

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

10 (composited)

SA-711-1584

Crystal Geyser

1 (1 liter)

Chicago, IL Not

Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

10 (composited)

297719-48 (43-48)

Crystal Geyser

1 (1 liter)

Chicago, IL Not

Detected

No test

No test

No test

No test

No test

No test No test 9

(individually)

297790-836 (810-818)

Brand(a)

Test #

Water Type

Purchase Location



Lab Rep. #

Comments









Other

Dannon 1 Natural Spring Water (1.05 pint )

San Francisco

Piedmont, Quebec, Canada

6 Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected


EQI-1-24a-f

Dannon 2 Natural Spring Water (1 liter)

San Francisco


330 Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

0.8 10 (composited)

SA-711-1696

Dannon 3 Natural Spring Water

New York City


Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

1.2 Di-n-butyl-pthalate at 7.5 ppb; Methylene chloride at 1.5 ppb (below 5ppb statandard)

10 (composited)

299863-942 (911-916)

Pthalate may be from leaching from bottle top or other packaging materials; methylene chloride of unknown origin, and at 30% of FDA standard.

Dannon†

4 Natural Spring Water

New York City


2 of 10 bottles tested contained HPC bacterial overgrowth†

No test

No test

No test

No test

No test

No test No test 10

(individually)

299 863-942 (917-926)

Bacterial overgrowth was observed in 2 of the 10 bottles tested. The presence of a large number of noncoliform HPC bacteria may be inhibiting the detection of coliform bacteria during the testing. See text for discussion of HPC bacteria.

Deer Park

1 Spring Water (1 liter)

New York City

Valley View Spring, Hegins Twp., PA

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

10 (composited)

299 863-942 (879-884)

Deer Park


New York City


Not Detected

No test

No test

No test

No test

No test

No test No test 10

(individually)

299 863-942 (885-894)

Deer Park

3 Spring Water (1.5 liter)

Washington DC

Hegin Township, PA

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

10 (composited)

298 808-965 (879-884)

Deer Park


Washington DC

Hegin Township, PA

Not Detected

No test

No test

No test

No test

No test

No test No test 10

(individually)

298 808-965 (869-878)

Dominick's


Chicago, IL Not

Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

0.6 10 (composited)

297719-48 (31-36)

Dominick's


Chicago, IL Not

Detected

No test

No test

No test

No test

No test

No test No test 9

(individually)

297 790-836 (828-836)

Brand(a)

Test #

Water Type

Purchase Location



Lab Rep. #

Comments









Other

Evian 1 Natural Spring Water (1 liter)

San Francisco, CA

Cachat Springs, Evian, France

21 2.0 Not Detected

Not Detected

Not Detected

Not Detected

Not Detected


EQI-1-21-23


San Francisco, CA


63 Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

0.8 10 (composited)

SA-711-1697

Fiuggi 1 Natural Mineral Water

Berkeley, CA

A.S.T.I.F., Fiuggi, Italy

7 Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

2.5 10 (composited)

SA-711-1698

(1 liter)

Gerber 1 Baby Water with Fluoride (1.5 liter)

Berkeley, CA

AquaPenn Springs, Graysville, PA

2 Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

0.6 Fluoride found at 0.46 ppm, below standard

10 (composited)

SA-711-1699

Gerolsteiner

1 Sprudel Sparkling Mineral Water (1 liter)

Berkeley, CA

Gerolstein, Germany

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

1.0 10 (composited)

SA-711-1700

Glacier Springs


Miami, FL Not

Detected

Not Detected


Not Detected

Not Detected

Not Detected

Aluminum found at 180 ppb (std. is 200 ppb)

10 (composited)

304085-165 (150-155)

Aluminum found at 180 ppb, just below the 200 ppb FDA bottled water standard, set based on taste, odor, and aesthetic concerns. FDA's standard for aluminum is not applicable to mineral water, but is applicable to purified water.

Glacier Springs†

2 Purified Water

Miami, FL HPC

bacterial overgrowth detected in 1 of 10 bottles tested†

No test

No test

No test

No test

No test

No test No test 10

(individually)

304085-165 (304156-304165)


Hawaii 1 Purified Drinking Water (1.5 liters)

Berkeley, CA

MenehuneWater Co, Aiea, HI

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

10 (composited)

SA-711-1701

Hildon 1 Mineral Water-Carbonated (750 ml)

Berkeley, CA

Broughton, Hampshire, England

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

5.6 10 (composited)

SA-711-1702

Elevated nitrate level, though below FDA standard, of potential concern--see text.


Berkeley, CA


No test No test

No test

No test

No test

No test

No test 5.4 10 (composited)

SA 808-1663

Retest of elevated nitrate level; below FDA standard, of potential concern--see text.

Brand(a)

Test #

Water Type

Purchase Location



Lab Rep. #

Comments









Other

Hildon 1 Mineral Water-Still (750 ml)

Berkeley, CA


200 Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

5.6 10 (composited)

SA-711-1703


Hinckley Schmidt

1 (1 gallon)

Chicago, IL Not

Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

1.9 10 (composited)

297719-48 (25-30)

Hinckley Schmidt

2 (1 gallon)

Chicago, IL Not

Detected

No test

No test

No test

No test

No test

No test No test 10

(individually)

297 790-836 (790-799)

Hyde Park†


Miami, FL >5700

† Not Detected


Not Detected

Not Detected

10 (composited)

304085-165 (101-106)

Level of HPC bacteria substantially exceeded guideline.

Hyde Park

2 Purified Water

Miami, FL Not

Detected

No test

No test

No test

No test

No test

No test No test 10

(individually)

304085-165 (304107-304116)

Retest for HPC bacteria in 10 bottles found none

Ice Age 1 "Glacial Water" (1 liter)

Berkeley, CA

Alpine Creek, Manitoba Inlet, Canada

67 Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

10 (composited)

SA-711-1704

Janet Lee

1 Drinking Water (1 gallon)


Albertsons, Boise, ID, distrib.

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

0.7 10 (composited)

SA-712-0393

Janet Lee



Albertsons, Boise ID, distrib.

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

10 (composited)

SA-712-0394

Janet Lee




41 Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

10 (composited)

SA-712-0395

Jewel 1 Artesian Water (1 gallon)

Chicago, IL Not

Detected

1.1 Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

10 (composited)

297719-48 (19-24)

Brand(a)

Test #

Water Type

Purchase Location



Lab Rep. #

Comments









Other


Chicago, IL Not

Detected

No test

No test

No test

No test

No test

No test No test 10

(individually)

298 808-965 (800-809)

Kroger 1 Utopia Spring Water (1 liter)

Houston, TX

Indian Springs, Franklin County, TX

1 Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

0.9 10 (composited)

298 808-965 (928-933)


Houston, TX


Not Detected

No test

No test

No test

No test

No test

No test No test 10

(individually)

298 808-965 (918-927)

Lady Lee

1 Natural Spring Water (1 gallon)

San Francisco

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Toluene at 13.9 ppb; o-xylene at 3.0 ppb


EQI-1-53-55

Toluene and xylene are constituents of gasoline and also used in some industrial chemicals.

Lucky (aka Lady Lee)


San Francisco

Plant #06-21

20 Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected


10 (composited)

SA-712-0025

Lady Lee


No test No test

Not Detected

Not Detected

Not Detected

Not Detected

No test No test

Toluene at 0.55 ppb, no xylene detected

10 (composited)

SA-806-2086

Lady Lee*

1 Purified Water purified by deionization (1 gallon)

San Francisco

Not Detected

6.5* 54.8* 54.8* Not Detected

Not Detected

Not Detected

0.1 Toluene at 9.5 ppb; ethyl-benzene at 2.0 ppb; m/p-xylene at 3.1 ppb; o-xylene at 6.3 ppb


EQI-1-50-52

Arsenic and chloroform at levels above CA Prop. 65 levels. TTHMs above CA and industry standard of 10 ppb. Toluene and xylene are gasoline constituents and also used in some industrial chemicals.



San Francisco

Plant #06-21

1 Not Detected


Not Detected

Not Detected

Not Detected

10 (composited)

SA-712-0026

Lady Lee

3 Purified Water purified by deionization (1 gal.)

San Francisco

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

No test No test

Methylene chloride at 4.1 ppb (std. is 5 ppb)


SA-808-1666

Methylene chloride at level just below federal standard.

Lady Lee*


San Francisco

Not Detected

3.2 91.6* 88.9* 2.7* Not Detected

Not Detected

0.1 Toluene at 11.0 ppb; o-xylene at 2.9 ppb


EQI-1-56-58

THM levels in excess of CA & industry standards; chloroform and bromodichloromethane in excess of CA Prop. 65 level. Toluene and xylene are gasoline

constituents and also used in industrial chemicals.

Brand(a)

Test #

Water Type

Purchase Location



Lab Rep. #

Comments









Other

Lady Lee*

2 Drinking Water

No test No test

29* 29* Not Detected

Not Detected

No test No test

Toluene at 0.5 ppb; no xylene found

10 (composited)

SA-806-2085

THM levels in excess of CA & industry standards; chloroform in excess of CA Prop. 65 level. Toluene is a gasoline constituent and used in industrial chemicals.



San Francisco

Plant #06-21

8 Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected


10 (composited)

SA-711-1705

Lucky* 1 Seltzer Water (2 liters)

San Francisco

Salt Lake City, UT, distrib., Am Procurement & Logistics

Not Detected

Not Detected

30.7* 29* 1.7 Not Detected

Not Detected

Not Detected

Fluoride found at 0.84 ppm*

10 (composited)

SA-712-0027

THM level exceeds CA & industry standards, and chloroform level exceeds CA Prop. 65 level. Fluoride level slightly over CA warm weather area standard of 0.8 ppm if fluoride added (if fluoride is natural, warm weather area

standard is 1.4 ppm); identical FDA standard does not apply to seltzer (not defined as "bottled water").

Lucky* 2 Seltzer Water

No test No test


Not Detected

No test No test

n-isopropyl-toluene at 230 ppb; n-butyl-benzene at 21 ppb; Toluene at 1.8 ppb;

SA-806-2087

Chloroform level CA Prop. 65 warning level; THM level exceeds CA & industry standards. High level of n-isopropyl toluene and elevated level of n-butyl-benzene of unknown origin; CA law generally prohibits levels over 1 ppb of these VOCs in source water, but may have been added in processing.

Lucky 1 Sparkling Water, Sugar Free Rasberry Bev. (1 liter)

San Francisco

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

0.2 p-isopropyl-toluene found at 5.4 ppb


EQI-1-41-43

Master Choice†

1 Spring Water (1.5 liters)

New York City

Stockbridge, VT

>5700†

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

1.7 10 (composited)

299863-942 (863-868)


Master Choice†


New York City

1 of 10 bottles had HPC bacterial overgrowth†

No test

No test

No test

No test

No test

No test No test 10

(individually)

299869-878

Bacterial overgrowth was observed in 1 of the 10 bottles tested. The presence of a large number of noncoliform HPC bacteria may be inhibiting

the detection of coliform bacteria during the testing. See text for discussion of HPC bacteria.

Mendocino


Berkeley, CA

Mendocino Bev., Comptche, CA

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

10 (composited)

SA-712-0028

Natural Value†


Berkeley, CA

Nat. Value, Sacramento, CA, distrib.

7,300† Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

10 (composited)

SA-712-0029

Level of HPC bacteria substantially exceeded guideline applied to bottled water by some states.

Naya 1 Canadian Natural Spring Water (1 liter)

Los Angeles

Revelstroke, BC, Canada

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected


EQI-1-LA 15-LA 17

Brand(a)

Test #

Water Type

Purchase Location



Lab Rep. #

Comments









Other

Naya 2 Canadian Spring Water (1 liter)

San Diego, CA


Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

10 (composited)

SA-712-0396

Naya 3 Canadian Spring Water (1.5 liter)

New York City

Revelstroke, B.C., Canada

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

10 (composited)

299863-942 (927-932)

Naya 4 Canadian

New York

Canada Not Detect

No test

No test

No test

No test

No test

No test No test 10

(indivi299 863-

Spring Water (1.5 liters)

City ed dually) 942 (933-942)

Niagara*


San Diego, CA

Irvine, CA

35 Not Detected

8.5 3.7 3.1* 1.7 Not Detected

Not Detected

10 (composited)

SA-712-0397

Bromodichlormethane found above CA Prop. 65 level.

Niagara 2 Drinking Water

No test No test

3.1 1.5 1.1 0.5 No test No test 1

(individual)

SA-901-0800


No test No test


No test No test 8

(composited)

SA-901-0800

Nursery 1 Drinking Water, sodium free fluoride added, not sterile, use as directed by physician or by labeling directions for use in infant formula (1 gallon)

San Francisco

Not Detected

4.5 ppb

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Toluene found at 12.4 ppb, o-xylene at 3.2 ppb, styrene at 3.0 ppb


EQI-1-47-49


Nursery 2 Drinking Water

No test No test

Not Detected

Not Detected

Not Detected

Not Detected

No test No test

Toluene at 0.57 ppb

10 (composited)

SA-807-0079

Odwalla*

1 Geothermal Natural Spring Water (1 liter)

Berkeley, CA

Trinity Springs, Davenport, CA

1 3.8 Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected


10 (composited)

SA-712-0030

FDA and California bottled water regulations impose a maximum of 1.4 ppm fluoride in areas with annual average high temperatures of >79.3 °F.

Odwalla*

2 No test 3.9 No test

No test

No test

No test

No test No test

Fluoride at 1.6 ppm*

10 (composited)

SA-807-0080

FDA and California bottled water regulations

impose a maximum of 1.4 ppm fluoride in areas with annual average high temperatures of >79.3 °F.

Brand(a)

Test #

Water Type

Purchase Location



Lab Rep. #

Comments









Other

Opal† 1 Spring Water (1.5 liter)

Berkeley, CA

Culver, OR

510† 2.4 Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected


10 (composited)

SA-712-0031

Level of HPC bacteria exceeded guideline applied to bottled water by some states.

Ozarka 1 Drinking Water

Houston, TX

Houston Municipal Water Supply

1 Not Detected


Not Detected

Not Detected

10 (composited)

29808-965 (960-965)


Houston, TX


Not Detected

No test

No test

No test

No test

No test

No test No test 10

(individually)

298950-959

Palomar*


Los Angeles

Palomar Mountain, Escondido, CA

2 5.8 ppb

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected


EQI-1-LA3-5

Arsenic level exceeds CA Prop. 65 warning level.

Palomar 2 Mountain Spring Water (1.5 liters)

Venice, CA


Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

0.6 10 (composited)

SA-712-0398


Los Angeles



No test

No test

No test

No test

No test No test 10

(composited)

SA-808-1664

Pathmark


New York City

Guelph, Canada

1 Not Detected

2.4 Not Detected

Not Detected

0.1 Not Detected

Not Detected

Bromoform (a trihalomethane) was found at 2.2 ppb

10 (composited)

299863-942 (895-900)

Pathmark†


New York City

Guelph, Canada


No test

No test

No test

No test

No test

No test No test 10

(individually)

299 863-942 (901-910)


Pathmark


New York City

Guelph, Canada

Not Detected

No test

No test

No test

No test

No test

No test No test 10

(individually)

299 863-942 (879 & 885-893)

Perrier 1 Sparkling Mineral Water (25 fl oz.)

San Francisco

Vergeze, France

19 Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

2.8 2-Chlorotoluene found at 4.6 ppb


EQI-1-44-46

Chlorotoluene of unknown origin

Brand(a)

Test #

Water Type

Purchase Location



Lab Rep. #

Comments









Other

Perrier 2 Sparkling Mineral Water

Los Angeles

Vergeze, France

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected


3 (1 for each contaminant

EQI-1-LA 36- LA

Chlorotoluene of unknown origin.

(25 fl oz.)

type) 38

Perrier*


San Francisco

Vergeze, France

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Di(2-ethylhexyl)Phthalate detected at 12 ppb*

4.3 No detection of 2-Chlorotoluene

10 (composited)

SA-712-0032

Exceeds 6 ppb tap water standard for Di(2-ethylhexyl) phthalate (DEHP), but there is no standard for bottled water for this chemical. California does not allow this DEHP level in the source water for bottled water, but sets no DEHP standard for finished bottled water.


San Francisco

Vergeze, France

No test No test

No test

No test

No test

No test

No test 4.1 No test 10 (composited)

SA-808-1662

Nitrate retest.

Poland Spring†


Washington, DC

750† Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

10 (composited)

298808-965 (819-824)

HPC bacteria found at levels exceeding guideline applied by some states to bottled water.

Poland Spring†


Washington, DC

5 of 10 bottles tested had HPC bacterial overgrowth†

No test

No test

No test

No test

No test

No test No test 10

(individually)

298 808-965 (809-818)

Bacterial overgrowth was observed in 5 of the 10 bottles tested. The presence of a large number of non-coliform HPC bacteria may be inhibiting the detection of coliform bacteria during the testing. See text for discussion of HPC bacteria.

Polar 1 Spring Water

Washington,

Crystal Springs,

Not Detect

Not Detec

0.1 0.1 Not Dete

Not Dete

Not Detected

0.8 Toluene detected

10 (comp

298 808-

Toluene is often an

(1 gallon)

DC Spring Grove, VT

ed ted cted cted at 2.5 ppb, (well below the standard of 1000 ppb)

osited) 965 (851-856)

indicator of the presence of gasoline or industrial chemicals, here of unknown origin.

Polar 2 Spring Water (1 gallon)

Washington, DC

Crystal Springs, Spring Grove, VT

Not Detected

No test

No test

No test

No test

No test

No test No test 10

(individually)

298 808-965 (841-850)

Private Selection* (Ralph's)


Los Angeles

Not Detected

Not Detected

47.1* 16.7* 20.1*

10.3*

Not Detected


EQI-1-LA 26- LA 27

THM levels violated CA & industry standards for bottled water, and chloroform, bromodichloromethane, and dibromochloromethane exceeded CA Prop. 65 levels.



Venice, CA

Ralph's LA, distrib., plant 06-178

66 Not Detected

22.3* 6.6 8.9* 6.8* Not Detected

Not Detected

10 (composited)

SA-712-0399

THM levels violated CA & industry standards for bottled water, and bromodichloromethane, and dibromochloromethane exceeded CA Prop. 65 levels.

Private Selection (Ralph's)


Los Angeles

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected


EQI-1-LA 34-LA 35

Brand(a)

Test #

Water Type

Purchase Location



Lab Rep. #

Comments



TTHMs(e) (CA & Industry bottled water standard 10 ppb) in






Other

ppb Private Selection* (Ralph's)


San Diego, CA


Not Detected

Not Detected

20.1* 8.4 7.4* 4.3* Not Detected

Not Detected

10 (composited)

SA-712-0582




Los Angeles


No test No test

10.4* 9.1 1.3 Not Detected

Not Detected

Not Detected

10 (composited)

SA-808-1665

THM levels violate CA & industry/IBWA standard for bottled water.

Publix† 1 Drinking Water (1 gallon)

Miami, FL Not

Detected

1.3 45† 41 3.2 0.2 Not Detected

0.8 Acetone found at 11 ppb (no std.); styrene found at 0.6 ppb (below std. of 100 ppb)

10 (composited)

304085-165 (085-090)

THM levels violate industry/IBWA standard of 10 ppb (no longer enforceable in FL)


Lakeland, FL No test No

test 53† 47 5.3 0.4 No test No

test Acetone found at 14 ppb (no standard)

8 (composite sample)

361 436-37 (36)

THM levels violate industry/IBWA standard of 10 ppb (no longer enforceable in FL).





1 bottle

361 436-37 (37)


Publix 4 Drinking Water (1 gallon)

Miami, Fl Not

Detected

No test

No test

No test

No test

No test

No test No test

No test 10 (individually)

304085-165 (304091-304100)

Publix† 1 Purified Water (1 gallon)

Miami, FL 1 Not

Detected

15† 14† 0.9 Not Detected

Not Detected

Not Detected

Styrene found at 0.2 ppb (below std. of 100 ppb)

10 (composited)

304085 (117-122)

THM found at level exceeding 10 ppb industry/IBWA standard (no longer enforceable in FL).

Styrene from unknown source.


Miami, FL 5 of 10

bottles tested contained HPC "bacterial overgrowth"†

No test

No test

No test

No test

No test

No test No test

No test 10 bottles (individualy)

304085-165 (304123-304132)


Puritas 1 Drinking Water (1 gal.)

Los Angeles

Grt. Sprg. Waters of America, Milpitas, CA

Not Detected

3.2 Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected


EQI-1-LA1-LA2

Puritas†


Berkeley, CA


990† Not Detected

Not Detected

Not Detected

Not Detected

Not Detected


Not Detected

10 (composited)

SA-712-0033


Brand(a)

Test #

Water Type

Purchase Location



Lab Rep. #

Comments









Other

Ralph's 1 Mountain Spring Water (1.5

Los Angeles

"California Mountains," L.A.,

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

0.8 3 (1 for each contaminant

EQI-1-LA 28- LA

liter) CA, distrib.

type) 30

Ralph's 2 Mountain Spring Water (1.5 liters)

San Diego

"California Mountains"

270 Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

0.6 10 (composited)

SA-712-0583

Randalls 1 Remarkable Drinking Water (1 gallon)

Houston, TX

Buck Springs, Jasper, TX

Not Detected

Not Detected

0.4 Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Bromoform (a trihalomethane) found at 0.4 ppb

10 (composited)

298 808-965 (895-900)


Houston, TX


Not Detected

No test

No test

No test

No test

No test

No test No test 10

bottles (individually)

298 808-965 (885-894)

HPC retest found none.

Randalls†

1 Deja Blue Drinking Water (1 liter)

Houston, TX

City of Irving Water Supply

>5700†

Not Detected

29.6† 14 12 3.6 Not Detected

Not Detected

10 (composited)

298 808-965 (911-916)

Levels of TTHM exceed IBWA/industry standards (not enforceable in TX).

Randalls 2 Deja Blue Drinking Water (1 liter)

Houston, TX


Not Detected

No test

No test

No test

No test

No test

No test No test 10


298 808-965 (901-910)

Rocky Mountain

1 Drinking Water, non-carbonated (1.5 liter)

Los Angeles

"Deep Well Water"

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected


EQI-1-LA 31- LA 33

Rocky Mountain

2 Drinking Water, non-carbonated (1.5 liters)

San Dimas, CA

Santa Fe Springs, CA

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

10 (composited)

SA-712-0584

S. Pellegrino

1 Sparkling Natural Mineral Water, bottled at the source (25.3 oz.)

San Francisco

San Pellegrino, Italy

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected


EQI-1-38-40

S. 2 Sparkl San San Not Not Not Not Not Not Not Not Fluoride 10 SA-

Pellegrino

ing Natural Mineral Water (1 liter)

Francisco

Pellegrino, Italy

Detected

Detected

Detected

Detected

Detected

Detected

Detected Detected

found at 0.37 ppm (below standard)

(composited)

712-0034

Brand(a)

Test #

Water Type

Purchase Location



Lab Rep. #

Comments









Other

Safeway*† (CA)


Berkeley, CA

Municipal Source, Safeway Inc., Oakland, CA, distrib.


35.1* 31* 4.1* Not Detected

Not Detected

Not Detected

Fluoride found at 0.81 ppm (above standard in warm weather areas)

10 (composited)

SA-712-0214

THM found at level above CA & industry bottled water standards; chloroform and bromodichloromethane (BDCM) found at levels above CA Prop. 65 limits. Fluoride at level above FDA & state limit for areas with av. high temp. >79.3°F. HPC bacteria above guideline adopted by some states for bottled water.

Safeway* (CA)

2 Drinking Water

51,000† (1 bottle) 12,000†(1 bottle) 2-21 (4 bottles) Not

No test

37* 35* 2.3 Not Detected

No test No test 10

(composited for chemical analysis) 10 (indivi

SA 807-0081

THM found at level above CA & industry bottled water standards, and chloroform found at a

Detected in 4 bottles (see notes)

dually for bacteria analysis)

level above CA Prop. 65 limit. Retests of individual bottles that were initially found to contain 51,000 cfl/mu and 12,000 cfl/mu found no HPC and 6,000 cfu/ml, respectively, though these results are unreliable since they were retested beyond EPA-mandated "hold time" after opening.

Safeway (CA)

1 Key Lime Sparkling Water (1 quart)

San Francisco

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected


EQI-1-13-15

Safeway*† (CA)


San Francisco

>5,700†

Not Detected

26.4* 26.4* Not Detected

Not Detected

Not Detected

0.1 Total coliforms count 5*; Toluene found at 8.4 ppb


EQI-1-7-9

Coliforms, HPC bacteria, trihalomethanes, and chloroform exceed guidelines/standards. Toluene is a constituent of gasoline and industrial chemicals that should be removed if treated with reverse osmosis. Label claims "prepared by deionization and/or reverse osmosis." Could have been added during processing.

Safeway* (CA)

2 Purified Water

San Francisco/

Municipal Source,

4 Not Detected


Not Detected

Not Detected

Toluene not detected

10 (composited)

SA-712-058

THM levels violate CA & industry

(1 gallon)

Berkeley, CA

Safeway, Oakland, CA, distrib.

, coliforms not detected

5 standards for bottled water., chloroform and bromodichloromethane exceeded CA Prop. 65 levels.

Safeway* (CA)

1 Select Club Soda (2 liter)

Berkeley, CA


Not Detected

Not Detected


Not Detected

Not Detected


10 (composited)

SA-712-0215

THM levels violate CA & industry standards for bottled water. Chloroform and bromodichloromethane exceeded CA Prop. 65 levels.

Safeway* (CA)

2 Select Club Soda

No test No test


No test No test 10

(composited)

SA-807-0082

Chloroform level exceeds CA Prop. 65 level; Trihalomethane levels over CA & industry standards.

Safeway*† (CA)

1 Select Seltzer Water (2 liter)

Berkeley, CA


Not Detected

Not Detected


Not Detected

Not Detected

Fluoride found at 0.83 ppm* above warm weather std. for added fluoride

10 (composited)

SA-712-0216

THM levels violate CA & industry standards. Chloroform level exceeds CA Prop. 65 level. Fluoride above 0.80 CA std. for areas with av. high >79.3°F (if fluoride added; if natural, warm weather area standard is 1.4 ppm); identical FDA standard does not apply to seltzer (not defined as "bottled water").

Safeway* (CA)

2 Select Seltzer Water

No test No test


Not Detected

No test No test 10

(composited)

SA-807-0083

THM levels violate CA & industry standards, chloroform level exceeds CA Prop. 65

level. Safeway*† (CA)

1 Spring Water "Especially selected for its Natural Purity" (1 gallon)

San Francisco

>5700†

Not Detected

56.8* 53.3* 3.5* Not Detected

Not Detected

Not Detected

Toluene found at 14.2 ppb; o-xylene at 3.1 ppb, both below standards


EQI-1-10-12

Toluene and o-xylene are constituents of gasoline and industrial chemicals. This water apparently was chlorinated, suggesting that it could be tap water or if it is spring water, it was subjected to chlorination. Levels of TTHMs exceeded CA & industry standard; level of chloroform exceeds CA Prop. 65 level; HPC exceeded guidelines.

Brand(a)

Test #

Water Type

Purchase Location



Lab Rep. #

Comments









Other

Safeway* (CA)


Berkeley, CA


15 Not Detected


Invalid Not Detected

Fluoride found at 0.28 ppm, below std.; no toluene or xylene found

10 (composited)

SA-712-0217

THM levels violate CA & industry standards. Chloroform level exceeds CA Prop. 65 level.

Safeway (CA)


Berkeley, CA


No test No test

No test

No test

No test

No test

Not Detected

No test


SA 801-0364

Retest for phthalate and semivolatile organics, not

detected. Safeway (DC)

1 Refreshe Natural Spring Water (16.9 oz.)

Washington, DC

Safeway Spring, NY

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

0.7 10 (composited)

298808-965 (835-840)

Safeway (DC)


Washington, DC

Safeway Spring, NY

1 of 10 bottles tested had overgrowth of HPC bacteria

No test

No test

No test

No test

No test

No test No test 10


298 808 965 (825-834)


Safeway (DC)

1 Safeway Spring Water (1 gallon)

Washington, DC

Tower City, PA

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Toluene found at 4.7 ppb ( below the standard of 1000 ppb)

10 (composited)

298808-965 (863-868)

Toluene is a constituent of gasoline and industrial chemicals, although its source here is unknown.

Safeway (DC)


Washington, DC

Tower City, PA

Not Detected

No test

No test

No test

No test

No test

No test No test 10

(composited)

298 808 965 (857-862, 917)

Sahara*

1 Drinking Water, "Premium" (50.7 oz.)

Los Angeles

1 Not Detected

37.9* 14.7* 14.9 8.3* Not Detected


EQI-1-LA9-11


Sahara*



Bear Spec. & Mktg., San Bernadino, CA, distrib.

Not Detected

Not Detected

15.9* 6.5* 6.6* 2.8 Not Detected

2.5 Fluoride at 0.54 ppm

10 (composited)

SA-712-0586

THM levels violated CA & industry standards for bottled water, and chloroform

and bromodichloromethane exceeded CA Prop. 65 levels.

Save the Earth


Berkeley, CA

Baxter Springs, CA

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

10 (composited)

SA-712-0218

Schweppes


San Francisco, CA

Cadbury Bev., Stamford, CT

Not Detected

Not Detected


Not Detected

Invalid test

Not Detected

Fluoride found at 0.13 ppm, well below standard

10 (composited)

SA-712-0219

Brand(a)

Test #

Water Type

Purchase Location



Lab Rep. #

Comments









Other

Schweppes


San Francisco

Dr. Pepper/Seven Up, Inc., Dallas, TX

No test No test

No test

No test

No test

No test

Not Detected

No test 10

(composited)

SA 801-0360

Retest of semivolatile organics, including phthalate, found none.

Schweppes

1 Seltzer Water (1 liter)

Berkeley, CA


Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Invalid test

Not Detected


10 (composited)

SA-712-0220

Schweppes


San Francisco


No test No test

No test

No test

No test

No test

Not Detected

No test 10

(composited)

SA 801-0361


Shasta 1 Sparkling Club Soda (2 liters)

Berkeley, CA

Shasta Bev., Hayward, CA, distrib.

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected


Not Detected


10 (composited)

SA-712-0221

Shasta 2 Sparkling

Berkeley,

Shasta Bev.,

No test No test

No test

No test

No test

No test

Not Detected

No test 10

(compSA 801-

Retest of semivolatile

Club Soda (2 liters)

CA Hayward, CA, distrib.

osited) 0365

organics, including phthalate, found none.

Sparkletts†

1 Crystal Fresh Drinking Water -- "Meet or Exceed all State and Federal Water Quality Standards" (1 liter)

Los Angeles

McKesson Water Prods., Pasadena, CA


Not Detected

Not Detected

Not Detected

Not Detected

Not Detected


EQI-1-LA 12-LA 14

Heterotrophic Plate Count Bacteri (HPC) exceeded guideline.

Sparkletts


Venice, CA


140 Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

10 (composited)

SA-712-0587

HPC level below guidelines in retest.

Sparkletts

1 Distilled Drinking Water (1 gallon)

Venice, CA


190 Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

10 (composited)

SA-712-0588

Sparkletts†

1 Mountain Spring Water (33.8 oz.)

Los Angeles


>5700†

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected


EQI-1-LA 18-LA 20

Heterotrophic Plate Count Bacteria (HPC) exceeded guideline.

Sparkletts


Venice, CA


Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

10 (composited)

SA-712-0589

HPC Not Detected.

Brand(a)

Test #

Water Type

Purchase Location



Lab Rep. #

Comments









Other

Sparkling Springs

1 (1.5 liter)

Chicago, IL Not

Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

3.1 10 (composited)

297 719-48 (37-42)

Sparkling Springs

2 (1.5 liter)

Chicago, IL Not

Detected

No test

No test

No test

No test

No test


297 790 836 (819-827)

Vittel* 1 Mineral Water (1.5 liter)

Berkeley, CA

Vittel Bonne Source Well, Vittel, France

Not Detected

11* 9.3 9.3 Not Detected

Not Detected

Not Detected

Not Detected

10 (composited)

SA-712-0222

Arsenic level exceeds CA Prop. 65 level and WHO/EU arsenic water limit.

Vittel* 2 Mineral Water

San Francisco

No test 13 ppb

No test

No test

No test

No test

No test No test


SA-901-0799

Arsenic exceeds CA Prop. 65 level and WHO/EU water limit.

Volvic* 1 Natural Spring Water (1.5 liter)

Berkeley, CA

Clairvic Spring, Volvic, France

11 14* Not Detected

Not Detected

Not Detected

Not Detected


1.3 Fluoride found at 0.17 ppm, well below standard

10 (composited)

SA-712-0223



Berkeley, CA


No test 12* No test

No test

No test

No test

No test No test


SA-808-1667


Volvic 3 Natural Spring Water (1.5 liter)

Berkeley, CA


No test No test

No test

No test

No test

No test

Not Detected

No test 10

(composited)

SA 801-0362


Vons 1 Drinking

Los Angel

Vons LA,

Not Detect

Not Detec

Not Detec

Not Detect

Not Dete

Not Dete

Not Detected

Not Dete

3 (1 for

EQI-1-

Water (1 gallon)

es distrib. ed ted ted ed cted cted cted each contaminant type)

LA 24- LA 25

Vons 2 Drinking Water (1 gallon)


Vons LA, distrib. plt. 06-2796

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Test invalid

Not Detected

10 (composited)

SA-712-0590


Los Angeles


No test No test

No test

No test

No test

No test

Not Detected

No test 10

(composited)

SA 801-0363


Vons 1 Natural Spring Water (1 liter)

Los Angeles

Vons LA, distrib.

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected


EQI-1- LA 21- LA 23

Vons 2 Natural Mountain Spring Water (1 liter)


Vons Co. LA, distrib.

1.0 Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

0.7 10 (composited)

SA-712-0591

Vons 1 Purified Water (1 gallon)


Vons LA, plt. 06-2796

1 Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

10 (composited)

SA 712-0805

Yosemite Waters†

1 Drinking Water (5 gallons)

Los Angeles /Santa Monica

Highland Park, CA


Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

1.3 10 (composited)

SA 712-0806

Level of HPC bacteria exceeds guidelines.

Zephyrhills


Miami, FL Not

Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

10 (composited)

304 085-165 (133-138)

Note: These tests used established FDA- or EPA-approved test methods, but are not necessarily statistically representative of all bottled water of the brand listed. See text for further discussion.

a Row with bold name indicates level exceeding standard or guideline: asterisk {*} indicates exceeds enforceable standard; dagger {†} indicates exceeds unenforceable guideline. See text and accompanying Technical Report (print report only).

b As discussed in the text, the California Proposition 65 ("Prop. 65") levels noted in this table are derived from the "No Significant Risk" levels established by the California Department of Health Services, and are based on the CDHS’s rules’ assumption that people drink 2 liters of water per day (the same assumption used by the U.S. EPA). Thus, for example, the Arsenic Proposition 65 level is 10 micrograms per day, so assuming 2 liters of water consumed per day, the Prop. 65 Arsenic level is 5 ppb.

c There is no enforceable FDA standard for HPC bacteria. We use 500 cfu/ml as an informal guideline. HPC bacteria are not necessarily harmful themselves but are often used as an indicator of overall

sanitation during bottling. The European Union (EU) has adopted an enforceable bottled water standard of 100 colonies per 100 ml (at 22oC) at bottling. EPA’s tap water rules provide that water containing over 500 cfu/ml is treated as a coliform-positive sample absent proof of adequate disinfectant residual. The International Bottled Water Association recommends plants meet a level of <30 cfu/ml at bottling, and <200 cfu/ml in 90% of samples tested 5 days after bottling. Massachusetts and New York have an informal bottled water guideline (unenforceable) of 500 cfu/ml. Other states (such as RI) also have informal guidelines.

d Federal tap water and bottled water standards for arsenic, originally set in 1942 and not revised since, is 50 ppb. Congress has required updated standard by 2001. International (WHO/EU) standard is 10 ppb (see text).

e TTHMs are "total trihalomethanes," potentially cancer-causing chemicals created when organic matter reacts with chlorine. Recent studies also indicate TTHMs may also be linked to birth defects and spontaneous abortions. While California and International Bottled Water Association (industry trade association) standard is 10 ppb, new Federal tap water standard is 80 ppb, and FDA bottled water standard is 100 ppb (see text).

f BDCM is bromodichloromethane, a type of trihalomethane (see above).

g DBCM is dibromochloromenthane, a type of trihalomethane (see above).

Note re Crystal Geyser: The Crystal Geyser company has provided NRDC with test results indicating that beginning in April 1999, Crystal Geyser substantially reduced the arsenic levels in its spring water, in an agreement reached after they were sued (based on NRDC's previous test results) by the Environmental Law Foundation, a California Public Interest Group. This testing shows that as of April 1999, arsenic is either not found, or, if present, is found at levels between non-detectable (<2 ppb) and 4.8 ppb, maximum. These levels are below the California Proposition 65 arsenic warning level of 5 ppb and well below current federal standard, but EPA recently has proposed to drop the federal drinking water standard to 5 ppb.

EXECUTIVE SUMMARY

More than half of all Americans drink bottled water ; about a third of the public consumes it regularly. Sales have tripled in the past 10 years, to about $4 billion a year. This sales bonanza has been fueled by ubiquitous ads picturing towering mountains, pristine glaciers, and crystal-clear springs nestled in unto uched forests yielding absolutely pure water. But is the marketing image of total purity a ccurate? Also, are rules for bottled water stricter than those for tap water?

Not exactly. No one should assume that just because he or she purchases water in a bottle that it is necessarily any better regulated, purer, or safer than most tap water. NRDC has completed a four-year study of the bottled water in dustry, including its bacterial and chemical contamination problems. We have conducted a review of available information on bottled water and its sources, an in-depth asses sment of Food and Drug Administration (FDA) and all 50 states' programs go verning bottled water safety, and an analysis of government and academic bottled water t esting results. We have compared FDA's bottled water rules with certain internationa l bottled water standards and with the U.S. Environmental Protection Agency (EPA) rules th at apply to piped tap water supplied by public water systems. In addition, NRDC commissi oned independent lab testing of more than 1,000 bottles of 103 types of bottled wat er from many parts of the country

(California, the District of Columbia, Florida, Ill inois, New York, and Texas). Our conclusions and recommendations follow.

An Exploding Bottled Water Market

• There has been an explosion in bottled water use i n the United States, driven in large measure by marketing designed to convince the public of bottled water's purity and safety, and capitalizing on public conce rn about tap water quality. People spend from 240 to over 10,000 times more per gallon for bottled water than they typically do for tap water.

• Some of this marketing is misleading, implying the water comes from pristine sources when it does not. For example, one brand of "spring water" whose label pictured a lake and mountains, actually came from a well in an industrial facility's parking lot, near a hazardous waste dump, and perio dically was contaminated with industrial chemicals at levels above FDA standards.

• According to government and industry estimates, ab out one fourth of bottled water is bottled tap water (and by some accounts, as much as 40 percent is derived from tap water) -- sometimes with additional treatment, sometimes not.

Major Regulatory Gaps

• FDA's rules completely exempt 60-70 percent of the bottled water sold in the United States from the agency's bottled water stand ards, because FDA says its rules do not apply to water packaged and sold withi n the same state. Nearly 40 states say they do regulate such waters (generally with few or no res ources dedicated to policing this); therefore, about one o ut of five states do not.

• FDA also exempts "carbonated water," "seltzer," an d many other waters sold in bottles from its bottled water standards, applying only vague general sanitation rules that set no specific contamination limits. Fe wer than half of the states require these waters to meet bottled water standards.

• Even when bottled waters are covered by FDA's specific bottled water standards, those rules are weaker in many ways than EPA rules that apply to big city tap water. For instance, comparing those EPA regulation s (for water systems which serve the majority of the U.S. population) with FDA 's bottled water rules:

o City tap water can have no confirmed E. coli or fecal coliform bacteria (bacteria that are indications of possible contamin ation by fecal matter). FDA bottled water rules include no such prohibition (a certain amount of any type of coliform bacteria is allowed in bottled water).

o City tap water from surface water must be filtered and disinfected (or the water system must adopt well-defined protective mea sures for the source water it uses, such as control of potentially pollu ting activities that may affect the stream involved). In contrast, there are no federal filtration or

disinfection requirements for bottled water -- the only source-water protection, filtration, or disinfection provisions for bottled water are completely delegated to state discretion, and many states have adopted no such meaningful programs.

o Bottled water plants must test for coliform bacter ia just once a week; big-city tap water must be tested 100 or more times a m onth.

o Repeated high levels of bacteria (i.e., "heterotro phic-plate-count" bacteria) in tap water combined with a lack of disinefectant can trigger a violation for cities -- but not for water bottlers.

o Most cities using surface water have had to test f or Cryptosporidium or Giardia , two common water pathogens that can cause diarrhe a and other intestinal problems (or more serious problems in vu lnerable people), yet bottled water companies don't have to do this.

o City tap water must meet standards for certain imp ortant toxic or cancer-causing chemicals such as phthalate (a chemical tha t can leach from plastic, including plastic bottles); some in the in dustry persuaded FDA to exempt bottled water from regulations regarding the se chemicals.

o Any violation of tap-water standards is grounds fo r enforcement -- but bottled water in violation of standards can still b e sold if it is labeled as "containing excessive chemicals" or "excessive bact eria" (unless FDA finds it "adulterated," a term not specifically def ined).

o Cities generally must test at least once a quarter for many chemical contaminants. Water bottlers generally must test on ly annually.

o Cities must have their water tested by government- certified labs; such certified testing is not required for bottlers.

o Tap water test results and notices of violations m ust be reported to state or federal officials. There is no mandatory reporting for water bottlers.

o City water system operators must be certified and trained to ensure that they know how to safely treat and deliver water -- not so for bottlers.

o City water systems must issue annual "right-to-kno w" reports telling consumers what is in their water; as detailed in th is report, bottlers successfully killed such a requirement for bottled water.

• FDA and state bottled water programs are seriously underfunded. FDA says bottled water is a low priority; the agency estimat es it has the equivalent of fewer than one staff person dedicated to developing and issuing b ottled water rules, and the equivalent of fewer than one FDA staffer assuring compliance with the bottled water rules on the books. Although a small number o f states (such as California) have real bottled water programs, our 1998 survey f ound that 43 states have fewer than one staff person dedicated to bottled water re gulation. By comparison, hundreds of federal staff and many more state perso nnel are dedicated to tap water regulation. Directing disproportionate resour ces to tap water protection is warranted. At the same time, over half the U.S. pub lic (including many immunocompromised people) uses bottled water, and m any millions of people use bottled water as their chief or exclusive drinking water source.

• FDA's regulations are less stringent than some int ernational standards. For example, unlike FDA's rules, the European Union's ( EU's) bottled natural mineral water standards regulate total bacteria count, and explicitly ban all parasites and pathogenic microorganisms, E. coli or other coliform bacteria, fecal streptococci (e.g., Streptococcus faecalis , recently renamed Enterococcus faecalis) , Pseudomonas aeruginosa , and sporulated sulphite-reducing anaerobic bacter ia. Moreover, unlike the weaker FDA rules, the EU rules require natural mineral bottled water's labels to state the composition of the wate r and the specific water source, and mandate that only one water label may be used p er source of water. Similarly, recent EU standards applicable to all bottled water also are far stricter than FDA standards. FDA's standards for certain chemicals (s uch as arsenic) also are weaker than certain World Health Organization (WHO) guidelines.

Bottled Water: As Pure as We Are Led to Believe?

• While most bottled water apparently is of good qua lity, publicly available monitoring data are scarce. The underfunded and hap hazard patchwork of regulatory programs has found numerous cases where bottled water has been contaminated at levels above state or federal stand ards. In some cases bottled water has been recalled.

• Our "snapshot" testing of more than 1,000 bottles of 103 brands of water by three independent labs found that most bottled water test ed was of good quality, but some brands' quality was spotty. About one third of the bottled waters we tested contained significant contamination (i.e., levels o f chemical or bacterial contaminants exceeding those allowed under a state or industry standard or guideline) in at least one test. This is the most c omprehensive independent testing of bottled water in the United States that is publi cly available. Moreover, NRDC contracted with an independent data verification fi rm to confirm the accuracy of our positive test results. Still, the testing was l imited. The labs tested most waters for about half of the drinking water contaminants r egulated by FDA (to control costs). They found:

o Nearly one in four of the waters tested (23 of the 103 waters, or 22 percent) violated strict applicable state (California) limit s for bottled water in at least one sample, most commonly for arsenic or certain ca ncer-causing man-made ("synthetic") organic compounds. Another three waters sold outside of California (3 percent of the national total) vio lated industry-recommended standards for synthetic organic compoun ds in at least one sample, but unlike in California, those industry st andards were not enforceable in the states (Florida and Texas) in wh ich they were sold.

o Nearly one in five tested waters (18 of the 103, o r 17 percent) contained, in at least one sample, more bacteria than allowed und er microbiological-purity "guidelines" (unenforceable sanitation guide lines based on heterotrophic plate count [HPC] bacteria levels in the water) adopted by some states, the industry, and the EU. The U.S. bot tled water industry uses HPC guidelines, and there are European HPC standard s applicable overseas to certain bottled waters, but there are n o U.S. standards in light of strong bottler opposition to making such limits legally binding.

o In sum, approximately one third of the tested wate rs (34 of 103 waters, or 33 percent) violated an enforceable state standard or exceeded microbiological-purity guidelines, or both, in at l east one sample. We were unable to test for many microbial contaminants, suc h as Cryptosporidium , because the logistics and cost of testing for them post-bottling were beyond our means.

o Four waters (4 percent) violated the generally wea k federal bottled water standards (two for excessive fluoride and two for e xcessive coliform bacteria; neither of the two latter waters were fou nd to be contaminated with coliform bacteria in our testing of a differen t lot of the same brand).

o About one fifth of the waters contained synthetic organic chemicals -- such as industrial chemicals (e.g., toluene or xylene) o r chemicals used in manufacturing plastic (e.g., phthalate, adipate, or styrene) -- in at least one sample, but generally at levels below state and fed eral standards. One sample contained phthalate -- a carcinogen that lea ches from plastic -- at a level twice the tap water standard, but there is no bottled water standard for this chemical; two other samples from different batches of this same water contained no detectable phthalate.

o In addition, many waters contained arsenic, nitrat es, or other inorganic contaminants at levels below current standards. Whi le in most cases the levels found were not surprising, in eight cases ar senic was found in at least one test at a level of potential health conce rn.

o For purposes of comparison, we note that EPA recen tly reported that in 1996 about 1 in 10 community tap water systems (ser ving about one seventh of the U.S. population) violated EPA's tap water treatment or contaminant standards, and 28 percent of tap water systems violated significant water-monitoring or reporting requireme nts. In addition, the tap water of more than 32 million Americans (and perhap s more) exceeds 2 parts per billion (ppb) arsenic (the California Pro position 65 warning level, applicable to bottled water, is 5 ppb); and 80 to 1 00 million Americans drink tap water that contains very significant trihalomet hane levels (over 40 ppb). Thus, while much tap water is supplied by systems t hat have violated EPA standards or that serve water containing substantia l levels of risky contaminants, apparently the majority of the countr y's tap water passes EPA standards. Therefore, while much tap water is i ndeed risky, having compared available data we conclude that there is n o assurance that bottled water is any safer than tap water.

• Other academic and government bottled water survey s generally are consistent with the testing NRDC commissioned. Though usually limited in scope, these studies also have found that most bottled water mee ts applicable enforceable standards, but that a minority of waters contain ch emical or microbiological contaminants of potential concern.

Recommendations

Every American has a right to safe, good-tasting wa ter from the tap. If we choose to buy bottled water, we deserve assurances that it too is safe. In addition, whether our water comes from a tap or a bottle, we have a right to kn ow what's in it. Among our key recommendations are:

• FDA should set strict limits (equivalent to those in California, EPA rules, international standards, or industry guidelines, wh ichever is most health protective) for contaminants of concern in bottled water, including arsenic, heterotrophic-plate-count bacteria, E. coli and other parasites and pathogens, Pseudomonas aeruginosa , and synthetic organic chemicals, including chemic als such as phthalate, which can leach from plastic.

• FDA's rules should be overhauled and should apply to all bottled water distributed nationally or within a state, carbonated or not. To comply with common sense and a new requirement tucked into the 1996 Safe Drinkin g Water Act Amendments, FDA standards must be made at least as strict as th ose applicable to city tap water supplies. The FDA should adopt rules for bottled wa ter testing, to control microbial and chemical contaminants, to protect water sources , to ensure the reporting of test results and violations to state and federal of ficials, to train and certify operators of water bottling plants, and to require the use of certified labs. In addition, FDA should do its own audits and monitori ng of the quality of bottled water sold across the nation and should publicly re lease the results.

• Right-to-know requirements should require water-bo ttle labels to disclose contaminants, the exact water source, treatment, an d other key information, as is now required of tap water systems. If bottled water is so pure, why not prove it with full disclosure on the label?

• FDA's bottled water program and state programs mus t be better funded, with a new penny-per-bottle fee on bottled water to fund r egulatory programs, testing, and enforcement.

• State bottled water programs should be subject to federal review and approval, and should receive federal funding from the penny-p er-bottle fee recommended above.

• If FDA fails within 18 months to make its bottled water rules and its regulatory oversight and enforcement at least as stringent as those for tap water, the bottled water regulatory program and funding for it (includ ing the proceeds from a penny-per-bottle fee) should be transferred to EPA. We re commend this transfer with some trepidation, in light of EPA's less-than-perfe ct tap water program and its own serious resource constraints. We conclude, however, that it would be hard for EPA authority to be worse than FDA's seriously deficien t program, and that a transfer of funding for bottled water supervision to EPA from F DA would help. Clearly EPA has more resources dedicated to drinking water and has adopted stricter rules and oversight of state programs than FDA has. More stri ngent EPA tap water rules should be applied to bottled water within six month s after transfer of authority.

• A credible independent third-party nongovernmental organization should establish a "certified safe" bottled water program that is tr uly open, ensures full compliance with all FDA, EPA, state, industry, and internation al standards and guidelines, does twice-a-year surprise inspections, documents suffic ient source protection and

treatment to meet EPA/Centers for Disease Control a nd Prevention (CDC) criteria for Cryptosporidium -safe bottled water, and makes readily available (i ncluding on the Web) all inspections and monitoring results. Cu rrently neither NSF nor International Bottled Water Association certificati ons have sufficiently stringent criteria, nor are they sufficiently independent of the industry, to provide consumer confidence that such strict standards are met. Immu ne-compromised or other vulnerable people particularly may want such certif ication to be fully confident of their bottled water's purity.

• While we reasonably may choose to use bottled wate r for convenience, taste, or as a temporary alternative to contaminated tap water, it is no long-term national solution to this problem. Bottled water sometimes i s contaminated, and we don't use it to bathe, shower, etc. -- major routes of ex posure for some tap water contaminants. A major shift to bottled water could undermine funding for tap water protection, raising serious equity issues for the p oor. Manufacture and shipping of billions of bottles causes unnecessary energy and p etroleum consumption, leads to landfilling or incineration of bottles, and can release environmental toxins. The long-term solution to our water woes is to fix our tap water so it is safe for everyone, and tastes and smells good.

Chapter 1

PRINCIPAL FINDINGS AND RECOMMENDATIONS

Americans increasingly are turning to bottled water , making it a $4 billion-a-year business in the United States. [1] Millions of us are willing to pay 240 to over 10,0 00 times more per gallon for bottled water than we do for tap water - - though we probably rarely think of it that way. [2] However, some bottled water contains bacterial con taminants, and several brands of bottled water contain synthetic organic c hemicals (such as industrial solvents, chemicals from plastic, or trihalomethanes -- the b y-products of the chemical reaction between chlorine and organic matter in water) or in organic contaminants (such as arsenic, a known carcinogen) in at least some bottles (see C hapter 3 and our accompanying Technical Report [print report only]). [1a] Moreover, as Chapter 4 documents, bottled water regulations have gaping holes, and both state and f ederal bottled water regulatory programs are severely underfunded. In Chapter 5 we present evidence that there is substantially misleading marketing of some bottled water, and in Chapter 6 we argue that consumers should be informed about the contaminants found in the water they purchase. NRDC's major findings and recommendations are summa rized below.

Findings

1. Most bottled water apparently is of good quality , but some contains contamination; it should not automatically be assum ed to be purer or safer than most tap water.

Based on available data and our testing, most bottl ed water is of good quality, and contamination posing immediate risks to healthy peo ple is rare (see Chapter 3 and the Technical Report [print report only]). However, blanket reassurance s from the bottled water industry that bottled water is totally safe a nd pure are false.

No one should assume that just because water comes from a bottle that it is necessarily any purer or safer than most tap water. Testing com missioned by NRDC and studies by previous investigators [3] show that bottled water is sometimes contaminated. NRDC contracted with three leading independent laborator ies to do "snapshot" testing (testing one to three times for a subset of contaminants of concern) of bottled water.

We found after testing more than 1,000 bottles that about one fourth of the bottled water brands (23 of 103 waters, or 22 percent) were conta minated at levels violating strict enforceable state (California) limits for the state in which they were purchased, in at least one sample. We also found that almost one fifth of the waters we tested (18 of 103, or 17 percent) exceeded unenforceable sanitary guidelines for microbiological purity (heterotrophic-plate-count [HPC] bacteria guideline s, adopted in some states, the European Union (EU), and recommended by the bottled water industry) in at least one test. While HPC bacteria may be harmless themselves, they may mask the presence of pathogens; some states, the EU and the bottled wate r industry have adopted HPC guidelines to help ensure sanitary source water, pr ocessing, and bottling practices. In all, at least one sample of one third of the waters we t ested (34 of 103, or 33 percent) exceeded a state enforceable standard for bacterial or chemi cal contamination, a nonenforceable microbiological-purity (HPC) guideline, or both.

The labs contracted by NRDC detected contaminants o f potential concern (either microbes or chemicals regulated in tap or bottled water) in at least one sample of about half of the bottled waters we tested, though in the majority of the waters no standards were exceeded. While state or industry standards and guidelines were violated in at least one test for about one fourth of the bottled waters, ju st four waters (4 percent) exceeded the weak federal standards. Of these four waters, two violated the FDA coliform-bacteria rule (coliforms are bacteria that can be harmless themse lves but may indicate the presence of fecal contamination and disease-carrying organisms in the water) in one test. When we retested another lot of the same waters for colifor m bacteria, however, both of these waters tested clean. In addition, two other waters violated the FDA standard for fluoride in two sequential tests of samples from different lots of these two waters.

While our testing is the most comprehensive publicl y available independent testing of U.S. bottled water, it must be viewed as incomplete. Onl y about half of the drinking water contaminants regulated by FDA and EPA were tested, due to cost constraints. There are, conservatively, more than 700 brands selling bottle d water in the United States, yet we tested only 103 waters. Additionally, we generally tested just one to three lots of each water, whereas often thousands or even millions of bottles may be produced annually by a single bottler, with the potential for periodic (an d undetected) contamination problems. Testing by other investigators generally has been c onsistent with our results. For example, as is discussed in detail in the accompany ing Technical Report (print report only), a major survey of microbiological contaminat ion of domestic and imported bottled water sold in Canada published in 1998 yielded resu lts very similar to NRDC's. [4] We were not able to test for Cryptosporidium in bottled water (nor did the Canadian investigato rs) because the current EPA method for Cryptosporidium monitoring requires the filtration of many gallons of water and analysis of the filter us ing a method feasible for bottlers prior to bottling the water, but this was logistically an d financially infeasible for us to use on finished product sold at stores.

Bottled water recalls and other contamination incid ents -- whether bacterial, industrial-chemical, algae, excessive-chlorine, or other conta mination problems -- have sometimes been quietly dealt with by bottlers, generally with little or no public fanfare. In other cases, violations of bottled water standards have been all owed to go on for months without a recall or formal enforcement action. Although most of the bottled water on the market

seems to be of good quality, some of these products are not as absolutely pure and pristine as many of their consumers may expect.

Comparing the data for bottled water quality with t hose for tap water is not straightforward. Far more monitoring data are publi cly available for tap water than for bottled water. EPA requires frequent monitoring of tap water and makes available on its Web site national compliance data for all tap water systems. [5] Additionally, numerous surveys of tap water quality (beyond simple complia nce data) are available for tap water quality, [6] whereas no such comprehensive data are available f or bottled water. Thus, direct comparison of tap water quality versus bottl ed water quality is not possible based on comparable databases. However, EPA recently repo rted that in 1996, almost 10 percent of community tap water systems (serving 14 percent of the U.S. population) violated federal EPA tap water treatment or contaminant stan dards, and 28 percent of these tap water systems violated significant water quality mo nitoring or reporting requirements. [7] While these tap water system compliance data are pl agued by underreporting and likely understate the extent of the problem somewhat, [8] without question they are based on a far larger database than is publicly available for bott led water. Moreover, according to available data, nearly half of the U.S. population served by tap water systems gets legally allowable but from a health standpoint potentially significant levels of contaminants such as cancer-causing trihalomethanes, radon, and/or ar senic in their tap water. [9] Thus, while there definitely are problems with a substantial mi nority of the nation's tap water systems, based on the limited data available there is little basis to conclude that just because water is purchased in a bottle it is necessarily any bett er than most tap water.

2. Bottled water contamination with microbes may ra ise public health issues, particularly for people who are immunocompr omised.

Millions of Americans use bottled water as their pr imary source of drinking water. Some of these people are immunocompromised (such as people undergoing cancer chemotherapy, organ-transplant recipients, the chronically ill el derly, some infants whose immune systems are not fully developed, and people with AI DS) and use bottled water at the recommendation of public health officials or health care providers, who suggest that tap water use may be too risky. [1b] In some cases, officials also may urge the general public to use bottled water during a tap water contamination crisis.

As discussed in Chapter 3 and our attached Technical Report (print report only), NRDC's testing and other published and unpublished data in dicate that while most bottled water apparently is of high quality in terms of microbiol ogical purity, a substantial minority of it may not be. As noted there, a small percentage of t he bottled water we tested (about 3 percent) sometimes contained coliform bacteria -- a possible indicator of contamination with pathogenic bacteria -- and nearly one fifth of the waters we tested contained heterotrophic-plate-count (HPC) bacteria at levels exceeding state and industry guidelines in at least one test. Some bottled waters contain b acteria (sometimes naturally occurring), including species of Pseudomonas and others, some of which may be a health concern for immunocompromised people. [10]

In cases where there is known tap water microbial c ontamination, or where an individual suffers from specific health problems such as a com promised immune system, tap water can be boiled for one minute to kill all microbes. In the alternative, certain types of bottled water may be a temporary solution. To be cautious, however, an immunocompromised person should buy bottled water only if it is from a protected source, and is subjected to EPA-CDC-recommended treatment to kill Cryptosporidium , the intestinal parasite that

sickened over 400,000 people and killed over 100 in a 1993 Milwaukee tap water incident. [11] For example, to remove or kill Cryptosporidium , water must be treated with "absolute one micron" membrane filtration or reverse osmosis, adequately high levels of ozone disinfection, or distillation, at a minimum.

Thus, NRDC recommends that seriously immunocompromi sed people boil their tap water for one minute before using it for consumption or w ashing food. If they choose to buy bottled water, they should consider purchasing only certified "sterile" bottled water. Most bottled water has not been independently certified to meet either the EP A-CDC standards for killing Cryptosporidium or the definition of "sterile" water, so vulnerabl e people must be especially careful in selecting a drinking water supply. [1c]

3. Government bottled water regulations and program s have serious deficiencies.

Chapter 4 outlines in detail the gaping holes in fe deral regulatory controls for bottled water, and the trivial FDA resources dedicated to p rotecting bottled water. FDA estimates that one half of a full-time FDA staff person is de dicated to bottled water regulation, and fewer than one FDA staff-person equivalent is spent on assuring compliance with FDA bottled water rules. [12] An estimated 60 to 70 percent of the bottled water sold in the United States, according to FDA interpretations, is exempt ed from FDA's contamination limits and specific bottled water standards because it is bott led and sold in the same state.

Thus, under FDA's interpretation, the regulation of most bottled water is left to ill-equipped and understaffed state governments. Yet 43 of 50 st ates have the equivalent of fewer than a single staff person dedicated to regulating bottled water, according t o our 1998 state survey. Four states have adopted no regulations at all for bottled water, and the majority of states have simply republished FDA's deficient r ules. About 40 states say they regulate "intrastate" waters, but most have dedicated virtua lly no resources to doing so.

FDA's rules also exempt many forms of what most of us would consider "bottled water" from all of its specific water-testing and contamin ation standards. If the product is declared on the ingredient label simply as "water," "carbonated water," "disinfected water," "filtered water," "seltzer water," "sparkli ng water," or "soda water," it is not considered "bottled water" by FDA, [13] nor, as noted in Chapter 4, do most states regulat e this water as bottled water. For these products, th e specific FDA contamination standards and water quality testing requirements for bottled water are not applicable. No contamination monitoring is required, and only a va gue narrative legal standard applies, stating that the water cannot be "adulterated" -- a term not specifically defined and, to date, apparently never enforced against any of thes e products by FDA. Therefore, the generalized FDA "good manufacturing practice" requi rements applicable to these waters [14] set no specific contamination standards. The same i s true with most state regulations.

Even what FDA defines to be "bottled water" is exem pt from many of the standards and testing requirements that apply to tap water. This appears to directly contradict the letter and the spirit of the Federal Food, Drug, and Cosme tic Act (FFDCA), which requires -- under a provision strengthened in 1996 -- that FDA' s bottled water standards must be at least as stringent as tap water standards. [15] For example, EPA's rules clearly prohibit tap water from containing any confirmed E. coli or fecal coliform bacteria (bacteria that are indicators of possible fecal matter contamination o ften associated with waterborne disease). [16] FDA has no such prohibition for bottled water; instead, any type of coliform

bacteria is allowed up to a certain level. [17] (See Table 1 for a comparison of EPA and FDA rules.)

Similarly, a big city has to test its tap water 100 times or more each month for coliform bacteria -- many times a day, on average -- yet bot tled water (even at an enormous bottling plant) must be tested for coliform bacteria only on ce a week under FDA rules. Moreover, while high overall levels of bacteria (known as het erotrophic-plate-count [HPC] bacteria) can be counted toward bacteria violations for city tap water (in the absence of adequate disinfection), as described in Chapter 4, FDA bowed to bottled water industry arguments and decided to apply no standards for HPC bacteria in bottled water. HPC bacteria are commonly found in bottled water.

EPA's "information collection rule" generally requi res big cities that use surface water (such as rivers or lakes) for tap water to test for common parasites such as viruses, Giardia , and Cryptosporidium . Under FDA rules, water bottlers are never required to do so. In the same vein, cities using surface water genera lly must disinfect their water and filter it to remove bacteria and certain parasites. [1d] Yet there are no FDA standards requiring bottled water to be disinfected or treated in any w ay to remove bacteria or parasites. Additionally, the FDA requirement that bottled wate r be derived from an "approved source" is no substitute for source water protectio n, filtration, or disinfection. This rule has been aptly characterized as a "regulatory mirag e," since what is "approved" is left to state discretion with no meaningful federal require ments or oversight.

For chemical contaminants, the regulations for bott led water are also weak in many ways. While a city generally must test its tap water for scores of organic chemicals (such as industrial chemicals, some pesticides, and trihalom ethanes) at least quarterly, [1e] bottlers generally need only test once a year under FDA's ru les. These infrequent annual tests could miss serious problems, because levels of thes e contaminants sometimes vary substantially depending on when they are tested.

Also, phthalate [1f] -- a toxic chemical produced in plastic-making tha t tests show can leach from plastic into water under common conditions -- is regulated by EPA in tap water but FDA does not regulate it in bottled water. After so me water bottlers and plastics manufacturers argued that phthalate controls would be inappropriate and burdensome for bottled water, FDA decided not to regulate it in bo ttled water, where it is sometimes found, particularly after long storage.

Furthermore, FDA currently has no enforceable stand ard or treatment requirement for three other contaminants regulated by EPA in tap wa ter -- acrylamide, asbestos, and epichlorohydrin. Thus, while city water systems gen erally must test for all of these contaminants and must meet EPA standards for them, presently water bottlers need not.

EPA also requires city tap water suppliers to test for more than a dozen "unregulated" contaminants -- chemicals that are not currently su bject to EPA standards but which, if present, may pose a health concern, such as a risk of cancer. Under EPA rules, states are to consider adding 15 additional named unregulated contaminants to this list for mandatory water system monitoring, if they are beli eved to be a potential problem in local tap water. [18] Bottlers face no monitoring requirements for any unregulated contaminants.

Even if bottled water is more contaminated than FDA 's standards would otherwise allow, FDA rules explicitly allow the water to be sold, as long as it says on the label "contains excessive chemical substances" or "contains excessi ve bacteria" or includes a similar statement on the label. FDA says it may enforce against such labeled contaminated water if it finds that it is "adulterated" and "injurious to health." However, there is no

requirement that water bottlers report such problem s to FDA, and apparently there are no cases of FDA having taken any enforcement action ag ainst any such bottlers.

FDA has stated that bottled water regulation carrie s a low priority. [19] Because of this, water bottlers can expect to be FDA-inspected only about every four to five years, on average. [20] This is far too infrequent to detect certain possi ble problems, such as periodic contamination caused by occasional substandard plan t operations or maintenance, bacteria from sewage overflows or leaks, pest infes tations, or occasional spikes of pollution due to short-lived phenomena. In addition , bottlers are not required to keep records of their operations and testing for more th an two years, making effective inspections difficult or impossible, since evidence of periodic or past problems can simply be discarded before it is ever reviewed by inspecto rs.

It also should be noted than in many cases FDA's ru les are weaker than international standards. The European Union's (EU's) bottled wate r standards, for example, set limits for total bacteria count, [21] which, as noted above, FDA does not. Moreover, the EU's bottled mineral water rules ban all parasites and p athogenic microorganisms, E. coli or other coliform bacteria, fecal streptococci (e.g., Streptococcus faecalis , recently renamed Enterococcus faecalis ), Pseudomonas aeruginosa , or sporulated sulphite-reducing anaerobes, whereas FDA's rules include no such bans . [22] Additionally, unlike the FDA rules, EU rules require natural mineral water's lab els to state the waters' "analytical composition, giving its characteristic constituents " and the specific water source and name, and information on certain treatments used. [23] The EU mineral water rules further forbid use of more than one brand label per source of water [24] and generally prohibit labels from making any claims about the prevention, treatm ent or cure of human illness. [25] No such provisions are included in FDA rules. Similarl y, the EU's new general standards for all bottled water generally are far stricter than FDA' s rules, and FDA's standards for certain chemicals (such as arsenic) are weaker than World H ealth Organization (WHO) guidelines for drinking water. [26]

4. Voluntary bottled water industry controls are co mmendable, but an inadequate substitute for strong government rules a nd programs.

The bottled water industry's trade association, the International Bottled Water Association (IBWA), has sometimes been a progressive force in s eeking to improve certain FDA controls (petitioning for stronger FDA rules in som e areas, for example). Moreover, IBWA has adopted a voluntary state bottled water code -- somewhat stricter than the FDA rules -- which has been adopted in whole or in part by 16 st ates. However, IBWA sometimes has vigorously fought against tough FDA rules, such as possible controls on Pseudomonas aeruginosa bacteria, rules for heterotrophic bacteria, and ri ght-to-know requirements for bottled water. The fight against right-to-know for bottled water is interesting in light of the bottled water industry's frequent references to tap water contamination problems. It also starkly contrasts with IBWA's admission that bottle d water sales may have increased due to the requirement that diet soda labels disclose a ll ingredients, which IBWA said may have driven consumers concerned about diet soda's c ontents to use bottled water. [27]

IBWA has adopted a much-ballyhooed voluntary indust ry code and inspection program for its members. The association claims its members pro duce 85 percent of the bottled water sold in the United States. [28] But these voluntary IBWA standards are just that - - voluntary -- in the 34 states that have not adopted them, and there is no published reporting about compliance. Additionally, IBWA does not disclose th e results of its inspections and testing to the public, so it is impossible to verify indepe ndently the effectiveness of these

voluntary programs. Moreover, even by IBWA's count, many bottlers are not IBWA members and have never volunteered to comply with t he association's standards. In fact, some of the problems with some bottled waters discu ssed in this report have occurred with IBWA members, suggesting the IBWA program is n ot foolproof. Finally, it should be noted that, as with FDA rules, IBWA standards do no t apply to seltzer, soda water, carbonated water, or the many other waters exempt f rom FDA's bottled water rules. [29]

5. Bottled water marketing can be misleading.

Chapter 5 shows that despite recent FDA rules inten ded to reduce misleading marketing, some bottled water comes from sources that are vast ly different from what the labels might lead consumers to believe. One brand of water discussed in this report was sold as "spring water" and its label showed a lake and moun tains in the background -- with FDA's explicit blessing. But until recently the water act ually came from a periodically contaminated well in an industrial facility's parki ng lot, near a waste dump (a state whistleblower informed the local media after years of internal struggles, finally putting an end to the use of this source). [30] Another brand of water sold with a label stating i t is "pure glacier water" actually came from a public water su pply, according to state records. [31] While FDA recently adopted rules intended to curb s uch practices, those rules include many weak spots and loopholes (including those that allowed the water taken from an industrial-park well to be sold as spring water wit h a label picturing mountains), and there are very few resources to enforce them.

Water with one brand name can come from numerous di fferent sources, depending upon the time of year, location of sale, or other market factors. Moreover, water from one source (such as the industrial-parking-lot well noted abov e) can be used and labeled for a half-dozen or more different labels and brands. In addit ion, according to government and industry estimates, about one fourth or more of the bottled water sold in the United States [32] (and by some accounts 40 percent [33]) is taken from public water systems -- tap water, essentially. Sometimes this tap water is bottled af ter additional treatment (such as carbon filtration or ozonation), and sometimes it is bottl ed with little or no additional treatment.

6. The long-term solution to drinking water problem s is to fix tap water -- not to switch to bottled water.

Many people may choose to use bottled water because they prefer its taste and smell, or because it is convenient. Bottled water, in some ca ses, also may be needed as a stopgap measure when tap water is contaminated, rendering t he water nonpotable (as in the case of a boil-water alert). In the long run, however, i t is far better from an economic, environmental, and public health point of view to i mprove public drinking water supplies than it is to have a massive societal shift from co nsumer use of tap water to use of bottled water. We cannot give up on tap water safety. The r easons we have reached this conclusion include:

• Public health concerns. Bottled water sometimes po ses its own potential health risks due to contamination. Furthermore, even if bo ttled water is completely pure, use of it can only somewhat reduce public exposure to contaminants in tap wate r; some people will continue to use tap water. Even if no one were to drink tap water, virtually everyone would continue to be exposed to some common contaminants

(especially those that are volatile or can penetrat e the skin) when showering, bathing, washing dishes, and cooking.

• Equity concerns. If those who can afford bottled w ater shift to it as their primary source of drinking water, only low-income people ar e left drinking tap water, its quality may then slip into an ever-downward spiral.

• Environmental concerns. Provision of water by unde rground pipe is energy-efficient and consumes far fewer natural resources per gallon than using bottled water. Placing water in bottles and transporting th ose heavy bottles around the country (or around the globe) consumes far more ene rgy and other resources than using tap water. The manufacture of bottles also ca n cause release of phthalates, and other byproducts of plastic-making, into water, air, or other parts of the environment. And, ultimately, many bottles will be added to already overflowing landfills or incinerated, potentially adding to our environmental problems.

• Economic concerns. Bottled water typically costs h undreds of times more than tap water, even up to 10,000 or more times more than wh at comes out of your faucet. These costs cannot be easily borne by low-income pe ople and should not have to be borne by the elderly, the immunocompromised, or chronically ill people in order to get water that is safe to drink. The $4 billion a year now spent by consumers on bottled water could be better spent on upgrading ta p water supplies.

Thus, in NRDC's view, although bottled water may be a convenience or needed as a short-term solution to tap water contamination problems i n some communities or for highly vulnerable subpopulations, it should generally be v iewed only as a temporary fix. Our study leads us to make the following recommendation s:

Recommendations

1. Fix tap water quality -- don't give up and just rely on bottled water.

For the reasons just noted, it would generally be b etter to upgrade and improve tap water quality than to have a part of society shift to bot tled water. Those who dislike the taste and smell of their tap water may want to consider placi ng tap water in a glass or ceramic pitcher in their refrigerator, with the top loose t o allow the chlorine to dissipate overnight. This also will allow volatile disinfection by-produ cts to evaporate (though less volatile disinfection by-products may stay in the water). Ov ernight refrigeration in a loosely capped container eliminates the objectionable chlor ine taste and odor, and the chilled water can be put in reusable sports bottles as desi red to make it convenient to carry ice-cold water to the office, on trips, or when exercis ing. It also saves money and has environmental and other benefits, as previously not ed.

2. Establish the public's right to know for bottled water as now required for tap water.

Bottled water labels should be required to list any contaminants found in the water (as well as health goals and standards), the water's fl uoride and sodium content, the health

effects of the contaminants found, the bottler's co mpliance with applicable standards, the source of the water, and any treatment used. Labels also should indicate whether the water meets the EPA-CDC criteria for Cryptosporidium safety. The date of bottling and information on how to get further information also should be placed on labels. We fail to understand why, if bottled water is as pure as the bottlers say, they are so afraid of a right-to-know requirement. However, FDA has the authority to require such information on bottled water labels, has been required by the Safe Drinking Water Act to evaluate the feasibility of doing so, and therefore should move forward with rules requiring such disclosure for bottled water.

3. FDA should create a Web site and a phone-accessi ble information system on bottled water.

FDA should add to its Web site and should make avai lable, through a hot line, a user-friendly array of information on bottled water bran ds, including all of the basic information noted in recommendation 2, for each bottler. This b ottled water information should build upon and expand the EPA hotline and web site that g ives specific information on individual tap water systems and drinking water gen erally. The FDA hot line and Web site should make available the results of all government , industry, or other bottled water testing by certified labs for all brands. It also s hould include information on all inspections and recalls, and any other relevant consumer inform ation on particular brands of bottled water.

4. Overhaul FDA rules for bottled water.

The FDA rules for bottled water are weak and should be strengthened. If necessary, FDA should request additional legislative authority to adopt these changes. FDA should:

• Establish standards and monitoring requirements fo r bottled water no less stringent than EPA's rules for tap water in major c ities, including standards for all microbiological and chemical contaminants, specific and defined water treatment (including filtration and disinfection or strict so urce-protection requirements), operator-certification requirements, and unregulate d-contaminant monitoring rules.

• Set strict, up-to-date standards for contaminants potentially found in bottled water. These standards should be at least as protective of public health as the strictest regulations adopted by other authorities. Thus, the standards should be as stringent as possible for the bottled water industr y and certainly should be no less stringent than the following: arsenic less than 5 p arts per billion (ppb)(California Proposition 65); heterotrophic-plate-count bacteria less than 100 colony-forming units per milliliter at bottling (EU standard), 200 cfu/ml 5 days after bottling in 90 percent of samples (industry recommendation), and a maximum at all times of 500 cfu/ml; no parasites, pathogens, fecal streptococci (e.g., the recently renamed Enterococcus faecalis ), Pseudomonas aeruginosa , sporulated sulphite-reducing anaerobes (EU natural mineral water rules); trihalo methanes less than 10 ppb (California law and industry model code); phthalate less than 6 ppb (EPA tap water); individual synthetic organic and inorganic chemicals (e.g., bromodichloromethane) equal to California's Proposi tion 65 levels. For other

contaminants more strictly controlled under bottled water industry code than under current FDA rules or with EPA Health Advisori es, FDA should adopt the industry or EPA recommendation.

• Immediately finalize its 1993 proposed ban on coli form bacteria in bottled water.

• Establish clearly defined criteria and protections for an "approved source" of bottled water under FDA rules, and require annual s tate reevaluation of compliance with these new "approved source" rules, including r eview of potential contamination problems.

• Require bottlers to retain microbial test results for 5 years, and chemical tests for 10 years, as EPA requires for tap water.

• Mandate a bottling date and "refrigerate after ope ning" statement on labels, in order to inform consumers who seek to minimize the chances of potentially excessive microbial growth and contamination in bot tled water.

• Require labs used for bottled water analysis to be certified by EPA or FDA.

• Direct that water be tested daily at the plant for microbes, quarterly for chemicals during bottling, and quarterly in bottles after ext ended storage, especially for chemicals that can leach from bottles and for micro bes that can multiply during storage.

• Require quarterly reporting of test results to sta tes and FDA, and reporting of acute violations within 24 hours to state and FDA o fficials.

• Prohibit all sales of water contaminated at levels above FDA standards.

• Apply FDA's standards to all intrastate bottled wa ter sales.

• Mandate that water bottlers be trained and certifi ed.

• Require state bottled water programs to be reviewe d and approved by FDA, and FDA should oversee their effectiveness.

• Establish clear mandatory recall authority for FDA through administrative order or a civil action.

• Maintain an inventory, and register all water bott lers.

• Cover all water sold in a bottle that is likely to be ingested by people, including "purified," "disinfected," "seltzer," etc., under t he FDA bottled water standards -- as under California and other states' laws.

• Conduct routine FDA monitoring of bottled water qu ality for waters sold across the country, as has been done in Canada for many years, and release the results, including brand names, to the public in published r eports and on its website.

5. Annual inspections should be required.

FDA should conduct annual inspections (or fund annu al state inspections) of all bottling facilities and of their water sources.

6. Institute a "penny-per-bottle" fee to assure bot tled water safety.

We recommend that a fee of one cent per bottle of b ottled water sold should be instituted, to be placed in a trust fund for use without furthe r appropriation by FDA to pay for a stringent bottled water regulatory program. The fee , which we estimate would raise more than $30 million dollars a year, should fund improv ed FDA implementation, random testing, a public Web site, state and federal inspe ctions, and funding and oversight of state programs and bottlers.

7. Set a deadline for transferring the bottled wate r program to EPA if FDA lacks the resources or will to implement it eff ectively.

FDA has made it clear that bottled water protection is a low priority. If FDA concludes that making bottled water comply with the same requireme nts as tap water is unduly burdensome, or that the preceding recommendations t o achieve that goal are not of sufficient priority to claim FDA resources, the pro gram should be transferred to EPA, which already regulates tap water. FDA should be gi ven no more than 18 months to demonstrate, by overhauling its rules and program, whether it wishes to retain the program. If such an overhaul does not occur, the pr ogram should be automatically transferred to EPA. EPA should be given six months to apply the rules applicable to big city water systems to bottled water; of course, the rules should be modified where they would be inapplicable to bottled water (as where EP A rules require monitoring at the tap). EPA also should be provided the revenue from a penn y-per-bottle fee on bottled water to carry out the program. We make this recommendation for transfer with some uneasiness, since EPA's tap water regulatory program suffers fr om its own serious deficiencies and resource constraints. However, on balance we believ e that if FDA continues to lack the will and resources to address bottled water issues as th e sales skyrocket, even an inadequate EPA bottled water regulatory program could hardly b e worse than FDA's current effort.

8. Establish "certified safe" bottled water.

In light of the poor government regulatory performa nce, an independent third-party organization such as Green Seal or Underwriters Lab s should establish a "certified safe" bottled water program. Criteria for inclusion would be that the water always meets the strictest of all standards, including FDA, IBWA, in ternational (e.g., EU and WHO) and state rules, recommendations, and guidelines, meets all E PA health goals, health advisories, and national primary drinking water regulations, is tested at least daily for microbial contaminants and quarterly for chemicals (monthly i f using surface water or other water subject to frequent water quality changes), meets s ource-water protection criteria, is protected from Cryptosporidium in accordance with EPA-CDC guidelines, is disinfec ted, and is surprise inspected twice a year by independe nt third-party inspectors. The

certifying organization should establish an open-do cket release of its inspection, testing, and compliance evaluation results. While the curren t NSF and IBWA seals are intended to provide such a stamp of approval, we believe a more independent and open body imposing stricter standards and making all testing, inspection, and other collected information readily available to consumers (includi ng on the Web), would provide greater consumer confidence in the certification.

Thus, we believe the long-term national solution is to fix the nation's tap water supplies. Until the recommended regulatory changes are adopte d, those who wish to use bottled water for reasons of taste or otherwise cannot be c onfident that they are necessarily getting what they pay for -- a pure, well-regulated product. Unless such reforms are adopted, bottled water consumers should observe the ancient rule of caveat emptor -- "buyer beware.")

Chapter Notes

1a. Throughout this document we use the term contam inant in the same way that term is used in the Safe Drinking Water Act (SDWA) -- i.e, "any physical, chemical, biologi cal, or radiological substance or matter in water." 42 U.S.C. § 300f(6).

1b. EPA and CDC have jointly recommended that sever ely immunocompromised people consult with their hea lth care provider to decide whether they should drink tap wa ter or switch to bottled water treated with certain advanced technologies (or use tap water that is boiled or tr eated with an advanced home filter). However, we ha ve found that very few bottled water companies clearly label their bot tles to enable consumers to determine whether the w ater meets the EPA-CDC recommendations.

1c. The use of home filtration devices is an issue beyond the scope of this study, but experts recomme nd that at a minimum, an immunocompromised person should only pu rchase a filter certified by NSF International for "cyst removal" (i.e., to remove protozoa "cysts," such as Cryptosporidium ). In addition, users of home filters must be extre mely careful to maintain the filter and to change the filtration media at least as frequently as recommended by the manufacturer, or more often.

1d. Cities using surface water as their source gene rally must disinfect, unless they can document and obtain state approval for a filtration waiver, based on evidence that their source water is pure and highly protect ed from contamination.

1e. In certain cases, EPA's rules allow tap water t o be tested less frequently than quarterly for some organic contaminants. For example, a waiver may be availabl e to a system if the contaminant was not detected i n the first round of four quarterly tests and the system is evaluated by the state and found unlikely to become contamin ated in the future.

1f. Specifically, di(2-ethylhexyl)phthalate, or DEH P--a likely carcinogen that studies have indicated also may cause disruption of the endocrine system. See, e.g., B.J. Davis, R.R. Maronpot, and J.J. Heindel , " Di-(2-ethylhexyl) phthalate Suppresses Estradiol and Ovulation in Cycling Rats, " Toxicol Appl Pharmacol , vol. 128, no. 2, pp. 216-223 (October 1994),(exposure to DEHP resulted in hypoestrogenic anovulatory cycles and polycystic ovaries in adult female rats).

Report Notes

1. Beverage Marketing Association, 1998 data cited in "Advertising & Marketing:Waterlogged," Los Angeles Times p. D5 (April 23, 1998); Tim Madigan, Fort Worth Star-Telegram , August 24, 1997, page 1.

2. The bottled water NRDC purchased ranged in price from a low of about $0.70 per gallon to more than $5.00 per gallon for more expensive imports sold in smaller bottles. The average cost of bottled water in California ha s been reported to be $0.90 cents per gallon, though that appears to b e a low estimate compared to most of our purchases. Tap water generally costs from a low of around $0.45 cents pe r thousand gallons to about $2.85 per thousand gallons, with an average cost of about $1.60. L. Allen & J.L. Darby, "Quality Control of Bottled and Vended Water in Ca lifornia: A Review

and Comparison of Tap Water," Journal of Environmental Health , vol. 56, no. 8, pp. 17-22 (April 1994); "Bottled Water Regulation," Hearing of the Subcommittee on Oversig ht and Investigations of the House Committee on Ene rgy and Commerce, Serial No. 102-36, 102nd Cong., 1st Sess. 5, (April 10, 1991). Thus, the ratio for bottled w ater to tap water ranges from a low of about 240 times more expensive (cheap bottled water: expensive tap water), to ove r 10,000 times more expensive (expensive bottled water: cheap tap water).

3. See Chapter 3 on bottled water contamination, an d for more details see attached Technical Report (p rint report only) on bacterial and chemical contamination of bottled water.

4. D. Warburton, B. Harrison, C. Crawford, R. Foste r, C. Fox, L. Gour, and P. Krol, "A Further Review of the Microbiological Quality of Bottled Water Sold in Ca nada: 1992-1997 Survey Results," International Journal of Food Microbiology , vol. 39, pp. 221-226 (1998).

5. See www.epa.gov/enviro/html/sdwis/sdwis_ov.html

6. See, e.g. NRDC, USPIRG, and Clean Water Action, Trouble on Tap: Arsenic, Radon, and Trihalomethanes in Our Drinking Water (1995); NRDC, Your Are What You Drink (1995); NRDC, Think Before You Drink (1993); NRDC, Think Before You Drink: Urgent Release: 1992-1993 Update (1994); EWG & NRDC, Just Add Water (1996).

7. EPA, Providing Safe Drinking Water in America: 1996 Nati onal Public Water System Annual Compliance Report a nd Update on Implementation of the 1996 Safe Drinking Water Act Amendments , Executive Summary (September 1998),(available at www.epa.gov/ogwdw ).

8. See, e.g. NRDC, Think Before You Drink (1993); NRDC, Think Before You Drink: Urgent Release: 1992-1993 U pdate (1994); EWG & NRDC, Just Add Water (1996).

9. See, e.g. NRDC, USPIRG, and Clean Water Action, Trouble on Tap: Arsenic, Radon, and Trihalomethanes in Our Drinking Water (1995)

10. See, e.g., D.W. Warburton, "A Review of the Microbiological Quality of Bottled Water Sold in Canada, Part 2: Th e Need for More Stringent Standards and Regulations," Canadian J. of Microbiology , vol. 39, p. 162 (1993); H. Hernandez-Duquino, and F.A. Rosenberg, "Antibiotic-Resistant Pseudomonas in Bottled Drinking Water," Canadian J. of Microbiology , vol. 33, pp. 286-289 (1987); P.R. Hunter, "The Mi crobiology of Bottled Natural Mineral Waters," J. Applied Bacteriol. , vol. 74, pp. 345-352 (1993); see also, F.A. Rosen berg, "The Bacterial Flora of Bottled Waters and Po tential Problems Associated With the Presence of Antibiotic -Resistant Species," in Proceedings of the Bottled Water Workshop, September 13 and 14, 1990, A Report Prepared for th e Use of the Subcommittee on Oversight and Investig ations of the Committee on Energy and Commerce, U.S. House of Rep resentatives, Committee Print 101-X, 101st Cong., 2 d Sess. pp. 72-83 (December 1990).

11. See, e.g. , W. R. MacKenzie, et al., "A Massive Outbreak in M ilwaukee of Cryptosporidium Infection Transmitted Through the Public Water Supply," New Engl. J. of Med. vol. 331, no. 3, pp. 161-167 (July 21, 1994); Mari lyn Marchione, "Silent Disaster: Crypto Has Killed 104 -- And Coun ting," Milwaukee Journal , p. 1 (March 27, 1994).

12. Personal Communication with Terry Troxel and Sh ellee Davis, FDA, September 18, 1997; Personal Comm unication with Ron Roy, FDA, compliance programs, November 20 , 1998.

13. 21 C.F.R. § 165.110(a)(1).

14. 21 C.F.R. part 110 (1997).

15. 21 U.S.C. § 349(b)(3).

16. See 40 C.F.R.§ 141.63(b), prohibiting any confirmed fe cal coliform bacteria or E. Coli (i.e. confirmed wi th a repeat sample).

17. 21 C.F.R. § 165.110(b)(2).

18. 40 C.F.R. § 141.40.

19. Interview with Terry Troxel, FDA, September 18, 1997.

20. Ibid.; 60 Fed. Reg. 57076, at 57117 (November 1 3, 1995).

21. European Union, Council Directive of 15 July 19 80 on the Approximation of the Laws of the Member S tates Relating to the Exploitation and Marketing of Natural Minera l Waters, Article 5 § 1 (80/777/EEC: OJ No. L 229, 30.8. 1980 p. 1), as amended (available in consolidated text form at www.europa.eu.int );EU, Council Directive 98/83/EC of 3 November 1998 On The Quality of Water Intended for Human Consumpt ion [available at same web site].

22. Ibid. Directive 80/777/EEC Article 5 § 2.

23. Ibid. Article 7 § 2.



26. EU, Council Directive 98/83/EC, Supra ; The WHO provisional guideline for arsenic in drin king water for human consumption is 10 ppb. World Health Organization, Guidelines for Drinking Water Quality (2nd Edition, Geneva, 1993). The FDA standard for arsenic (and the EPA tap water standard, required to be updated in 2001), based o n an outdated 1942 U.S. Public Health Service guideline, is 50 pp b.

27. Constance Hayes, "Now, Liquid Gold Comes in Bot tles," New York Times , p. D4 (January 20, 1998).

28. IBWA, "What is IBWA?" available at www.bottledw ater.org/about.html (printed11/20/1998).

29. IBWA Model Code § 1(d)., available at www.bottl edwater.org/regs/indreg.html (printed 11/30/1998).

30. This troubling case arose in Massachusetts. Mas sachusetts state files reveal that the described we ll in Millis, Massachusetts for years supplied several bottlers, including Cumberland Farms, West Lynn Creamery, Gar elick Farms, and Spring Hill Dairy for sale as "spring water" un der many brand names. Massachusetts Department of P ublic Health, Ann & Hope Water Incident Files, 1993-1997; MDPH Me moranda Provided to NRDC Pursuant to Freedom of Inf ormation Request; Personal Communication with Dr. Liz Bourqu e, MDPH, August 1997.

31. According to State of Washington files, bottled water called "Alaska Premium Glacier Drinking Wate r: Pure Glacier Water From the Last Unpolluted Frontier, Bacteria F ree" actually was derived from"Public Water System #111241," apparently a public water system in (Juneau, Alaska ), according to the files. The bottler apparently w as told that when it reordered its labels, it had to state that the wate r is "from a municipal source" or "from a community water system" in accordance with FDA rules; the phrase "Pure Glacier Water" was, according to State files, "considered false and misleading." Also, the bottler was required to drop the "bacteria free" claim, as this was "considered synonymous with sterile and false." Washington State Department of Agriculture Food Establishment Inspection Report 4/ 17/97 and attachments; WSDA Food Establishment Inspection Rep ort 10/4/96 and attachments; WSDA Food Processor Li censing Worksheet and Attachments, and WSDA Food Establishm ent Inspection Report and Attachments, 3/20/96. Sta te officials report that the required label changes have been ma de after the intervention of FDA and state regulato rs. Personal communication with Shelly Haywood, USDA (January 19 99)

32. L. Allen & J.L. Darby, "Quality Control of Bott led and Vended Water in California: A Review and Co mparison of Tap Water," Journal of Environmental Health , Vol. 56, No. 8, p. 19 (April 1994), citing FDA; a ccord, "Bottled Water Regulation," Hearing Before the Subcommittee on Ove rsight and Investigation of the House Committee on Energy and Commerce, 102nd Cong., 1st Sess., p. 3, Serial No. 102-36 (April 10, 1991); accord, Ibid. at 152 (Statement of William F. Deal, CEO, International Bottled Water Association) . In a recent interview with the head of the FDA bo ttled water program, FDA confirmed that they have no reason to believe that this percentage has changed substantia lly since 1991. Interview with Terry Troxel, FDA, September 18, 199 7.

33. Memorandum, Dr. Karen Golden, FDA:CFSAN:OC:RCS, Regarding Discussion with Tyrone Wilson, Internati onal Bottled Water Association, Regarding Bottled Drinki ng Water (dated February 10, 1992)[FDA Docket 93N-0 200, Reference 2].

Chapter 2

EXPLODING SALES: MARKETING A PERCEPTION OF PURITY

Over half of all Americans (54 percent) drink bottl ed water, and about 36 percent of us imbibe regularly (more than once a week). [34] Sales have nearly tripled in the last decade, to about $4 billion in 1997, rising from 4.5 gallon s per year for the average American in 1986 to 12.7 gallons per year per person in 1997. [35] Americans consumed a total of 3.43 billion gallons of bottled water in 1997 (see Figur e 1). [36] Globally, the market was estimated in 1995 to be worth more than $14 billion annually in wholesale sales, and it has certainly grown since then. [37] According to a 1992 inventory, there were already 700 brands of bottled water produced by about 430 bottl ing facilities in the United States, [38] a number that likely has grown since that time, becau se of the enormous expansion in bottled water sales.

Enormous Growth in Sales of Bottled Water

The industry has more than recovered from adverse p ublic attention to problems with bottled water quality in 1990 and 1991. At that tim e benzene contamination was found in Perrier mineral water, causing a worldwide recall o f this bottled water in February 1990. Congressional hearings convened in 1991 by Michigan congressman John Dingell focused intense public scrutiny on bottled water qu ality issues in the wake of the Perrier incident, giving the industry a fleeting black eye. [39]

Since expunging these blotches on its image of puri ty, the industry has exploded, with the market now growing at a strong rate of 8 to 10 perc ent per year -- about twice as fast as the rate for other beverages. [40] According to industry stock analysts, "the profit margins in the business are really pretty good" -- for some bottlers in the neighborhood of 25 to 30 percent. [41] That means every $1.50 bottle of water brings arou nd $0.50 in profit. The actual cost of the water in the bottle purchased off a store shelf is gener ally just a fraction of a cent to a few cents. [42] Thus, typically 90 percent or more of the cost pai d by bottled water consumers goes to things other than the water itsel f -- bottling, packaging, shipping, marketing, retailing, other expenses, and profit. A s the then-chairman of the board of the Perrier Corporation stated in a remarkable moment o f candor, "It struck me . . .that all you had to do is take the water out of the ground and t hen sell it for more than the price of wine, milk, or, for that matter, oil." [43]

The bottled water industry's rapid growth is surpri sing in light of the retail price of bottled water: It costs from 240 to over 10,000 times more per gallon to purchase bottled water than it does to purchase a gallon of average tap wa ter. For example, in California average

tap water costs about $1.60 per thousand gallons (a bout one tenth of a cent per gallon), while it has been reported that average bottled wat er costs about $0.90 per gallon -- a 560-fold difference. [44] Expensive imported water sold in smaller bottles c an cost several thousand times more than tap water: That $1.50 half -liter bottle of imported water may be costing you 10,000 times more per gallon than your tap water.

While Americans with annual incomes of $60,000 per year or more are about 35 percent more likely than those of lesser means to buy bottl ed water, the purchasers of bottled water are hardly limited to high income yuppies. [45] As was put starkly in American Demographics recently,

Black, Asian, and Hispanic households are more like ly than whites to use bottled water, even though blacks and Hispanics as a group have lo wer-than-average household incomes . . . .Scares like the municipal water cont amination that occurred in Milwaukee in 1993 may have even low-income families springing fo r bottled water. It's clear that many households are still opting for bottled water, even though it can be an expensive habit. A five-year supply of bottled water at the recommende d intake of eight glasses a day can cost more than $1,000. An equivalent amount of tap water costs about $1.65. [46]

Heavy Marketing of the "Purity" of Bottled Water versus Tap Water

What has driven this ever-greater consumer demand f or bottled water? Market experts and public-opinion polls attribute the surprising incre ase primarily to several factors. People choose bottled water because it is perceived to be safer and of higher quality than tap water, and many are now using it because they view it as a healthful alternative beverage to soft drinks or alcohol.

The public is concerned about tap water safety and quality, and, with much encouragement from the bottled water industry's agg ressive marketing, views bottled water as a purer, safer option. As a key industry c onsultant put it, "water bottlers are selling a market perception that water is 'pure and good for you' . . . ." [47]

Just to be sure this public perception is carefully nurtured, the bottled water industry has engaged in an expensive public relations campaign t o persuade the public about the purity of bottled water and to disabuse the public of any "misconceptions about the cost, safety, quality and regulations governing bottled w ater." [48] The PR campaign has included media releases, briefings in at least 10 cities, di stribution of press kits, videos and video news releases. The campaign spent significant resou rces enlisting health groups as spokespeople, "educating" consumers and groups repr esenting populations likely to be at elevated risk from tap water, and seeking to reach others about the safety of bottled water. [49] Recent figures for the total bottled water industr y's advertising budget are difficult to come by, but as long ago as 1990 -- when the indust ry was selling much less water than it is today -- total media outlays for the bottled wat er industry were $42.9 million dollars. [50] That spending likely has increased substantially in the past nine years.

The industry-encouraged consumer thirst for bottled water as a safer, higher-quality source of drinking water was recently explained in a bottled water industry association trade magazine:

Consumers Want to Drink Water That's Safe. News reports about crises involving municipal water supplies in many parts of the count ry heightened public awareness and concern about the safety of tap water. Environmenta l groups and the Environmental Protection Agency sounded the safety alarm in sever al cities last year. As a result, consumers began to choose bottled water as a safe a lternative for drinking water. [51]

Many companies directly and openly market to consum ers by highlighting tap water contamination problems and offering their product a s a safer alternative. An ad campaign of the nation's second-largest water-bottling compa ny, McKesson Water Products Company (bottlers of Sparkletts, Alhambra, Aqua Ven d, and Crystal), for example, was cited in the advertising trade press as "right on" and highly effective because it took advantage of "consumers' concern over the purity of tap water . . . ." [52] McKesson was commended for running ads that "listed some of the contaminants in tap water, juxtaposing Sparkletts as 'the source of pure water .'" [53] Other bottlers have used EPA data indicating widespread tap water contamination with lead, [54] and much has been made by the industry of the vulnerability of tap water to Cryptosporidium and the purported complete protection of bottled water from this para site. [55]

One soft-drink-industry executive who has increasin gly turned to bottled water to boost revenue and "sells lots of Evian" explained to The New York Times recently how the bottled water market is helped by pollution concern s: "Water quality in the United States is getting progressively worse. Every time there's a w ater main break on 23rd Street and people have to boil water for a week, or there's pr oblems with the Ohio River, it clears out the supermarket shelves." [56]

In discussing the public's concern about tap water and how this opens up opportunities for bottlers, a recent article in the magazine of t he International Bottled Water Association (IBWA), the industry's trade association, explained :

Consumers are being bombarded with headlines warnin g about the potential risks of tap water, particularly water that may be contaminated with the parasite Cryptosporidium . . . . [N]ational media attention has been focused on the issue for several reasons. First, the Natural Resources Defense Council -- one of the cou ntry's most respected environmental groups -- warned consumers about the dangers of Cryptosporidium in municipal water supplies. Next, the Centers for Disease Control and Prevention (CDC) released guidelines for immuno-compromised people who are concerned abo ut the safety of their drinking water. Finally, the media has been extensively cove ring congressional activity on water safety.

Naturally all of this has resulted in increased con sumer awareness and concern about the safety of water . . . . The good news is that bottl ed water is a safe alternative. IBWA member companies produce safe, high-quality, strict ly regulated products. The challenge for the industry is one of communication: how can w e get the facts about bottled water to consumers? [57]

In response, the industry has made a major effort t o train its staff to "explain" why bottled water is safer than tap water and to place media st ories focusing on the high quality of bottled water. These representatives portray their products as entirely free of any contamination and free of risk from Cryptosporidium and any other contaminants. [58]

Bottled water industry advertising materials and "f act sheets" routinely state that bottled water is pure or entirely free of contaminants. A w idely circulated IBWA question-and-answer fact sheet for consumers is one typical exam ple:

How do I know that Cryptosporidium is not in my bot tled water? For starters, bottled water companies are required to use approved sources . . . .By law, [springs and wells] must be protected from surface intrusion and other environmental influences. This requirement ensures that surface w ater contaminants such as Cryptosporidium and Giardia are not present . . . . All IBWA member companies t hat use municipal supplies are encouraged to employ at leas t one of the three processing methods recommended by [CDC] for effective removal of microbial (surface water) contaminants, including Cryptosporidium.

Does bottled water contain any chlorine or harmful chemicals? No. [59]

As discussed in Chapter 3 and the accompanying Technical Report (print report only), these blanket reassurances of absolute purity of al l bottled water are incorrect. At least one sample of about a quarter of the bottled waters we tested violated strict state (California) health standards or warning levels, an d about one fifth of the waters exceeded unenforceable state or industry bacteria guidelines . Moreover, it is incorrect to assert that simply because water comes from a well or a spring it is immune from Cryptosporidium or other microbial contaminants of potential concern. Several waterborne-disease outbreaks -- including outbreaks of Cryptosporidium -induced illness -- have been caused by tap water taken from contaminated wells or springs. [60] There is no reason to believe that bottled water taken from springs, wells (or from ta p water or other sources, for that matter) is necessarily impervious to such contamination; on ly strong regulatory controls of water sources and strict treatment mandates (controls wel l beyond the weak federal bottled water rules) can ensure that no microbial contamina nts are present.

While it appears that many consumers who turn to bo ttled water do so out of concern about the safety of their tap water, some also have switched to bottled water because they are turned off by tap water's taste and odor (such as the pungent chlorine smell and taste) and simply prefer the taste and smell of bottled wa ter. In addition, Americans are choosing bottled water as what industry insiders call a "ref reshment beverage," because it is marketed and viewed as a light, clear, caffeine-, s alt-, and sweetener-free, and healthful alternative to soft drinks like Coke and Pepsi. [61]

In fact, a 1993 poll of people who drink bottled wa ter [62] found that 35 percent of bottled water drinkers used it primarily out of concern abo ut tap water quality. Another 12 percent chose bottled water because of both safety or healt h concerns and the desire for a substitute for other beverages (see Figure 2). Thus , as of 1993 at least, nearly half (47 percent) of bottled water drinkers used it at least partially out of concern for their health and safety. Another 35 percent drank it as a substi tute for soft drinks and other beverages. Seventeen percent said they chose bottled water for other reasons -- such as "taste" (7 percent) or "convenience."

It is absolutely clear, therefore, that a leading r eason for the explosion in bottled water sales is the public perception, fueled by heavy ind ustry advertising, that bottled water is pure and pristine, and thus a healthier choice than tap water.

Selling bottled tap water

What exactly are consumers getting for their money? Is the bottled water industry's carefully marketed image of absolute purity and pri stine sources an accurate reflection of where bottled water comes from, and is the water re ally so immaculately pure compared with tap water?

Government and industry estimates indicate that abo ut 25 percent to 30 percent of the bottled water sold in the United States comes from a city's or town's tap water -- sometimes further treated, sometimes not. [63] One IBWA expert reportedly estimated in 1992 that 40 percent of the bottled water was deriv ed from tap water. [64] The percentage of bottled water derived from tap water may be rising, because some major bottlers have begun to sell new brands of water derived from city tap water.

One extremely popular newly launched brand of bottl ed water is Pepsico's Aquafina® brand (which reportedly has taken Pepsi into the to p 10 sellers of bottled water in the United States, with sales jumping 126 percent in on e year to more than $52 million in 1997, according to the trade press). [65] Aquafina® bottles, which picture beautiful stylize d mountains on the label, do not mention that the wat er is derived from municipal tap water. The water reportedly is treated tap water taken fro m 11 different city and town water supplies across the nation. [66] Pepsi executives defend the practice. In a 1997 re port, "Pepsi spokesman Larry Jabbonsky made no apologies for the Aquafina label or advertising and said Pepsi isn't hiding anything. H e said anyone can find out the true source of Aquafina by calling the 800 number on the bottle top." [67] Coca-Cola, according to some accounts, is also very interested in the hi gh profit potential of entering the U.S. bottled water market and has carefully tracked Peps i's success with Aquafina. [68]

Other bottlers also use tap water as their source. For example, it has been reported that in south Texas, a brand of bottled water called Everes t, with mountains on the label, lists the source as the municipal water supply of Corpus Chri sti, which, as one report noted, "is hard by the Gulf of Mexico and nowhere near Everest or any other mountain." [69]

NRDC's testing found that some brands of bottled wa ter that claim to be spring water or that do not indicate that they are from a municipal source have likely been chlorinated -- a sign that they are likely derived from a municipal source, even though one of bottlers' key selling points is the lack of chlorine taste and od or in their product. For example, tests of two different samples of Safeway Spring Water, sold in California, chemically resembled tap water, in that it contained substantial levels of trihalomethanes -- common by-products of chlorine disinfection. [2a]

In addition, some cities recently have announced th at they plan to enter the bottled water market by selling their water untreated in bottles. [70] Houston, for instance, has announced that it will sell its self-proclaimed "Superior Wat er" -- city water taken straight from the tap and pumped into bottles. [71] Other cities including Kansas City and North Miami Beach are said to be evaluating plans to sell their water in bottles. [72]

Recent FDA rules now in force do require that if wa ter is taken from a municipal source and not treated further, the bottle label must indi cate that it is "from a municipal source" or "from a community water system." [73] However, if the water is treated using any of several common technologies (some of which could fa il to filter out certain contaminants, depending upon the treatment used), there is no req uirement to label its municipal source. [74] Apparently Pepsi is permitted to not mention on th e Aquafina® label that its water derives from municipal tap water, because it consid ers its water "purified water" under this exception. [2b]

Chapter Notes

2a. It is possible, albeit unlikely, that true spri ng water could have been chlorinated prior to bottl ing.

2b. No quantitative data are publicly available reg arding whether this practice is in widespread use b eyond the Aquafina® label. Moreover, due to the lack of state and FDA resources dedicated to monitoring the bott led water industry, the prevalence of the now unlawful practi ce of bottling untreated tap water from a public wa ter system without labeling its municipal water source is unknown.

Report Notes

34. "Uncapping Consumers’ Thirst for Bottled Water, " Bottled Water Reporter , p. 63 (December/January, 1994); Martha Hamilton, Washington Post , "Liquid Assets, Pure and Simple," September 14, 1 996 p. D1.

35. Beverage Marketing Association, 1998 data cited in "Advertising & Marketing:Waterlogged," Los Angeles Times , p. D5 (April 23, 1998); Tim Madigan, Fort Worth Star-Telegram , August 24, 1997, p. 1.

36. Beverage Marketing Association, 1998 data cited in "Advertising & Marketing:Waterlogged," Los Angeles Times , p. D5 (April 23, 1998).

37. Timothy & Maureen Green, "Bottled Water Goes Gl obal," Bottled Water Reporter , p. 48, (June/July 1995).

38. Business Trend Analysis, Inc., The Bottled Water Market: Past Performance, Current Trends, and Strategies for the Future: A Business Information Report , p. 1 (1992).

39. See, "Bottled Water Regulation," Hearing of the Subcom mittee on Oversight and Investigations of the House Committee on Energy and Commerce, Serial No. 102-36 , 102nd Cong., 1st Sess. (April 10, 1991).

40. In 1997, there was a 9.6 percent increase in bo ttled water sales over 1996, for example, according to Beverage Marketing Association 1998 data cited in "Advertisi ng & Marketing:Waterlogged," Los Angeles Times , p. D5 (April 23, 1998); see also , Harry Berkowitz, "Wading in Water: As Sales Soar, Bottlers Try to Distinguish Their Products," Newsday , p. 1 (August 31, 1997).

41. Ibid. , quoting Casey Alexander, securities analyst at Gi lford Securities.

42. According to an industry consulting company: "I f the bottler installs the equipment the price per gallon may be as low as 0.0125 cents per gallon. If the property ins talls the equipment the price range, depending on v olume and market proximity, is 0.02 to 0.06 cents per gallon. The pr oximity of the source to the bottling facility has a significant fiscal impact on the raw product costs. According to Mike Cullis formerly of Hidell-Eyster Technical Services , Inc., ‘Total operating costs of a dedicated tanker is $1.10 per mile. Therefore the difference between a source 100 miles and a source 200 miles from the bottling plant translates to $220 per load or a laid in cost of 0.04 cents p er gallon’." "The higher the volume, the lower the cost per gallon. F illing a 5,000 gallon tanker truck per week from a supplier with his own pumping equipment can cost 0.05 cents per gallon. I f the volume increases the cost drops considerably. According to Roy Christensen of Black Mountain Spring Water some of the biggest cost of raw water is negotiating th e contract. Besides owning their own sources, Black Mountain ha s leases and agreements with spring water property owners.

‘Entrepreneurs have developed spring sources in our area and there are now more sources available than ever before,’ said Christensen. The price per gallon in Northern California has remained consistent over the past fe w years because, unlike fossil fuels, spring sources are not a dimin ishing resource, even with increasing demand. "Road access is a primary problem along with water quality. Lower tot al dissolved solids (tds) is most desirable for spr ing bottlers but the threshold of acceptability varies from State to Sta te. A source in the Western U.S. may have upwards o f 150 parts per million (ppm) tds [total dissolved solids] and be a cceptable, while in the Northeast bottlers prefer 1 00 or less tds. "The Perrier Group developed a pumping station at a Boys Scout Camp south of Waco, Texas for their Oasis an d Ozarka brands. The cost of the pumping station was approxi mately $300,000 which Perrier supplied. Today Perri er pays an annual fee of $25,000 to draw the water from the so urce and average 10,000 gallons per day. "Bill Egan , owner of Mountainwood Springs in Blairstown, New Jersey, bou ght property with a large 5-6 million gallon per da y spring, twelve years ago. He built a stainless steel pumping facil ity and developed a bulk water business selling wat er to bottlers like Great Bear, Cumberland Farms and General Foods. "It is very competitive,’ said Egan. ‘A lot of people think that if you get a spring you'll be an instant millionaire. They don't do their homework. There are not a lot of bi g users for bulk water," Egan said. He tests his water every hour an d it is certified by the National Sanitation Founda tion. In the summer season Egan says he fills over ten 6200 gallon tank er trucks per day, each one taking about 45 minutes to load. "The raw spring water supplier is often tempted to enter the business himself and build a bottling facility. Ul timately this may undermine the relationship with other bottlers who he supplies to, as they compete for supermarket she lf space and route sales. Being a bulk water supplier is not as capital intensive as becoming a bottler and still h as a lot of appeal. As Bill Egan said, ‘The business is glamorous. Water i s a topic of conversation." "What is water worth? T oday water is sold from spring owners to bottlers from a few pennies t o almost 10 cents a gallon." THE BOTTLED WATER WEB, © 1997 Best Cellar Communications, www.bottledwaterweb.com/indus.html .

43. Gustave Leven, Chairman of the Board, The Perri er Corporation of France, quoted in P. Betts, "Bubbling Over in a Healthy Market," The Financial Times , January 13, 1988.

44. L. Allen and J.L. Darby, "Quality Control of Bo ttled and Vended Water in California: A Review and Comparison to Tap Water," Journal of Environmental Health , vol. 56, no. 8, pp. 17-22 (April 1994).

45. Marcia Mogelonsky, "Water Off the Shelf," American Demographics , p. 26 (April 1997)

46. Ibid.

47. Henry R. Hidell III, "Water: The Search for a G lobal Balance," Bottled Water Reporter , p. 53 (June/July 1995),(emphasis added).

48. See, e.g., "Bottled Water Campaign Focuses on Q uality Issues," Bottled Water Reporter , p. 52 (April/May 1995); "A Flood of Good News for Bottled Water: The Beverage For Life Campaign: A (Media) Year in Review, Bottled Water Reporter , p. 73 (October/November 1994)

49. "Bottled Water: The ‘Beverage for Life’ Campaig n," Bottled Water Reporter , p. 86 (February/March 1995); Sylvia Swanson, "IBWA In the Forefront," Bottled Water Reporter , p. 30 (December/January 1996).

50. Business Trend Analysis, Inc., The Bottled Water Market: Past Performance, Current Trends, and Strategies for the Future: A Business Information Report , p. 84 (1992).

51. "Uncapping Consumers’ Thirst for Bottled Water, " Bottled Water Reporter , p. 63 (December/January, 1994).

52. Marcy Magiera, "Bottled Water: Sales Jump as Pu blic Trust [of Tap Water] Drops," Advertising Age (February 7, 1994), excerpted in Greenwire, American Political N etwork, February 9, 1994.

53. Ibid.

54. As one typical example, advertising materials f or Nicolet "Natural Artesian Water" cite as one rat ionale for purchasing Nicolet water the fact that "US EPA rece ntly stated that as many as 42 million Americans ma y be consuming tapwater tainted with unacceptable lead concentrati ons from lead soldered joints in water mains and pl umbing systems." (www.nicoletwater.com/source/source.html [8/12/1997 ]).

55. International Bottled Water Association, "Frequ ently Asked Questions About Bottled Water," (availa ble at www.bottledwater.org/faq.html), (printed 11/20/1998 ).

56. Bruce Llewellyn, Chairman and CEO of Philadelph ia Coca Cola Bottling Company, quoted by Constance Hayes, "Now, Liquid Gold Comes in Bottles," New York Times , p. D4 (January 20, 1998).

57. Jennifer Levine, "Why Crytosporidium? Why Now? Information on Responding to Consumers’ Questions" Bottled Water Reporter , pp. 16-17 (August/September 1995).

58. See, ibid ; International Bottled Water Association, "Frequen tly Asked Questions About Bottled Water," (availabl e at www.bottledwater.org/faq.html), (printed 11/20/1998 )

59. International Bottled Water Association, "Frequ ently Asked Questions About Bottled Water," (availa ble at www.bottledwater.org/faq.html), (printed 11/20/1998 ), (emphasis added).

60. See, M.H. Kramer, et al. , "Surveillance for Waterborne-Disease Outbreaks--U nited States, 1993-1994," In: Centers for Disease Control & Prevention Surveillance Summaries , Morbidity and Mortality Weekly Report , vol. 45, no. SS-1, pp. 1-31 (April 12, 1996); B.L. Herwart, et al., "Outbreaks of Waterborne Disease in the U.S.: 1989-90," Journal of the American Water Works Association , p. 129 (April 1992); W.C. Levine, W.T. Stephenson , and G. Craun, "Waterborne Disease Outbreaks, 1986-1988," Mortality and Morbidity Weekly Report vol. 39, no. SS-1 (March 1990; NRDC, The Dirty Little Secret About Our Drinking Water (1995).

61. "Uncapping Consumers’ Thirst for Bottled Water, " Bottled Water Reporter , p. 63 (December/January, 1994).

62. American Water Works Association Research Found ation, "Consumer Attitude Survey," pp. 19-20 (1993) .

63. L. Allen & J.L. Darby, "Quality Control of Bott led and Vended Water in California: A Review and Co mparison of Tap Water," Journal of Environmental Health , vol. 56, no. 8, p. 19 (April 1994), citing FDA; accord , "Bottled Water Regulation," Hearing Before the Subcommittee on Oversight and In vestigation of the House Committee on Energy and Co mmerce , Serial No. 102-36 102nd Cong., 1st Sess., p. 3, (Ap ril 10, 1991); accord, Ibid. p. 152 (Statement of William F. Deal, CEO, International Bottled Water Association). In a rece nt interview with the head of the FDA bottled water program, FDA confirmed that they have no reason to believe that this percentage has changed substantially since 199 1. Interview with Terry Troxel, FDA, September 18, 1997.

64. Memorandum, Dr. Karen Golden, FDA:CFSAN:OC:RCS, Regarding Discussion with Tyrone Wilson, Internati onal Bottled Water Association, Regarding Bottled Drinki ng Water (dated February 10, 1992)[FDA Docket 93N-0 200, Reference 2].

65. G.W. Prince, "What it Tables," Beverage World, p. 46 (April 15, 1998).

66. See, K. Benezra, "Pepsi to Herald Aquafina as P opulist Alternative to Pricey Waters," Brandweek (June 2, 1997); B. Mohl and P. Wen, "Mountain on Water's Label is Just a Mirage," The Boston Globe , p. B2; (October 19, 1997); H. Berkowitz, "Wading in Water: As Sales Soar, Bottler s Try to Distinguish Their Products," Newsday (August 31, 1997); Mark Tran, "Demi Moore Creates a Fizz; Pepsi Dives Into Growth Market in Effort to Swamp French Brands ," The Guardian (London) , p. 20 (June 27, 1997); "1996 Alternative Beverage s: Still Water Supply Up Sharply, Perrier, Coke, Pepsi, and Suntory Gain Share," Beverage Digest (April 25, 1997), (www.beverage-digest.com/970425. html), (printed 9/25/1997).

67. B. Mohl and P. Wen, "Mountain on Water's Label is Just a Mirage," The Boston Globe , p. B2; (October 19, 1997).

68. Coke already sells its brand "Bon Aqua®"® in 30 countries overseas, but not in the United States. Constance Hayes, "Now, Liquid Gold Comes in Bottles," New York Times , p. D4 (January 20, 1998).

69. S.H. Verhovek, " It's Wet. It's Bottled. It Sor t of Tastes Like Water.," The New York Times , p. D2 (August 10, 1997).

70. Ibid.

71. Julie Mason, "A Big Splash? Bottled City Water Soon May be Available in Stores," The Houston Chronicle p. 1 (July 10, 1997); D. Usborne, "Oil Town Finds an New Sourc e of Wealth on Tap," The Independent p. 10 (August 7, 1997); "No Frills Water," The Christian Science Monitor p. 20 (September 3, 1997), (editorial).

72. Ibid; S.H. Verhovek, " It's Wet. It's Bottled. It Sort of Tastes Like Water.," The New York Times , p.D2 (August 10, 1997).

73. 21 C.F.R. section 165.110(a)(3)(ii).

74. Ibid.

Chapter 3

BOTTLED WATER CONTAMINATION: AN OVERVIEW OF NRDC'S AND OTHERS' SURVEYS

Setting aside the question of whether bottled water is as pure as advertised, is the public’s view that bottled water is safer than tap water cor rect? Certainly the aggressive marketing by the bottled water industry would lead us to beli eve so.

NRDC undertook a four-year, detailed investigation to evaluate the quality of bottled water. We reviewed published and unpublished literature an d data sources, wrote to and interviewed by phone all 50 states asking for any s urveys of bottled water quality they have conducted or were aware of, and interviewed ex perts from FDA. In addition, through three leading independent laboratories, we conducte d "snapshot" testing of more than 1,000 bottles of water sold under 103 brand names.

What NRDC has found is in some cases reassuring and in others genuinely troubling. The results of all testing NRDC conducted is presented in Appendix A; Figure 4 summarizes the results.

The bottled water industry generally has publicly m aintained that there are no chemical contaminants in bottled water. For example, as note d in Chapter 2, a widely disseminated fact sheet on bottled water distributed by the Inte rnational Bottled Water Association (IBWA) -- the industry’s trade association -- state s flatly that bottled water contains no chlorine or harmful chemicals. [75]

However, our investigation has found that potential ly harmful chemical contaminants are indeed sometimes found in some brands of bottled wa ter. (The box at the end of this chapter highlights a particularly troubling example .) NRDC’s testing of more than 1,000 bottles of water (for about half of FDA-regulated c ontaminants; see the Technical Report [print report only]), found that at least one sampl e of 26 of the 103 bottled water brands tested (25 percent) contained chemical contaminants at levels above the strict, health-protective limits of California, the bottled water industry code, or other states [3a] (23 waters, or 22 percent, had at least one sample that violate d enforceable state limits). We found only two waters that violated the weaker federal bo ttled water standards for chemicals (in two repeat samples), and two waters that violated t he federal standards for coliform bacteria in one test (though another batch of both of those waters tested clean for bacteria). The Technical Report (print report only) also discusses evidence provid ed by other investigators who in the past found that chem ical contaminants were found in bottled water at levels violating the federal bottl ed water standards. [76]

Thus, in our limited bottled water testing, while s trict health-protective state limits for chemicals sometimes were not met by about one fourt h of the waters, the weaker federal bottled water standards generally were not violated . As noted in Table 2, among the

chemical contaminants of greatest potential concern in bottled water are volatile organic chemicals, arsenic, certain other inorganic chemica ls, and plastic or plasticizing compounds. Although most bottled water contained no detectable levels of these contaminants, or contained levels of the contaminan ts lower than those found in many major cities’ tap water, we determined that one can not assume on faith, simply because one is buying water in a bottle, that the water is of any higher chemical quality than tap water.

TABLE 2 Selected Contaminants of Potential Concern for Bottled Water

Contaminant Health Concern with Excess Levels

Coliform Bacteria Broad class of bacteria used as potential indicator of fecal contamination; may be harmless of themselves. Harmful types of coliform bacteria (such as certain fecal coliform bacteria or E. coli) can cause infections with vomiting, diarrhea, or serious illness in children, the elderly, and immunocompromised or other vulnerable people.

Heterotrophic Plate Count (HPC) Bacteria

Potential indicator of overall sanitation in bottling and source water; may be harmless of themselves. In some cases may indicate presence of infectious bacteria; data show sometimes linked to illnesses. Can interfere with detection of coliform bacteria or infectious bacteria. Unregulated by FDA.

Pseudomonas aeruginosa bacteria Possible indicator of fecal contamination or unsanitary source water or bottling. Can cause opportunistic infections. Unregulated by FDA.

Arsenic Known human carcinogen. Also can cause skin, nervous, and reproductive or developmental problems.

Nitrate Causes "blue baby" syndrome in infants, due to interference with blood's ability to take up oxygen. Potential cancer risk.

Trihalomethanes (i.e., chloroform, bromodichloromethane, dibromochloromethane, and bromoform)

Cancer of the bladder, colorectal cancer, possibly pancreatic cancer. Also concerns about possible birth defects and spontaneous abortions.

Phthalate (DEHP) Cancer; possible endocrine system disrupter. Unregulated by FDA.

Source: NRDC

NRDC Testing Methodology

NRDC began during the summer of 1997 to test bottle d water quality and continued testing or retesting some brands through early 1999. Our te sting methodology is summarized in Table 3, and described in greater detail in the accompanyi ng Technical Report (print report

only). We conducted a four-pronged testing program, using three of the nation's most respected laboratories: two major independent comme rcial labs and one academic laboratory. In this four-pronged testing program, w e tested water sold in the five states with the highest bottled water consumption in 1994 (California, Florida, Illinois, New York, and Texas), plus bottled water sold in the District of Columbia. [77] We tried to test major brands that held a significant percentage of the na tional or regional market share (for those brands for which market-share information was available), and we strove to purchase a variety of other brands and types of wat er, including the major bottled water products offered by some of the leading supermarket chains in the areas where the water was purchased.

The first prong of our survey was a preliminary scr eening of 37 California bottled waters in the summer and fall of 1997. The second involved de tailed testing of 73 California waters in late 1997 and early 1998. The third was a survey of five bottled waters from each of five states other than California (a total of 25 waters) in late 1997 and early 1998. The final prong involved retesting more than 20 in which cont amination had been found in earlier tests, which took place in mid- to late-1998 and ea rly 1999.

We sampled the most waters from California, whose r esidents are by far the greatest consumers of bottled water in the nation. More bott led water is purchased in California than in the next five largest consuming states comb ined (see Figure 3 ). California generally has the most stringent standards and warn ing levels applicable to bottled water in the nation.

All of the labs we contracted with used standard EP A analytical methods for testing water. We conducted "snapshot" testing -- that is, we purc hased several bottles of a single type of water, at a single location, and had those bottl es tested. If we found a problem, we generally repurchased and then retested the water t o confirm the earlier results. [78] Our testing methodology is summarized in Table 3, and d escribed in greater detail in the accompanying Technical Report (print report only).

We asked the labs to use their standard contaminant test packages in order to control the total testing costs. In general, this meant that th e labs tested for many of the most commonly found regulated contaminants, plus certain other contaminants that they could readily detect and quantify using the standard EPA methods and the analytical equipment they routinely use. Thus, some labs were able to de tect more contaminants than others, though all tested for a core set of more than 30 re gulated contaminants.

TABLE 3: Summary of Lab Testing Protocols

Lab # of Brands of Water Tested

Number of Contaminants Tested

General Testing Protocol Comments

Environmental Quality Institute (Univ. N.C.)

37 41 regulated, over 40 unregulated

EPA analytical methods, single bottle sampled per contaminant type

Initial screening of California waters to determine whether more in-depth

testing needed.

Sequoia Analytical

73 32 regulated, over 40 unregulated

EPA analytical methods, FDA protocol for sampling (test 1 composite sample of 10 bottles for chemical and microbial contaminants; 10 individual bottles tested for microbial follow-up if excess bacteria found in first round)

More extensive testing of California waters only.

National testing 25 57 regulated, over 200 unregulated

EPA analytical methods, FDA protocol for sampling (test 1 composite sample of 10 bottles; 10 individual bottles of all tested for bacteria)

Testing of waters from 5 states outside of California (NY, FL, TX, IL, and DC).

Summary of Results of NRDC Testing

NRDC testing: the good news

First, the good news: Most brands of bottled water we tested were, according to our "snapshot" analyses of a subset of regulated contam inants, of relatively good quality (i.e., they were comparable to good tap water). Most water s contained no detectable bacteria, and the levels of synthetic organic chemicals and i norganic chemicals of concern for which we tested were either below detection limits or well below all applicable standards.

Caveats. This is not to say that all of these brand s are without risk. One of the key limitations of the testing is that most tests were done just once or twice, so we could have missed a significant but intermittent problem. Nume rous studies of source-water quality -- particularly surface-water sources and shallow grou ndwater sources -- demonstrate that source-water quality may substantially vary over ti me. [79] Operation, maintenance, or other mishaps at a bottling plant may cause periodic wate r-contamination problems that would not be detected by such "snapshot" tests. Thus, dep ending upon the bottler's source water, treatment technology (if any), and manufactu ring, operation, and maintenance practices, some bottled waters' quality may vary su bstantially with time and with different production runs.

In addition, while we did test for dozens of contam inants at a cost of from about $400 to about $1,000 per type of water per round of testing (depending on the intensity of the testing), we were unable to test for many contamina nts that may be of health concern. Thus, as is discussed in the accompanying Technical Report (print report only), we were unable to test for many kinds of bacteria, parasite s, radioactivity, and toxic chemicals regulated by EPA and FDA in tap water or bottled wa ter because such testing would have been even more expensive or difficult. Still, with those caveats, many bottled waters do appear to be of good quality, based on our limited testing.

NRDC testing: the bad news

For some other bottled waters, the story is quite d ifferent. The independent labs that conducted testing for NRDC found high levels of het erotrophic-plate-count bacteria in some samples, and in a few cases coliform bacteria (no coliforms were found in retests of different lots of the same water). The labs also fo und that some samples contained arsenic (a carcinogen) and synthetic organic chemicals (SOC s, i.e., man-made chemicals containing hydrogen and carbon), such as those cont ained in gasoline or used in industry. SOCs found included the probable human carcinogen p hthalate (likely from the plastic water bottles), and trihalomethanes (cancer-causing by-products of water chlorination, which have been associated with birth defects and s pontaneous abortions when found in tap water at high levels). [3b]

A detailed review of all our testing results and th ose of other investigators is presented in the accompanying Technical Report (print report only), and the actual results for ea ch brand of bottled water we tested are presented in A ppendix A. In summary, our testing of 103 types of water found:

• Violations of state standards. At least one sample of about one fourth of the bottled waters bought in California (23 waters, or 22 percent) violated enforceable state limits (either bottled water standards or man datory warning levels).

• Violations of federal bottled water quality standa rds (coliform bacteria and fluoride). Based on limited testing, four waters vi olated the weak federal bottled water standards (two for coliform bacteria that on retest contained no coliforms, and two for fluoride that were confirmed on retest to contain excessive fluoride). Coliform bacteria in water may not be dangerous the mselves, but they are widely used as an indicator that may signal the presence o f other bacteria or pathogens that could cause illness. Fluoride at excessive lev els can cause mottling or dental fluorosis (pitting of teeth), skeletal fluorosis (a dverse effects on bones), and cardiovascular and certain other health effects. [80]

• Arsenic contamination. Arsenic is a "known human c arcinogen" when in drinking water; it also can cause many other illnesses, incl uding skin lesions, nervous-system problems, and adverse reproductive and cardi ovascular effects (the precise levels in drinking water necessary to cause these effects are the subject of heated debate). [81] Our testing found that one or more samples of eigh t waters (8 percent) purchased in California exceeded the 5 ppb warning level for arsenic set under California's Proposition 65, a law requiring public warnings if a company exposes people to excessive levels of toxic chemica ls. [3c] (See Figure 5. )

• Trihalomethane violations. Trihalomethanes (THMs) are a family of chemicals created when chlorine is used to disinfect water (c hlorine reacts with organic matter in the water to form THMs and other byproduc ts). Studies of people and animals exposed to THMs in their tap water have fou nd elevated risks of cancer [82] and potentially a higher risk of spontaneous aborti ons and birth defects. [83] California has adopted a 10 ppb total THM limit, a standard recommended by the International Bottled Water Association (IBWA), the bottled water industry trade association. Twelve waters (12 percent) purchased i n California had at least one sample that violated the state and IBWA bottled wat er standard for THMs in the

same fashion. (See Figure 6 .) Two waters sold in Florida exceeded the IBWA standard (Florida repealed its 10 ppb TTHM standard in 1997), and one sold in Texas violated the IBWA standard (Texas has not mad e the stricter 10 ppb standard enforceable). Chlorinated tap water also t ypically contains THMs (generally at levels above 10 ppb if the water is c hlorinated), though many people who buy bottled water to avoid chlorine and its tas te, odor, and by-products may be surprised to learn THMs are sometimes found in b ottled water as well.

• Excessive chloroform Chloroform is the most common THM found in tap and bottled water; it is of particular concern because it is listed by EPA as a probable human carcinogen. Twelve waters purchased in Califo rnia had at least one sample that exceeded the warning level for chloroform (a t rihalomethane) set by California under Proposition 65, but they were sold without th e required health warning (see Appendix A).

• Excessive bromodichloromethane (BDCM). BDCM is ano ther THM that EPA has listed as a probable human carcinogen. Ten waters w e bought in California that contained unlawful TTHM levels also had at least on e sample that exceeded the Proposition 65 warning level for bromodichlorometha ne. These waters all were sold with no health warning that they contained BDC M at a level above the Proposition 65 level.

• Excessive heterotrophic-plate-count (HPC) bacteria . HPC bacteria are a measure of the level of general bacterial contamination in wat er. HPC bacteria are not necessarily harmful themselves, but they can indica te the presence of dangerous bacteria or other pathogens and are used as a gener al indication of whether sanitary practices were used by the bottler. Nearly one in five waters tested (18 waters, or 17 percent) had at least one sample that exceeded the unenforceable microbiological-purity "guidelines" adopted by some states for HPC bacteria (500 colony-forming units, or cfu, per milliliter). (See Figure 7 .) These states use unenforceable HPC-bacteria "guidelines" to measure bacterial contamination and sanitation. These state guidelines actually are wea ker than voluntary HPC guidelines used by the industry trade association t o check plant sanitation. (200 cfu/ml in 90 percent of samples taken five days aft er bottling), and are weaker than the European Union (EU) standard (100 cfu/ml, at bo ttling at 22 degrees Celsius).

• Elevated nitrates, but at levels below standards. Nitrates can be present in water as a result of runoff from fertilized fields or lawns, or from sewage; nitrates also may occur naturally, generally at lower levels. At elev ated levels, nitrates can cause blue-baby syndrome -- a condition in infants in whi ch the blood has diminished ability to take up oxygen, potentially causing brai n damage or death; according to some, nitrates may be linked to cancer in adults. [84] The EPA and FDA standard for nitrates is 10 parts per million (ppm). There is sp irited debate about whether these standards are sufficient to protect all infants in light of some studies suggesting ill effects at lower levels, [85] but both EPA and the National Research Council mai ntain that the current standard is adequate to protect he alth. [86] We found six bottled waters that had at least one sample containing more than 2 ppm nitrates; four of these had at least one sample containing more than 3 ppm nitrates (two contained up to 5.6 ppm nitrates in at least one test). (See Table 4.) Four of the six waters containing higher nitrate levels were mineral water s. The U.S. Geological Survey says that nitrate levels in excess of 3 ppm may ind icate human-caused nitrate

contamination of the water, [87] although it may be that some mineral waters naturally contain higher nitrate levels. To be safe , babies probably should not be fed with mineral water containing elevated nitrate levels.

TABLE 4 Selected Nitrate Levels Found in Bottled Waters

Bottled Water Brand

Nitrate Level (as Nitrogen, in ppm) (First Test)

Nitrate Level (as Nitrogen, in ppm) (Subsequent Tests, If Any)

Fiuggi Natural Mineral Water 2.5

Hildon Carbonated Mineral Water 5.6 5.4

Hildon Still Mineral Water 5.6

Perrier Sparkling Mineral Water 2.8, 2.6 4.3, 4.1

Sahara Mountain Spring Water 2.5

Sparkling Springs 3.1

Source: NRDC, 1997-1999

• No fecal coliform bacteria or Pseudomonas aeruginosa. Although, as noted previously, we did find total coliform bacteria in a few samples, no fecal coliform bacteria or E. coli bacteria were found. Earlier studies have found mu ltiple species of the bacteria Pseudomonas in bottled water. [88] However, in an effort to control costs, we looked only for the species Pseudomonas aeruginosa and found none.

• Synthetic organic chemicals at levels below enforc eable standards. About 16 percent of the waters (16 of 103) had at least one sample that contained human-made synthetic organic chemicals (SOCs) at levels b elow state and federal standards. The most frequently found SOCs were indu strial chemicals (e.g., toluene, xylene, and isopropyltoluene), and chemica ls used in manufacturing plastic (e.g., phthalate, adipate, and styrene). As discussed in the accompanying Technical Report (print report only), some of the chemicals found ( such as phthalate) may pose health risks such as potential cancer-causing effects, even if present at relatively low levels. Generally, long-t erm consumption (over many years) is required to pose such chronic risks. The levels of these contaminants found in our testing are indicated in Table 5.

• Overall contamination findings Overall, at least o ne sample of about one third of the tested waters (34 waters, or 33 percent) contai ned significant contamination (i.e., contaminants were found at levels in excess of standards or guidelines). This

is not simply the sum of the waters that violate en forceable standards plus those that exceeded guidelines, as some waters violated b oth.

• The detailed results of our testing for each type of water are presented in the Technical Report (print report only). As is discussed there, testin g by states and by academic researchers have also sometimes found the contaminants we studied or other potentially toxic and infectious agents in so me brands of bottled water.

TABLE 5 Selected Synthetic Organic Compounds (Other Than THMs) in Bottled Water

Bottled Water (& State of Purchase)

Xylene Level (ppb)

Toluene Level (ppb)

Other VOCs Found (in ppb)

Comments

Alhambra Crystal Fresh Drinking Water (CA)

2.7 (test 1) 0 (test 2)

12.5 (test 1) Not Detected (test 2)

Not Detected (tests 1 & 2)

Xylene and toluene below FDA & CA standards, but presence could indicate treatment standard violation.

Black Mountain Spring Water (CA)

Not Detected (tests 1-3)

8.9 (test 1) Not Detected (tests 2 & 3)


Toluene below FDA and CA standards, but presence could indicate treatment standard violation.

Lady Lee Drinking Water (Lucky, CA)


11.0 (test 1) 0.5 (test 2)


Xylene and toluene below FDA & CA standards, but presence could indicate treatment standard violation.

Lady Lee Natural Spring Water (Lucky, CA)

3.0 (test 1) Not Detected (test 2) 0 (test 3)

13.9 (test 1) Not Detected (test 2) 0.5 (test 3)


Xylene and toluene below FDA & CA standards, but could indicate CA treatment standard violation.

Lady Lee Purified Water (Lucky, CA)



Ethylbenzene 2.0 ppb (test 1) Ethylbenzene not detected (test 2) Ethylbenzene not detected (test 3) Methylene Chloride 4.1 ppb (test 3)

Xylene, toluene, methylene chloride, and ethylbenzene below FDA & CA standards, but could indicate CA treatment standard violation. Methylene chloride standard is 5 ppb.

Lucky Sparkling Not Not p-isopropyltoluene Single test; no standard for

Water (w/raspberry)(CA)

Detected Detected 5.4 ppb p-isopropyltoluene.

Lucky Seltzer Water (CA)


Not Detected (test 1) 1.8 (test 2)

n-isopropyltoluene at 230 ppb (test 2) n-butylbenzene at 21 ppb (test 2) Neither detected in test 1

Source of elevated level of n-isopropyltoluene and of n-butylbenzene contamination unknown; no standards apply.

Dannon Natural Spring Water (NY)



Methylene chloride at 1.5 ppb (test 3) Methylene chloride not detected in tests 1 & 2

FDA's Methylene chloride (dichlormethane) standard is 5 ppb.

Nursery Water (CA) 3.2 (test 1) Not Detected (test 2)

12.4 (test 1) 0.6 (test 2)

Styrene 3.0 (test 1) Not Detected (test 2)

Xylene, toluene, and styrene below FDA & CA standards, but could indicate CA treatment standards violation.

Perrier Mineral Water (CA)



2-Chlorotoluene 4.6 ppb (test 1) 2-Chlorotoluene 3.7 ppb (test 2) 2-Chlorotoluene Not Detected (test 3)

No standard for 2-chlorotoluene; contamination from unknown source.

Polar Spring Water (DC)

Not Detected

2.5 Not Detected Toluene detected at level below FDA standard (single test).

Publix Drinking Water (FL)



Acetone 11 ppb (test 1) Acetone 14 ppb (test 2) Acetone 16 ppb (test 3) Styrene 0.6 ppb (test 1) (No styrene found tests 2-3)

Styrene found at level well below EPA Health Advisory level; no standard or Health Advisory for acetone.

Publix Purified Water (FL)

Not Detected

Not Detected

Styrene 0.2 ppb Styrene found at level well below EPA Health Advisory level (single test).

Safeway Purified Water (CA)



Toluene detected at level below FDA and state standard, but could indicate CAtreatment standard violation.

Safeway Spring Water (CA)

3.1 (test 1) Not Detected

14.2 (test 1) Not

Xylene and toluene below FDA & CA standards, but could indicate CAtreatment standard

(test 2) Detected (test 2)

violation.

Safeway Spring Water (DC)

Not Detected

4.7 Single test, toluene below FDA standard.

Source: NRDC 1997-1999

Other Surveys of U.S. Bottled Water Quality

Relatively little information about bottled water q uality is readily available to consumers. Few surveys of bottled water quality have been cond ucted in the United States during the past four years, and fewer still are widely availab le.

A handful of state governments have done surveys in recent years. Kansas has done a small survey of certain waters sold in the state, [89] Massachusetts prepares an annual summary of industry testing of waters sold in that state, [90] and New Jersey issues an annual summary, primarily of industry testing of wa ter sold there. [91] In addition, Pennsylvania periodically issues a small state surv ey of waters sold locally, [92] and Wisconsin issues a small annual testing of about a dozen state waters. [93] In general, these states have reached conclusions similar to those we have reached: that most bottled water is of good quality but that a minority of the bottled water tested contains contaminants such as nitrates or synthetic organic chemicals, in a few cases at levels of potential health concern. These surveys are summari zed in detail in the Technical Report (print report only).

A few academicians have published papers focusing o n bottled water contamination from specific types of contaminants. For example, academ ic studies have focused on Pseudomonas bacteria in various brands of bottled water, [94] the leaching of chemicals from plastic manufacturing (such as phthalates) [95] from plastic bottles into the water, or contamination of bottled water with certain volatil e synthetic organic compounds. [96] The researchers often tested only a relatively small nu mber of brands of water, or failed even to name which bottled water was tested, making the information of limited value to consumers seeking to select a brand of water that i s uncontaminated. Comprehensive studies of Canadian bottled waters also have been p ublished -- without naming the brands with problems. The results of many of these studies are in the Technical Report (print report only), which presents in greater detail the evidence of microbiological and chemical contamination of bottled water.

Potential for Disease from Bottled Water

As is discussed in the accompanying Technical Report (print report only), there is no active surveillance for waterborne disease from tap water in the United States, nor is there active surveillance of potential disease from bottl ed water. There are certain "reportable" diseases, such as measles, which are reportable to CDC and state health departments, and for which there is active surveillance. Most di seases caused by organisms that have been found in bottled water, however, are not repor table, and in any event may come from a variety of sources, so the amount of disease from microbiologically contaminated

bottled water (or tap water) is unknown. Thus, sinc e no one is conducting active surveillance to determine if waterborne illnesses a re occurring, even if waterborne illness from bottled water were relatively common, it would be unlikely that it would be noticed by health officials unless it reached the point of a m ajor outbreak or epidemic.

There are cases of known and scientifically well-do cumented waterborne infectious disease from bottled water, but most have occurred outside of the United States (see Technical Report [print report only] and Appendix B). However, ther e clearly is a widespread potential, according to independent expe rts, for waterborne disease to be spread via bottled water. [97]

Bottled Water and Vulnerable Populations

Many people who are especially vulnerable to infect ion (such as the infirm elderly, young infants, people living with HIV/AIDS, people on imm unosuppressive chemotherapy, transplant patients, etc.) use bottled water as an alternative to tap water out of concern for their safety. Some leading public-health experts, t herefore, argue that bottled water should be of higher microbiological quality than most food s. [98] In fact, health-care providers and other professionals often recommend that people who are immunocompromised or who suffer from chronic health problems drink bottled w ater. Indeed, FDA's guidance for immunocompromised people (posted on the FDA Web sit e) recommends that people with lowered immunity should "drink only boiled or bottl ed water. . . ." [99]

Immunocompromised people often are not aware of the need to ensure that they are drinking microbiologically safe water or are vaguel y aware of this issue but simply switch to bottled water on the assumption that it is safer than tap water. As discussed previously and in detail in the accompanying Technical Report (print report only), this may not be a safe assumption.

Bottled Water Storage and Growth of Microorganisms

Bottled water often is stored at relatively warm (r oom) temperatures for extended periods of time, generally with no residual disinfectant co ntained in it. As noted in the Technical Report (print report only) and shown in Figure 8, several studies have documented that there can be substantial growth of certain bacteria in bottled mineral water during storage, with substantial increases in some cases in the lev els of types such as heterotrophic-plate-count-bacteria and Pseudomonas . [100] Studies also have shown that even when there are relatively low levels of bacteria in water when it is bottled, after one week of storage, total bacteria counts can jump by 1,000-fold or mor e in mineral water. [101]

Conclusions Regarding Bottled Water Contaminants

Our limited "snapshot" testing, and that published in a few other recent surveys of bottled water, indicate that most bottled water is of good quality. However, our testing also found that about one fourth of the tested bottled water b rands contained microbiological or chemical contaminants in at least some samples at l evels sufficiently high to violate enforceable state standards or warning levels. Abou t one fifth of the brands tested exceeded state bottled water microbial guidelines i n at least some samples. Overall, while most bottled water appears to be of good quality, i t is not necessarily any better than tap water, and vulnerable people or their care provider s should not assume that all bottled water is sterile. They must be sure it has been suf ficiently protected and treated to ensure safety for those populations.

AN EXAMPLE OF INDUSTRIAL-SOLVENT CONTAMINATION OF BOTTLED WATER [102]

One particularly troubling case of industrial-chemical contamination of bottled water arose in Massachusetts. Massachusetts Department of Public Health files reveal that the Ann & Hope commercial well in Millis, Massachusetts, for years supplied several bottlers, including Cumberland Farms, West Lynn Creamery, Garelick Farms, and Spring Hill Dairy with "spring water" sold under many brand names.

According to state officials and records, this well is located literally in a parking lot at an industr ial

warehouse facility and is sited near a state-designated hazardous-waste site. Several chemical contaminants were found in the water, including trichloroethylene (an EPA-designated probable human carcinogen). On at least four occasions these chemicals were found at levels above EPA and FDA standards in the well water. Dichloroethane, methylene chloride, and other synthetic organic chemicals (industrial chemicals) were also found, though the source of these contaminants reportedly was not identified.

Contamination was found in the water in 1993, 1994, 1995, and 1996, but according to a state memo written in 1996, "at no time did Ann & Hope [the well operating company] do anything to determine the source of the contamination nor treat the source. Rather, they continued to sell water laced with volatile organic compounds, some of which were reported in finished product." The contamination levels depended on pumping rates from the wells. After a state employee blew the whistle on the problem and demanded better protection of bottled water in the state, she was ordered not to speak to the media or bottlers and was reassigned by Massachusetts Department of Public Health supervisors to other duties, in what she alleges was a retaliatory action. State officia ls deny that her reassignment was due to retaliation. The well reportedly is no longer being used for bottled water after the controversy became public.

Chapter Notes

3a. For cost reasons, we did not test for any radio logical contaminants.

3b. Throughout this report and the attached Technic al Report (print report only) we refer to two categ ories of chemicals for which we tested, semivolatile synthetic organic chemicals and volatile organic chemicals (VOCs). T echnically, synthetic organic chemicals (SOCs) include any man- made chemicals—including nonvolatile, semivolatile, and volatile—that contain hydrogen and carbon. We, EPA, and FDA refer to VOCs as a shorthand for volatile synthetic organic chemicals, and to semivolatile SOCs as separate typ es of chemicals, even though many VOCs are also a t ype of SOC. The reason for differentiating between these two ca tegories of contaminants is that EPA standard metho ds for testing for them are different, and because both EPA and FD A rules tend to artificially distinguish between VO Cs and SOCs—the later being shorthand for semivolatile SOCs.

3c. None of the waters we tested exceeded the FDA a nd EPA standard for arsenic in water of 50 ppb. Tha t standard originally was set in 1942 and is 2,000 times highe r than the level EPA recommends for ambient surface water for public-health reasons; it also is 5 times higher than the World Health Organization and European Union arseni c-in-drinking-

water limit. Congress has required that the EPA sta ndard be updated by the year 2001. For reasons disc ussed in the accompanying Technical Report (print report only), many public health, medical, and other experts beli eve that the current EPA/FDA standard is far too high.

Report Notes

75. IBWA, "FAQs [Frequently Asked Questions] About Bottled Water," (1998); available at www.bottledwater.org/faq.html#3.

76. See, e.g., "The Selling of H2O," Consumer Repor ts, p. 531 (September 1980),.(finding excessive ars enic in several waters); "Water, Water Everywhere," Consumer Reports , pp. 42-48 (January 1987), (also finding excessive arsenic in several waters); see also, "Bottled Water Regulatio n," Hearing of the Subcommittee on Oversight and In vestigations of the House Committee on Energy and Commerce, Serial No. 102-36, 102nd Cong., 1st Sess. 5, (April 10, 19 91), (noting excessive benzene and other contaminants in bottled water).

77. According to figures for 1994 collected by the Beverage Marketing Corporation, the leading states were, in order, California (about 30% of the market), Florida (abou t 6%), New York (about 6%), Texas (about 6%) and Il linois (about 4%). Beverage Marketing Corporation, Bottled Water in the U.S. , 1996 Edition (1996), as cited in New Jersey Depar tment of Health & Senior Services, Report to the New Jersey Legislature, Summarizing L aboratory Test Results on the Quality of Bottled Drinking Water for the Period January 1, 19 95 through December 31, 1996 , p. 6 (July 1997). A more recent survey found "California remains the top market for bottle d water, with four times the number of gallons sold as the second-largest market. In fact, Californians drank 893,700 gallons of bottled water in 1997, more than the ne xt four states combined: Florida (221,700 gallons), Texas (218,700 ), New York (204,400), and Arizona (124,900)." C. R oush, "Bottled Water Sales Booming," The Daily News of Los Angeles , p. B1 (April 16, 1998).

78. In a handful of cases, water was found in a tes t to contain contamination at levels of potential c oncern, but not retested -- generally because the water could not b e found for retesting or it was logistically imprac tical to repurchase and reship the water for retesting. (See Appendix A .)

79. For example, the U.S. Geological Survey's (USGS ) National Water Summaries (see, e.g. USGS, National Water Summary , 1988-1996), and National Water Quality Assessment Program (see, e.g., USGS National Water Quality Assessment Program--Pesticides in Ground Water (1996), USGS National Water Quality Assessment Program -- Pesticides in Surface Water (1997); see also www.usgs.gov (amply document that water quality measured using pesticides or other indicator contaminants can vary by orders of magnitude in a stream or shallow grou ndwater in some areas, depending upon the time of year, chemical us e, hydrologic events such as precipitation, etc.)

80. See, U.S. Public Health Service, Department of Health and Human Services, Review of Fluoride: Benefits and Risks (February 1991); B. Hileman, "Fluoridation of Water : Questions About Health Risks and Benefits Remain After More than 40 Years," Chemical & Engineering News , pp. 26-42 (August 1, 1988); Robert J. Carton, Ph. D., and J. William Hirzy, Ph.D., EPA, and National Treasury Employees Union, "Applyi ng the NAEP Code of Ethics to the Environmental Pro tection Agency and the Fluoride in Drinking Water Standard, " Proceedings of the 23rd Annual Conference of the Na tional Association of Environmental Professionals ; 24 June 1998, San Diego, California, Sponsored by the California Association of Environmental Professionals, availab le at http://home.cdsnet.net/~fluoride/naep.htm .

81. Smith et al., "Cancer Risks from Arsenic in Dri nking Water," Environmental Health Perspectives , vol. 97, pp. 259-67 (1992); Agency for Toxic Substances and Disease Reg istry, Toxicological Profile for Arsenic , (1993); NRDC, USPIRG, and Clean Water Action, Trouble on Tap: Arsenic, Radioactive Radon, and Tri halomethanes in Our Drinking Water (1995); United States Environmental Protection Agency, Health Assessment Document for Inorganic Arsenic - Final Report (March 1984); M. S. Golub, M.S. Macintosh, and N. B aumrind, "Developmental and Reproductive Toxicity o f Inorganic Arsenic: Animal Studies and Human Concerns," J. Toxicol. Environ. Health B. Crit. Rev. , vol. 1, no. 3, pp. 199-241 (July 1998).

82. R.D. Morris, "Chlorination, Chlorination By-Pro ducts, and Cancer: A Meta Analysis," American Journal of Public Health , vol. 82, no. 7, at 955-963 (1992); EPA, "Proposed National Primary Drinking Water Regulations for Di sinfectants and Disinfection By-Products," 59 Fed. Reg. 38668 ( July 29, 1994); NRDC, U.S. PIRG, and Clean Water Ac tion, Trouble on Tap: Arsenic, Radioactive Radon, and Trihalomethane s in Our Drinking Water (1995).

83. See, S.H. Swan, et al., "A Prospective Study of Sponta neous Abortion: Relation to Amount and Source of Dr inking Water Consumed in Early Pregnancy," Epidemiology , vol. 9, no. 2, pp. 126-133 (March 1998); K. Walle r, S. H. Swan, et al. (1998). "Trihalomethanes in Drinking Water and Spon taneous Abortion," Epidemiology , vol. 9, no. 2, pp. 134-40 (1998); F. J. Bove, et al. "Public Drinking Water Contaminatio n and Birth Outcomes," Amer. J. Epidemiol. , vol. 141, no. 9, pp. 850-862 (1995); see also , NRDC, U.S. PIRG, and Clean Water Action, Trouble on Tap: Arsenic, Radioactive Radon, and Trihalomethanes in Our Drinking Water (1995).

84. EPA, "National Primary Drinking Water Regulatio ns, Final Rule," 56 Fed. Reg. 3526, at 3537-38 (Jan uary 30, 1991); Environmental Working Group, Pouring it On: Nitrate Contamination of Drinking Wa ter (1996); National Research Council, Nitrate and Nitrite in Drinking Water (1995).

85. Environmental Working Group, Pouring it On: Nitrate Contamination of Drinking Wa ter , p. 11 (1996),(citing P.G. Sattelmacher, "Methemoglobinemia from Nitrates in D rinking Water, Schriftenreiche des Verins fur Wasser Boden und Luthygiene , no. 21 (1962), and Simon, et al. , "Uber Vorkommen, Pathogenese, und Mogliichkeiten sur Prophylaxe der Durch Nitrit Verursachten Methamogloniamie," Zeitschrift fur Kinderheilkunde , vol. 91, pp. 124-138 (1964)).

86. Ibid.

87. R. J. Madison and J.O. Brunett, U.S. Geological Survey, "Overview of Nitrate in Ground Water of th e United States," National Water Summary, 1984: USGS Water Supply Pap er 2275, p. 93 (1985).

88. D.W. Warburton, "A Review of the Microbiologica l Quality of Bottled Water Sold in Canada, Part 2: The Need for More Stringent Standards and Regulations," Canadian J. of Microbiology , vol. 39, p. 162 (1993); H. Hernandez-Duquino, and F.A. Rosenberg, "Antibiotic-Resistant Pseudomonas i n Bottled Drinking Water," Canadian J. of Microbiology , vol. 33, 286-289 (1987); P.R. Hunter, "The Microbiology of B ottled Natural Mineral Waters," J. Applied Bacteriol. , vol. 74, pp. 345-352 (1993); see also, F.A. Rosenberg, "The Bacteria l Flora of Bottled Waters and Potential Problems As sociated With the Presence of Antibiotic-Resistant Species," in Proceedings of the Bottled Water Workshop , September 13 and 14, 1990, A Report Prepared for the Use of the Subcommittee on Oversight and Investigations of the Committee on En ergy and Commerce, U.S. House of Representatives, Committee Print 101-X, 101st Cong., 2d Sess. pp. 72-83 (Decem ber, 1990).

89. Kansas Department of Health and the Environment , A Pilot Study to Determine the Need for Additional Testing of Bottled Water in the State of Kansas (undated, 1994?).

90. Commonwealth of Massachusetts, Executive Office of Health and Human Services, Department of Public Health, Division of Food and Drugs, Survey of Bottled Water Sold in Massachusetts (May 22, 1997). See also, annual Surveys of Bottled Water Sold in Massachusetts for 1996, 1995, and 1994.

91. New Jersey Department of Health and Senior Serv ices, Division of Environmental and Occupational He alth Services, Report to the New Jersey legislature, Senate Enviro nment & Assembly Environment, Science, and Technolo gy Committees, Summarizing Laboratory Test Results on the Quality of Bottled Drinking Water for the Perio d January 1, 1995 through December 31, 1996 (July 1997).

92. Pennsylvania Department of Environmental Protec tion, Bureau of Water Supply and Community Health, Division of Drinking Water Management, Bottled Water Quality Assurance Survey: Summary Rep ort for 1993 through 1995 (1995).

93. Wisconsin Department of Agriculture, Trade, and Consumer Protection, State of Wisconsin Bottled Drinking Water Report & Analytical Results (Fiscal Year 1997); accord , Wisconsin Department of Agriculture, Trade, and C onsumer Protection, State of Wisconsin Bottled Drinking Water Sampling and Analysis Test Results (Fiscal Year 1994).

94. See, e.g., H. Hernandez-Duquino and F.A. Rosenb erg, "Antibiotic-Resistant Pseudomonas in Bottled Drinking Water," Can. J. Microbiology , vol. 33, p. 286 (1987).

95. R. Ashby, "Migration from Polyethylene Tereptha late Under All Conditions of Use," Food Add. & Contamin. , vol. 5, pp. 485-492 (1988); J. Gilbert, L. Castle, S.M. Jickell s, A.J. Mercer, and M. Sharman, "Migration from Pla stics Into Foodstuffs Under Realistic Conditions of Use," Food Add. & Contamin. , vol. 5, pp. 513-523 (1988); S. Monarca, R. De Fus co, D. Biscardi, V. De Feo, R. Pasquini, C. Fatigoni, M. M oretti, and A. Zanardini, "Studies of Migration of Potentially Genotoxic Compounds Into Water Stored In PET Bottles," Food Chem. Toxic. , vol. 32, no. 9, pp. 783-788 (1994).

96. Page, et al., "Survey of Bottled Drinking Water Sold in Canada, Part 2: Selected Volatile Organic Compounds," J. AOAC International , vol. 76, no. 1, pp. 26-31 (1993).

97. See, e.g., D.W. Warburton, "A Review of the Mic robiological Quality of Bottled Water Sold in Canad a. Part 2. The Need for More Stringent Standards and Regulations." Canadian J. Microbiology , vol. 39, pp. 158-168 (1993); P.R. Hunter, "The Microbiology of Bottled Natural Mineral Waters," J. Applied Bacteriol. , vol. 74 345-52 (1993); L. Moreira, et al., "Survi val of Allochthonous Bacteria in Still Mineral Water Bo ttled in Polyvinyl Chloride and Glass, J. Applied Bacteriol. , vol. 77, pp. 334-339 (1994).

98. D.W. Warburton, "A Review of the Microbiologica l Quality of Bottled Water Sold in Canada, Part 2: The Need for More Stringent Standards and Regulations," Canadian J. of Microbiology , vol. 39, p. 162 (1993).

99. D. Farley, "Food Safety Crucial for People With Lowered Immunity," FDA Consumer , available at www.fda.gov (printed 8/19/1997).

100. L. Moreira, P. Agostinho, P.V. Morais, and M.S . da Costa, "Survival of Allochthonous Bacteria in Still Mineral Water Bottled in Polyvinyl Chloride (PVC) and Glass," J. Applied Bacteriology , vol. 77, pp. 334-339 (1994); P.V. Morais, and M.S . Da Costa, "Alterations in the Major Heterotrophic B acterial Populations Isolated from a Still Bottled Mineral Water," J. Applied Bacteriol. , vol. 69, pp. 750-757 (1990); P.R. Hunter, "The Mi crobiology of Bottled Natural Mineral Waters," J. Applied Bacteriol. , vol. 74, pp. 345-52 (1993); F.A. Rosenberg, "The Bacterial Flora of Bottled Waters and Potential Problems Associated With the Presence of Antibiotic -Resistant Species," in Proceedings of the Bottled Water Workshop , September 13 and 14, 1990, A Report Prepared for th e Use of the Subcommittee on Oversight and Investig ations of the Committee on Energy and Commerce, U.S. House of Rep resentatives, Committee Print 101-X, 101st Cong., 2 d Sess. pp. 72-81 (December, 1990); D.W. Warburton, B. Bowen, a nd A. Konkle, "The Survival and Recovery of Pseudomonas aeruginosa and its effect on Salmonellae in Water: Methodolog y to Test Bottled Water in Canada," Can. J. Microbiol. , vol. 40, pp. 987-992 (1994); D.W. Warburton, J.K. McCorm ick, and B. Bowen, "The Survival and Recovery of Aeromonas hydrophila in Water: Development of a Methodology for Testing Bottled Water in Canada," Can. J. Microbiol. , vol. 40, pp. 145-48 (1994); D.W. Warburton, "A Review of the Mic robiological Quality of Bottled Water Sold in Canad a, Part 2: The Need for More Stringent Standards and Regulations," Canadian J. of Microbiology , vol. 39, p. 162 (1993); A. Ferreira, P.V. Morais, and M.S. Da Costa, "Alterations in Total Ba cteria, Iodonitrophenyltetrazolium (INT)-Positive B acteria, and Heterotrophic Plate Counts of Bottled Mineral Water ," Canadian J. of Microbiology , vol. 40, pp. 72-77 (1994).

101. Ibid; see especially A. Ferreira, A., P.V. Morais, and M.S. Da Costa, " Alterations in Total Bacteria, Iodonitrophenyltetrazolium (INT)-Positive Bacteria, and Heterotrophic Plate Counts of Bottled Mineral Water," Canadian J. of Microbiology , vol. 40, pp. 72-77 (1994).

102. The information in this text box is summarized from the Massachusetts Department of Public Health ’s (MDPH) Ann & Hope Water Incident Files, 1993-1997, including M DPH, Survey of Massachusetts Bottlers for Source and Fin ished Product Contamination (1992-1997); Summary of the Amount of Water Withdrawn from the M illis Springs, Inc. Spring #2 (undated); Letter from Dr. Elizabeth Bourque to J. McKinnies, Ann & Hope (August 7, 1996); Memorandum From Dr. Bourke to Paul Tierney, December 13, 1996 (MDPH Mem oranda Provided to NRDC Pursuant to Freedom of Info rmation Request); D. Talbot, "Bottled Water Flows from Trou bled Well," Boston Herald , p. 1 (December 16, 1996); E. Leuning, "Toxin in Ann & Hope Wells Worries Officials," Middlesex News , p. 1 (September 18, 1996); E. Leuning, and H. Swa ils, "Water Source has History of Contaminants," Country Gazette (September 18, 1996); Personal Communication with Dr. Bourque, MDPH, August 1997, and January 1999; Perso nal Communication with Paul Tierney, MDPH, January 1999.

Chapter 4

GAPING HOLES IN GOVERNMENT BOTTLED WATER REGULATION

The bottled water industry often makes the claim th at it is far better regulated than tap water suppliers are. For example, the International Bottled Water Association (IBWA) testified in 1991 that "When compared to the level of regulation and scrutiny applied to tap water . . .bottled water consumers come out way ahe ad." [103] IBWA asserted that "If one considers the full range of FDA consumer protection standards, bottled water safeguards have been more complete and protective for a longer time than tap water standards." [104]

This continues to be the industry argument. In a 19 98 fact sheet, for example, IBWA contends, "Quality is in every container of bottled water. It's consistent and it is inspected and monitored by governmental and private laborator ies. Unfortunately, tap water can be inconsistent -- sometimes it might be okay while ot her times it is not." [105] The IBWA further declares that "bottled water is strictly re gulated on the federal level by the Food and Drug Administration (FDA) and on the state leve l by state officials. This ensures that all bottled water sold in the United States meets t hese stringent standards ." [106]

FDA Rules for Bottled Water Are Generally Less Strict than Tap Water Rules

Our in-depth review indicates that, with few except ions, federal bottled water regulation is weaker than the tap water regulations facing city water s upplies. The bottled water

industry is disingenuous in pointing out that there are significant flaws in the tap water regulatory scheme, since many more flaws exist in b ottled water rules. Although smaller tap water utilities sometimes face less stringent c ontrols than do bigger cities, it still is clear that federal rules for city tap water general ly are more stringent than those for bottled water.

For many years, under the Federal Food, Drug, and C osmetic Act (FFDCA), FDA was supposed to adopt and apply to bottled water all EP A tap water standards within 180 days after EPA issued those standards. [107] FDA was authorized to refuse to apply the EPA tap water standards to bottled water in certain circums tances where it determined and published reasons explaining why they were inapprop riate for bottled water. [108] What happened, however, was that rather than affirmative ly making such determinations, FDA just could not seem to be able to get around to iss uing bottled water standards or making determinations at all.

Historically, FDA has lagged in its obligation to a pply the EPA standards to bottled water, having adopted only a fraction of EPA tap water sta ndards and often being severely criticized for its inaction. For example, a 1995 Se nate committee report noted:

FDA has been slow to act. FDA took 4 years to set s tandards for the 8 volatile organic chemicals (including benzene) regulated by EPA in 1 989. FDA did not set standards for the 35 contaminants covered by EPA's 1991 Phase II rule making until December, 1994. Standards for bottled water have not been issued fo r those contaminants regulated by the [EPA] Phase V rule for tap water, although it was p romulgated by EPA in 1992 and became effective for tap water on January 1, 1994. [109]

Public and congressional criticism of FDA came to a head after benzene was found in Perrier in 1990, and congressional hearings and a G eneral Accounting Office investigation in 1991 revealed widespread failures by FDA to adop t standards and to oversee the bottled water industry. [110] The industry suffered a temporary setback in its g rowth as a result of the public scrutiny, but ultimately both it and FDA weathered the storm.

The 1996 Safe Drinking Water Act (SDWA) amendments modified the FFDCA to provide that, by operation of law, if FDA does not adopt ne w EPA tap water rules for bottled water within 180 days, EPA standards will automatically s erve as bottled water standards. [111] If FDA decides to adopt its own standards, they must b e at least as stringent as EPA tap water standards, unless FDA finds that the contamin ant does not occur at all in bottled water -- in which case FDA can waive the requiremen t to have a bottled water standard. [112] The current legal status of bottled water standards for contaminants for which EPA had issued standards for tap water before the enactment of the 1996 SDWA amendments, but for which there were no FDA bottled water contamina nt standards in effect, is being debated.

NRDC has carefully evaluated the regulatory framewo rk now, more than seven years after the 1990-1991 storm of controversy swirled around t he industry, and more than two years after the enactment of the SDWA amendments of 1996. We find that although, from 1993 to 1998, FDA adopted some of the additional bottled water standards it was o bliged to adopt (and either decided not to adopt others or simply h as not completed rule-making on them), little else has changed. [113]

Gaping holes remain in the regulatory fabric for bo ttled water, and FDA and state resources dedicated to bottled water protection and enforcement generally are thin to nonexistent. For example, FDA's head bottled water regulator estimates that FDA has just one half of a person (full-time equivalent or FTE) per year dedicated to bottled water

regulation. [114] Similarly, bottled water compliance is a low prior ity for FDA, so specific figures are not kept for resources dedicated to ens uring it meets standards; the compliance office estimated in 1998 that a likely t otal of "less than one" FDA staff person (FTE) is dedicated to bottled water compliance. [115]

The problems created by this lack of regulatory att ention are addressed in detail below. "Voluntary compliance" and "industry self-regulatio n" seem to be the watchwords for the bottled water industry. While such an approach can be effective with motivated members of an industry, the discussions of contamination pr oblems documented in previous chapters and in the Technical Report (print report only) make it clear that this approa ch leaves plenty of room for unscrupulous or careless members of the industry to provide substandard products, with little chance of being c aught or subject to penalties.

This is not to say that bottled water quality is generally inf erior to average tap water quality. We do not believe such a statement is warr anted, and in fact NRDC has produced numerous reports documenting the contamination prob lems of tap water. [116]

Our evaluation does show, however, that the regulat ory system intended to ensure bottled water quality has enormous gaps. The majority of bo ttled water, according to FDA, is not covered by federal regulations, and FDA does not re gulate or monitor the bottled water that is covered by its rules particularly well.

Gaps and Loopholes in FDA Regulations

1. Water bottled and sold in a single state -- the majority of bottled water sold in the United States -- is not covered b y FDA rules, according to FDA.

An estimated 60 to 70 percent of the bottled water sold in the United States is sold in " intra state commerce" (i.e., it is bottled and sold in th e same state). [117] For example, the large delivered 5-gallon carboy bottles that are pu t in office or home water coolers are often intrastate waters, as are many of the brands sold in grocery, convenience, and other stores.

FDA says its bottled water regulations apply only t o water "that is in, or is intended to be shipped in, inter state commerce." [118] (emphasis added) Thus, according to FDA's interpretation, 60-70 percent of the bottled water sold in the U.S. -- all bottled water sold in intrastate commerce -- apparently is not covered by the FDA rules. This leaves the government regulation of this water, if any, to sta te governments.

The position that intrastate bottled water is not c overed by FDA's rules is based on FDA's interpretation of the limitations of the Federal Fo od, Drug, and Cosmetic Act, [119] which FDA says allows it to regulate only interstate comm erce (i.e., water that crosses state lines). This interpretation of the FFDCA has been q uestioned by experts, including some in the bottled water industry. [4a] Indeed, the FDA interpretation of the FFDCA appear s to be unduly narrow, in light of the clear nexus between virtually all intrastate bottled water sales and interstate commerce, as demonstrated, for instance, in the fact that packaging materials and consumers of the bottled water freque ntly come from out of state.

The impact of the narrow FDA interpretation cannot be overstated. Our survey of states, reviewed later in this chapter, found that often st ates have few if any resources dedicated to policing bottled water. Thus, in many states, co mpliance with federal and state bottled water standards essentially is discretionary for ma ny bottlers, and the public's only protection is voluntary industry self-regulation. T his offers little or no protection from fly-by-night bottlers in some states.

The problem of inadequate regulatory protection for intrastate sales of bottled water was identified in 1991 as a significant problem by the General Accounting Office in a report delivered to Congress. [120] Nothing has been done by FDA or Congress to remedy the federal regulatory gap.

2. FDA's definition of "bottled water" covered by it s standards irrationally exempts many types of bottled water.

FDA's rules exempt many forms of what most of us wo uld consider bottled water from its definition of "bottled water," and therefore, accor ding to FDA, exempts them from all of FDA's specific standards for bottled water testing and contamination. If the product is declared on the bottle ingredient label simply as " water," or as "carbonated water," "disinfected water," "filtered water," "seltzer wat er," "soda water," "sparkling water," or "tonic water," it is not considered "bottled water" by FDA. [121] FDA says it exempted these waters because they are "not understood by the publ ic to be bottled water." [122] What is covered by FDA's rules? FDA says it regulates produ cts labeled as "spring water," "mineral water," "drinking water," "bottled water," "purified water," "distilled water," and a few other specific categories of bottled water -- c reating enormous confusion for any consumer seeking to figure out whether FDA rules ap ply or do not apply to a specific water on the grocery store shelf.

We doubt that most consumers would agree that water in a bottle listed on the ingredient label as "water" or "sparkling water" or "filtered water" should be exempted from the specific health-protection standards that cover any other bottled water. California and some other states have chosen a different course th an FDA and regulate all water that comes in bottles likely to be ingested by people as bottled water. [123] We support this approach and recommend that FDA revise its rules to cover all water intended for drinking or culinary purposes that is likely to be ingested by people and that comes in a bottle, as California and some other states have done.

Industry data indicate that these waters that FDA e xempts from the definition of bottled water represent a significant chunk of the overall bottled water industry. For example, a report in the beverage-industry trade press noted t hat in 1996 there were more than 152 million cases of sparkling water sold in the United States. [124] This of course does not include many nonsparkling exempted waters such as " filtered water" or "disinfected water."

For these "non-bottled water" bottled waters, FDA o fficials have said the specific FDA contamination standards and water-quality testing r equirements, as well as the specific bottled water good-manufacturing-practice rules for bottled water, are not applicable. [125] Thus, no contamination monitoring is specifically r equired, and only a vague narrative standard applies, according to FDA, which states th at the water cannot be "adulterated" and must be safe, wholesome, and truthfully labeled . These nebulous terms are not defined and, to date, apparently the FDA has never enforced the standard with any of these bottled products.

3. Even water defined as "bottled water" is not spe cifically required to meet treatment, contamination, or testing standards as strict as those applicable to city tap water.

Water that FDA does define as "bottled water" is no t required by federal rules to meet many of the specific standards and testing requirem ents that apply to city tap water. Some of the important disparities between bottled water and tap water are noted in Table 1 (in chapter 1), and in Tables 6 and 7. This seems to directly contradict the FFDCA's requirement [126] that bottled water is supposed to be regulated as stringently as tap water.

FDA argues that it retains the authority to act aga inst "adulterated" water (which is not specifically defined) and that its general food-saf ety authorities give it broad latitude to act if it finds a problem. [127] However, there is no indication that FDA has ever acted -- or has any intention of acting -- aggressively to implemen t and enforce treatment standards akin to those applicable to tap water. Moreover, FDA doe s very little random monitoring on its own of bottled water quality, so there is little as surance that if a problem does exist, FDA would ever find out about it.

Some of the important incongruities between tap wat er and bottled water standards follow.

Weaker bacteria rules for bottled water. There is a clear prohibition under EPA rules against any confirmed E. coli or fecal coliform bacteria in tap water. [128] FDA has adopted no such prohibition for bottled water. [129] Rather, FDA's rules set a maximum number of total coliform bacteria in bottled water, with no s pecific prohibition on fecal coliform bacteria or E. coli contamination of bottled water. [130] FDA's proposal over four years ago (in October 1993 [131]) to issue a ban on all coliform bacteria in bottle d water has languished. FDA has no specific plans to finalize this rule in the near future. [132]

Moreover, EPA's rules essentially treat excessive h eterotrophic-plate-count (HPC) bacteria (i.e., HPC presence greater than 500/ml) as a "posi tive" for total coliform bacteria for most big-city water supplies; no more than 5 percent of all monthly tap water samples can contain total coliform bacteria. [133] FDA has adopted no rules for HPC in bottled water; the agency says if HPC levels exceed 10,000/ml (i.e. 20 times higher than the EPA benchmark for tap water), FDA "will consider conducting a follow-up inspection of domestic bottlers...." [134]

In addition, while we certainly do not endorse EPA' s water-testing rules for tap water as a panacea for drinking water problems, at least a sys tem serving a larger city (more than 100,000 people) has to test its tap water over 100 times each month for coliform bacteria, on average several times a day. [135] Yet bottled water -- even at a huge bottling plant filling millions of water bottles a year -- must be tested for coliform bacteria only once a week under FDA rules. [136] (IBWA's model industry code recommends daily testi ng of its members' water, though IBWA's recommendation is not binding unless adopted under state law -- an action that most states have not taken, as noted in our review of state programs later in this chapter.)

FDA's failure to adopt these bacteriological standa rds contradicts FFDCA's requirement that FDA standards for bottled water must be at lea st as strict as tap water standards. [137]

No treatment requirements to remove or kill bacteri a and parasites in bottled water. Under EPA's tap water rules, which are less than complete , cities using surface water generally

must disinfect their water and filter it to remove not only bacteria (e.g., coliform bacteria and Legionella) and viruses, but also certain proto zoa such as Giardia (unless they can document and obtain formal approval for a filtratio n waiver because their water is of very high quality and their source water is highly prote cted from contamination). [138] Yet, as shown in Tables 1 and 6, there are no specific FDA standards requiring bottled water to be disinfected or treated in any way to remove bacteri a or parasites [139] -- another apparent violation of FFDCA's comparability requirement for bottled water and tap water standards.

There is a maximum turbidity standard for bottled w ater of 5 units (the same as for tap water, though the new tap water maximum is 1 unit e ffective on December 17, 2001, under a recently issued rule). [140] There is no rule, however, requiring that bottled water average less than 0.5 units of turbidity each month -- a re quirement that currently applies to tap water and will be dropped (effective on the same da te) to 0.3 units (for the 95th percentile level) under the same recent EPA rule. Moreover, wh ile tap water must have ongoing turbidity sampling every four hours, no such requir ement applies to bottled water. [141] The weaker bottled water rule is of concern because tur bidity is in many cases the only indication that water is contaminated with parasite s. [142]

Despite these serious FDA regulatory gaps, the bott led water industry publicly proclaims, we believe without justification, that consumers sh ould turn to bottled water if they want to avoid Cryptosporidium (the protozoan that sickened 400,000 people and ki lled more than 100 due to tap water contamination in Milwauke e in 1993 [143]). IBWA states, for example, that FDA rules "ensure that surface water contaminants such as Cryptosporidium and Giardia are not present" in bottled water derived from wel ls and springs, and that it tells its members to use addit ional treatment if they produce tap-water-derived bottled water, to assure that Cryptosporidium cannot get into the bottled water. [144]

Such public proclamations seem to run contrary to t he bottled water industry's own privately expressed concerns about the possibility of Cryptosporidium in bottled water supplies. [145] Candid internal communications admit that unless a ll water bottlers adopt adequate treatment to kill or remove Crypto , they will have a hard time convincing the public that bottled water is immune from such conta mination. For instance, the following appeared in the IBWA's in-house publication, urging bottlers to upgrade their treatment to be sure it meets CDC guidelines for removing Cryptosporidium : "How can we expect health groups to endorse our product if we don't AL L meet the [CDC Cryptosporidium removal] guidelines!" [146] (emphasis in original). An excellent question, ind eed.

No Cryptosporidium and Giardia testing for bottled water. EPA's Information Colle ction Rule has required that over the past couple of year s, big cities that use surface water (systems which serve the majority of the U.S. popul ation) generally must test for common parasites such as viruses, Giardia and Cryptosporidium .[147] By contrast, FDA rules do not specify that any water bottlers are ever required to do such testing. [148]

Weaker standards for some chemical contaminants in bottled water. The regulatory standards for several chemicals in bottled water ar e also weaker than the standards for city tap water (see Table 6). For example, FDA has refused to set standards or treatment techniques for acrylamide, asbestos, di(2-ethylhexy l)phthalate (DEHP), or epichlorohydrin, [149] all of which EPA regulates in tap water. [4b]

It is a strange twist indeed that DEHP, a probable human carcinogen, possible endocrine-system disrupter, and agent produced in plastics ma nufacturing that migrates into water from plastic water bottles, is regulated under EPA tap water rules but not under FDA's bottled water rules. [150] Logic would suggest that if anything, it is more i mportant to control phthalate in bottled water since, it is so often so ld in plastic bottles that can leach this chemical.

In fact, FDA stated when it decided not to adopt a DEHP standard that it was the only chemical contaminant it had proposed to regulate in that package of standards that it was aware occurred in bottled water at levels over the EPA standard. [151] Some bottlers and members of the plastics manufacturing industry vigo rously opposed a phthalate standard, arguing that it would cause some bottled water to b e in violation after storage for long periods. [152] As one company put it, "bottled water tested immed iately after packaging would meet the 6 ppb [FDA proposed] limit but with storage it is possible that levels might exceed this requirement . . .[so] the proposed amen dment . . .[would] effectively ban the use of DEHP in closure sealants for bottled water . . . ." [153] Although other members of the bottled water industry supported a phthalate standa rd, [154] FDA bowed to those who objected, and decided not to apply the EPA standard -- or any other standard -- for DEHP in bottled water. [155] FDA deferred further action on the DEHP standard i ndefinitely. This appears to be a clear violation of the Federal Food , Drug and Cosmetic Act, which requires bottled water rules to be at least as stringent as EPA's tap water rules. [156]

Similarly, in response to bottled water industry co mplaints about the burden of having to comply with too many standards (and in particular t he costs of testing), in 1996 FDA decided to stay any bottled water standards for nin e chemical contaminants that have been regulated in tap water since 1992. The nine we re antimony, beryllium, cyanide, diquat, endothall, glyphosate, nickel, thallium, an d 2,3,7,8-TCDD (dioxin). [157] In this case, however, the outcome appears as if it will be diffe rent. In August 1996, Congress mandated that FDA adopt bottled water standards for those nine chemicals within two years of enactment, or EPA's tap water rules for th ose contaminants would automatically apply to bottled water. [158] In response to that congressional mandate, in May 1998, FDA issued a "direct final rule" that would make EPA's tap water standards for these nine contaminants enforceable for bottled water by Febru ary 1999. [159] In August 1998, FDA confirmed that the new rules for the nine contamina nts would finally be subject to regulation in bottled water as of February 2, 1999 [160] -- seven years after EPA issued standards for them in tap water.

There is a ray of light in the FDA bottled water re gulatory program. FDA's bottled water standards for lead, copper, and fluoride are strict er than EPA's tap water standards (see Table 6). [161] The bottled water industry advocated stricter stan dards for these contaminants, on health grounds. A cynic might spec ulate that these standards enable the bottled water industry to claim that its water is m ore strictly regulated than tap water (a claim some in the industry routinely make) without much of a regulatory bite, since these contaminants are rarely a problem in bottled water. (Lead and copper generally exist in tap water due to leaching from pipes or faucets between the treatment plant and the consumer and should not be found in bottled water; fluoride generally is intentionally added to tap water, though it is sometimes found in bottled wate r.) However, there is no record of such a rationale influencing the bottled water industry' s position.

TABLE 6 Comparison Of Health Standards: Tap Water Versus Bottled Watera

Contaminant EPA Health Goal (parts per billion)

EPA Tap Water Standard (parts per billion)

FDA Bottled Water Standard (parts per billion)

Bottled Water ("BW") vs. Tap Water Standard

Bacteria And Microbial Quality

E. Coli or Fecal Coliform

0 No confirmed samples of E. Coli or fecal coliform allowed

Up to 1 of 10 bottles tested may contain specified levels of any type of Coliform, subject to conditions

BW Weaker

Giardia lamblia 0 Treatment Technique

No Standard BW Weaker

Legionella 0 Treatment Technique


Standard-Plate-Count Bacteria (Heterotrophic-Plate-Count)

Not Applicable Treatment Technique


Total Coliform 0 No more than one sample/month may contain any total coliform (small systems). Cities: no more than 5% of samples may contain any coliform. No confirmed E. Coli or fecal coliform allowed

Specified levels of Total Coliform allowed in up to 1 in 10 bottles tested, subject to conditions; no ban on E. Coli or fecal coliform

BW Generally Weaker

Turbidity Not Applicable Treatment Technique; 5 NTUb maximum; less than 0.5 NTU 95% of time.

5 NTUb EPA lowered to 1 NTU 12/16/98, effective in 3-5 years

BW Weaker

Viruses 0 Treatment Technique


Chemical Contaminants

Acrylamide 0 TT No Standard BW Weaker

Adipate, (di(2-ethylhexyl))

400 400 400 Same

Alachlor 0 2 2 Same

Antimony 6 6 New Standard effective Feb. 1999c

Same

Arsenic 50 50 50 Same

Asbestos (>10µm) 7 MFLd 7 MFLd No Standard BW Weaker

Atrazine 3 3 3 Same

Barium 2,000 2,000 2,000 Same

Benzene 0 5 5 Same

Beryllium 4 4 New Standard Feb. 1999c

Same

Cadmium 5 5 5 Same

Carbofuran 40 40 40 Same

Carbon Tetrachloride 0 5 5 Same

Chlordane 0 2 2 Same

Chlorobenzene 100 100 100 Same

Chromium (total) 100 100 100 Same

Copper 1,300 Treatment Technique

1,000 BW Stricter

Cyanide 200 200 New Standard effective Feb. 1999c

Same

Dalapon 200 200 200 Same

2,4-D 70 70 70 Same

Dibromochloropropane 0 0.2 0.2 Same

o-Dichlorobenzene 600 600 600 Same

p-Dichlorobenzene 75 75 75 Same

1,2 -Dichloroethane 0 5 5 Same

1,1-Dichloroethylene 7 7 7 Same

cis-1,2-Dichloroethylene

70 70 70 Same

Trans-1,2-Dichloroethylene

100 100 100 Same

Dichloromethane 0 5 5 Same

1,2-Dichloropropane 0 5 5 Same

Dinoseb 7 7 7 Same

Dioxin 0 0.00003 New Standard effective Feb. 1999c

Same

Diquat 20 20 New Standard effective Feb. 1999c

Same

Endothall 100 100 New Standard effective Feb. 1999c

Same

Endrin 2 2 2 Same

Epichlorohydrin 0 Treatment Technique


Ethylbenzene 700 700 700 Same

Ethylene Dibromide 0 0.05 0.05 Same

Fluoride 4,000 4,000 Range from 800 to 2,400

BW Stricter

Glyphosate 700 700 New Standard effective Feb. 1999c

Same

Haloacetice Acids (5) 0 60 None BW Weaker

Heptachlor 0 0.4 0.4 Same

Heptachlor Epoxide 0 0.2 0.2 Same

Hexachloro-benzene 0 1 1 Same

Hexachlorocyclo- pentadiene

50 50 50 Same

Lead 0 Treatment Technique

5 BW Stricter

Lindane 0.2 0.2 0.2 Same

Mercury 2 2 2 Same

Methoxychlor 40 40 40 Same

Nitrate 10 10 10 Same

Nitrite 1 1 1 Same

Oxamyl 200 200 200 Same

PAHs (benzo(a)pyrene)

0 0.2 0.2 Same

Pentachlorophenol 0 1 1 Same

PCBs 0 0.5 0.5 Same

Phthalate, (di(2-ethylhexyl))

0 6 No Standard BW Weaker

Picloram 500 500 500 Same

Selenium 50 50 50 Same

Simazine 4 4 4 Same

Styrene 100 100 100 Same

Tetrachloroethylene 0 5 5 Same

Thallium 0.5 2 New Standard effective Feb. 1999c

Same

Toluene 1,000 1,000 1,000 Same

Toxaphene 0 3 3 Same

2,4,5-TP (Silvex) 50 50 50 Same

1,2,4-Trichlorobenzene 70 70 70 Same

1,1,1-Trichloroethane 200 200 200 Same

1,1-2-Trichloroethane 3 5 5 Same

Trichloroethylene 0 5 5 Same

Trihalomethanes 0 80f 100 BW Weaker

Vinyl Chloride 0 2 2 Same

Xylenes (total) 10,000 10,000 10,000 Same

Radioactive Substances

Alpha Emitters 0 15 pCi/Lg 15 pCi/Lg Same

Beta/Photon Emitters 0 4 mrem/yrh 4 mrem/yrh Same

Radium (Combined) 0 5 pCi/Lg 5 pCi/Lg Same

a Standards for bottled water reported in this table are only those adopted for health reasons and thus do not include secondary "aesthetically based" standards (such as those for color, chloride, iron, aluminum, silver, and manganese) that FDA adopted for aesthetic rather than health purposes; these secondary standards (except those for aluminum and silver) do not apply to bottled mineral water. b Nephelometric Turbidity Units (or NTU), is a measurement of turbidity, or water cloudiness. c An explicit mandate adopted by Congress in 1996 would have automatically applied EPA's tap water

standard for this contaminant to bottled water, unless FDA adopted a bottled water standard for the contaminant by August 6, 1998. On August 6, 1998, FDA confirmed a "direct final rule" that will apply the 1992 EPA tap water standard for this contaminant to bottled water, effective February 2, 1999. See 63 Fed. Reg. 42198. Until February 2, 1999, there is no bottled water standard for this contaminant. d MFL means Million Fibers of Asbestos per liter of water. e Tap water standard of 60 ppb for 5 haloacetic acids effective December 16, 2001 (except some small systems have until December 16, 2003). See 63 Fed. Reg. 69389 (December 16, 1998). f On December 16, 1998, EPA reduced the tap water MCL for TTHMs to 80 ppb from 100 ppb, effective December 16, 2001 (except some small systems have until December 16, 2003). See Fed. Reg. 69389 (December 16, 1998). g pCi/L means picocuries (a unit measuring radioactivity) per liter. h mrem/yr means a manmade radioactivity annual dose equivalent to the whole body or any internal organ of 4 millirems per year. Source: NRDC

Weaker chemical-contaminant testing requirements fo r bottled water. Under EPA rules, a city must test its tap water for many organic chemi cals, generally at least once a quarter .[162] In some cases (such as for trihalomethanes), city tap water systems must test at several locations each quarter. [4c]

Water bottlers, on the other hand, generally need o nly test for most chemicals once a year under FDA's rules. [4d] Moreover, water bottlers currently are exempt from testing for asbestos or phthalate, though there are tap water t esting and health standards for these. In addition, tap water supplies must test for 16 ad ditional unregulated contaminants and report the test results to authorities, as noted in Table 7. [163] Thus, it is apparent that bottled water testing requirements for some contami nants are less extensive and in depth than those that apply to city water systems.

TABLE 7 Contaminants That Must Be Monitored in City Tap Water but Not in Bottled Water

Regulated Contaminants Currently Required to be Monitored in Tap But Not Bottled Water

Asbestos Bromate (big cities past, soon all systems) Di(2-Ethylhexyl)phthalate

Haloacetic acids (big cities past, soon all systems)

Unregulated Contaminants* Currently Required to be Monitored in Tap But Not Bottled Water

Dibromomethane m-Dichlorobenzene 1,1-Dichloropropene

1,2,3-Trichloropropane 1,1,1,2-Tetrachloroethane Chloroethane

1,1-Dichloroethane 1,1,2,2-Tetrachloroethane 1,3-Dichloropropane Chloromethane Bromomethane

2,2-Dichloropropane o-Chlorotoluene p-Chlorotoluene Bromobenzene 1,3-Dichloropropene

Source: 40 C.F.R. §§ 141.21-141.30, 141.40 and 21 C.R. R. § 165.110 "Unregulated Contaminants" are contaminants not subject to enforceable Maximum Contaminant Levels or treatment requirements, but still required to be monitored for in tap water. "Regulated contaminants" are those subject to enforceable regulations currently, or under rules already promulgated but not enforceable until December 2001.

Bottlers self-test and do not have to use certified labs to test water; tap water suppliers may only use certified labs. Under EPA's regulation s, in order to ensure that water test results submitted by drinking water suppliers are a ccurate and of the highest quality, most tests must be completed by laboratories certified b y a state in accordance with EPA criteria. [164] This helps to ensure consistent quality assurance and quality control, and reduces the chances of inadvertent or intentional i naccuracies in water testing (although in many states, for some systems it is up to the wa ter system to submit the water to the lab for testing, presenting potential opportunities for mischief).

FDA, on the other hand, relies upon water bottler s elf-testing and self-selection of laboratories, and has refused to require lab certif ication. This failure to require certified labs came under criticism from General Accounting O ffice (GAO) investigators. In a critical 1991 report, GAO noted:

FDA lacks assurance that such [bottled water] tests are done correctly or that the results are reliable. FDA regulations specify that either " qualified bottling plant personnel" or "competent commercial laboratories" use approved wa ter quality test methods...[but] has not defined qualified personnel or competent labora tories, and it does not require that such personnel or laboratories be certified or othe rwise establish their qualifications to do the required tests. In contrast, for public drinkin g water, EPA requires certified laboratories.... [165]

Even after this GAO report, FDA has twice refused t o require that water bottlers use approved certified laboratories(even when the IBWA petitioned FDA to require them. In 1993, FDA argued:

the Act does not provide a basis for these [lab] ap provals. Moreover, the act does not provide authority to the agency to require such app roval. Further, even if such authority were provided by the Act, FDA lacks the resources t o monitor analytical laboratories and personnel in the absence of a significant public he alth problem. [166]

FDA reiterated this position in 1995. [167]

We disagree with FDA's narrow reading of the law as not authorizing such certification. For example, FFDCA Chapter IV and section 701 provi de broad authority to FDA to promulgate such a requirement. [168] FDA takes the position that under its authority un der the FFDCA, it can legally require bottlers to use c ompetent commercial laboratories, but

for reasons that are not supported, FDA contends th at it lacks legal authority to dictate that bottlers must use a certified lab.

In addition, even if FDA did not enjoy the authorit y to mandate use of certified labs before 1996, Section 410 of the FFDCA as amended by the 19 96 SDWA amendments seems to clearly support such a requirement. That newly revi sed provision of the FFDCA expressly authorizes FDA monitoring regulations for bottled w ater and makes EPA's tap water rules -- apparently including the EPA's certified-lab requ irements -- automatically apply in the case of FDA inaction. [169] If, indeed, FDA still believes it lacks the legal authority to require certified labs, FDA should ask Congress for such au thority.

With respect to resource constraints, FDA could ask Congress for additional resources for the bottled water program. As suggested in the reco mmendations in Chapter 1, a one-cent-per-bottle fee on bottled water would ease the FDA resource problem. In addition, it would require no expenditure of FDA resources whats oever for FDA simply to require that the labs used to test bottled water be EPA-certifie d (or state-certified with EPA approval) for drinking water testing. This is a commonsense s olution that FDA apparently refuses to consider for reasons that are not entirely clear.

While tap water system operators must be trained an d certified, bottlers need not be. Under the Safe Drinking Water Act amendments of 199 6, tap water suppliers' operators must receive training and be certified as competent to treat water by EPA-approved state authorities, pursuant to federal guidelines for det ermining the level of competence needed. [170] This requirement is widely viewed as an important development, because it will begin to ensure that opportunities for operator err or -- often the cause of serious contamination problems and even disease outbreaks i n tap water systems -- will be reduced.

Although the IBWA petitioned FDA to require certifi cation of bottling-plant supervisory personnel, FDA denied this petition in 1993. [171] FDA reiterated its denial in 1995. [172] As in the case of certifying labs, FDA argued that it lac ked the authority and the resources to require such certification of bottling-plant person nel.

Again, we disagree on both points; FFDCA Chapter IV and in particular sections 410 and 701 provide FDA with ample authority to require pla nt personnel to be competent, particularly in light of the 1996 SDWA amendments' incorporation by reference of EPA's National Primary Drinking Water Regulations to bott led water in cases of FDA inaction. On the issue of resources, creative solutions are avai lable, including asking Congress for funds, establishing a per-bottle fee, and/or using independent, FDA-certified trainers and certifiers (such as state or third-party certificat ion organizations using FDA training and certification guidelines).

FDA's source water approval requirement is essentia lly meaningless. Theoretically, under FDA rules, the source of bottled water must be appr oved by state or local authorities. [173] FDA's description of what is required to be an appr oved source is sketchy: It "means a source of water...that has been inspected and the w ater sampled, analyzed, and found to be of a safe and sanitary quality according to appl icable laws and regulations of state and local government agencies having jurisdiction." [174] There are no guidelines for what is required of these state and local rules, nor is the re any explanation of what should be done if there are no state or local rules or jurisd iction.

In discussing why the public should feel comfortabl e with bottled water quality, the bottled water industry often cites this FDA regulatory requ irement for source approval. For example, IBWA's widely disseminated fact sheet for consumers notes:

While bottled water originates from protected sources (75 percent from underground aquifers and springs), tap water comes mostly from rivers and lakes....

[B]ottled water companies are required to use approved sources . There are two types of sources from which bottled water can be drawn: the first type is natural sources (i.e., springs and wells). By law, these sources must be protected from surface intrusion and other environmental influences. This requirement en sures that surface contaminants such as Cryptosporidium and Giardia are not present.

The second source water type is approved potable municipal supplies.... [175]

This highly touted FDA-approved-source requirement is, however, in the words of one study, "a regulatory mirage." [176]

There are no specific requirements in FDA rules for protection of bottled water sources from pollution sources (such as setbacks from hazar dous-waste dumps, industrial facilities, septic tanks, or underground gasoline s torage tanks), nor are there any specific rules for disapproval of sources once they become c ontaminated. In fact, there are no requirements for bottlers or state or local authori ties even to evaluate or document whether any such potential contamination sources ma y exist. In addition, in 1990, government investigators reviewing bottler records found that 25 percent of the bottlers audited had no documentation of source approval. [177]

This contrasts with requirements for city tap water . Under the 1996 SDWA amendments, states are required to conduct a source-water asses sment for public drinking water supplies (i.e., tap water). [178] The assessment is required to delineate the bounda ries of the assessment area that supplies the water system and to evaluate known or potential sources of contamination and the susceptibility of the drinking water source to contamination. [179] Millions of dollars in federal funding were made a vailable to conduct these assessments.

In the case of bottled water source approvals, howe ver, NRDC's investigation has noted cases in which the source of bottled water either w as never assessed by authorities or the assessment overlooked important nearby contaminatio n sources. In such cases, the source is anything but "protected" from contaminati on. Even in a state with a relatively well-developed bottled water program, like Massachu setts, the source-approval process apparently is essentially pointless. For example, a s discussed in Chapter 3, the Millis well, in an industrial parking lot in Massachusetts near a state-designated hazardous-waste site, for several years supplied contaminated water to several major bottlers and was an approved source. [180] If even in an extreme case, such as the Ann & Hope well in Millis, the well meets the "approved source" requirement, the F DA rule appears to have no meaning. Indeed, in our review of scores of bottlers' files maintained by several states, we found no case in which source approval was denied or revoked. In the Millis Well Case, the state said it would allow continued use of the source, de spite past contamination, if the water were subject to treatment; apparently the well is n o longer used for bottling water.

4. Bottlers may violate FDA standards if the label notes that the water "contains excessive chemical substances."

The problem with FDA bottled water standards is not limited to the gaps in their coverage or lack of certified labs. Many people are stunned to learn that even if bottled water is

more contaminated than FDA's standards would otherw ise allow, FDA rules (and those of many states) explicitly still allow the water to be sold. The contaminated water may be marketed so long as it says on the label "contains excessive chemical substances" or "contains excessive bacteria" or includes a similar statement on the label. [181] For example, as discussed in the accompanying Technical Report , (print report only) the state of New Jersey found that Fuentes De Cutolo Spring Water co ntained nitrates at elevated levels that exceeded the FDA and state standards (as noted in our discussion of nitrates' health effects in Chapter 3 and the Technical Report (print report only), nitrates can cause blue-baby syndrome in infants if consumed at levels in e xcess of standards). Rather than taking an enforcement action, the state "requested that this firm either reduce the level of nitrate by treatment or change the product label to include a statement 'contains excessive nitrate'" on its label. [182]

In fact, in a 1996 Federal Register notice, FDA sent clear signals to the industry tha t if a bottler violates FDA standards, in some cases FDA i s prepared to take no action so long as the bottle includes such a statement. Responding to industry concerns that bottled water that meets chemical-contamination standards i n Europe might violate some proposed FDA rules, FDA pointed out that:

if a bottled water product...exceeds an allowable l evel for a particular contaminant...the bottler can still market that product, provided tha t the labeling bears a statement of substandard quality -- e.g., if it exceeds the allo wable level for thallium, the labeling shall state either "Contains Excessive Thallium" or "Cont ains Excessive Chemical Substances".... Therefore, should a European or Ame rican bottled water product exceed the allowable levels of contaminants, it still can be marketed in the United States if its labeling bears the prescribed statement of those co ntents. [183]

FDA suggests that it may enforce against such labeled contaminated water if it finds that it is "injurious to health" and thus "adulterated" [184] -- but there is no requirement that such contaminated bottles even be reported to FDA, and w e have been able to find no cases of FDA having taken any enforcement action against any such bottlers.

5. Bottlers are not required to report test results or violations and may dispose of records after two years; tap water s uppliers must report results and retain records.

Under EPA rules, tap water suppliers must report th eir monitoring results and any drinking water standards violations that occur to EPA or, if the state has obtained formal EPA approval to exercise "primary enforcement authority ," the water system must report to the state. [185] If there is a serious violation, it must be report ed to the state within 48 hours. [186] The state then must report results and violations t o EPA, [187] and EPA then posts all violations on the Web for easy public access. In ad dition, tap water suppliers must keep on hand their bacterial testing results for 5 years , and their chemical tests for 10 years, to allow effective EPA and state inspections. [188]

In contrast, FDA rules include no provision obligat ing a bottler to notify FDA or a state of test results, contamination problems, or violations , even in the case of contamination that could pose a serious health threat. FDA has refused to require such reporting when called upon to do so during rule-making proceedings. [189]

Answering both criticism of this lack of reporting and questions about how it can effectively track bottler compliance without report ing of test results, FDA said it "does not have the resources to review bottled water test res ults except during FDA plant inspections." [190] As noted below, however, such FDA inspections are quite rare (every four to five years or less frequently). Moreover, FDA re quires bottlers to retain their testing records for just two years [191] -- unlike the 5 year/10 year EPA tap water supplie r requirement. [192] This means that since FDA inspections are so rare, many contamination problems may never come to FDA's attention, because the record of the event can be discarded before FDA ever reviews the bottler's rec ords.

As GAO has pointed out, such record retention can b e critically important "to allow regulatory officials to (1) review historical test data to verify that the tests were done, (2) gain insight into a particular or recurring problem , and (3) learn of and respond to contaminated water problems." [193]

This lack of reporting combined with other shortcom ings in FDA's program pose serious problems for enforcement and compliance monitoring. For example, FDA does not maintain an inventory of water bottlers or shippers , so it often must rely upon state authorities for such information. [194] But state programs vary widely, with some having f ew if any resources dedicated to tracking bottled wate r (see the state programs section , later in this chapter.) Without an inventory of bottlers or reporting of testing results or violations, it is logistically difficult, to say th e least, for FDA to adequately track bottler compliance.

6. Bottlers are not required to test water after st orage, when it may have increased contamination levels, nor are they r equired to list the bottling dates for their water.

FDA's rules require weekly bacteria testing and ann ual chemical testing, but this testing is generally done of water at the bottling plant. [195] There is no requirement that bottlers test water after shipping it to stores or after storage. Moreover, FDA has refused requests to require bottlers to place a bottling date on their bottled water, or to require a label suggesting that consumers refrigerate their water a fter opening to retard bacterial growth.

This is problematic in light of the investigations discussed in earlier chapters of this report indicating that HPC bacteria, Pseudomonas aeruginosa , algae, and other microbes that may be present only at very low (or nondetectable) levels immediately after bottling can bloom and grow after bottling. The "FDA acknowledge s that some bacteria can grow in bottled water, and that bottled water, unless treat ed in some manner, is not sterile." [196] But such post-bottling microbial-growth problems are mi ssed under standard "at the bottling plant" testing under FDA rules.

Moreover, if there is no bottling date for bottled water, and no consumer warning to refrigerate after opening, the regrowth in the bott le could become substantial. FDA admits that "[a]dditional bacteria may enter a bottle of w ater with exposure to air" but argues that bottled water "is not a good source of nutrients fo r most microorganisms" so no precautions such as date of bottling or refrigerati on warnings are needed. [197] As discussed at length in the Technical Report (print report only) on microbial contamination, however, there are several studies documenting regr owth of Pseudomonas and other organisms occurring in bottled water after bottling that make it difficult to accept this unsupportable FDA reassurance. [198]

Similarly, as discussed in Chapter 3 and the Technical Report (print report only), several plasticizers and other plastic reactants or by-prod ucts can migrate from bottles into the water with time. Some studies indicate a steady inc rease with time of certain cancer-causing and other contaminants in bottles as the bo ttle slowly leaches out the chemical into the water. Again, if the water is tested only immediately after bottling, such problems will likely never be detected.

FDA Places a "Low Priority" on Bottled Water: Resources Are Extremely Limited, Inspections and Enforcement Are Rare

FDA has repeatedly stated that bottled water is low on its priority list. FDA says that "bottled water products are a relatively low public health problem," [199] and "[i]n this program bottled water plants generally are assigned low priority for inspection....When compared to products such as low acid canned foods. ..bottled water products must take a back seat." [200]

Indeed, according to FDA staff estimates, the agenc y has dedicated just one half of a staff person (full-time equivalent) to bottled water regulation , and less than one to ensuring bottled water compliance. [201] Because of this low priority, water bottlers can e xpect to be FDA inspected on average every four to five years o r less frequently. [202] GAO found that "FDA inspected about half of 410 domestic bottlers only once in 5-3/4 years." [203] FDA recently has confirmed that inspections are no more frequent today than they were in 1991, although FDA funds occasional state "contract inspections.". [204]

In 1995, FDA refused an IBWA petition asking for an nual FDA inspections of bottlers, citing low priority and lack of resources. [205] As the GAO has pointed out, however, inspecting once every five years or less often is f ar too infrequent to detect certain possible problems. For example, contamination probl ems may come and go depending on conditions in the source water, on pumping patterns , bottling-plant operation and maintenance practices, etc. Since testing and other records are required to be kept only for two years, there is no requirement to report te st results to FDA, and FDA inspects only once every four to five years or less often, it is quite possible that many contamination problems are never detected by FDA.

Moreover, GAO investigators found that when FDA doe s do inspections, often FDA relies upon the results of the bottlers' self-testing rath er than doing independent testing of its own. Even when FDA does do independent testing, it often checks for just a handful of contaminants out of the scores for which FDA rules require monitoring. GAO found that FDA tested for five or fewer contaminants in 94 per cent of the FDA tests they reviewed. [206] FDA staff recently admitted there likely has been n o major change in testing and inspection practices since the GAO investigation. [207]

Finally, FDA does not inspect foreign bottlers, so the compliance of those bottlers with FDA testing and good-manufacturing-practice require ments is uncertain. [208]

State Bottled Water Programs Lack Resources and Regulatory Standards, and in Some Cases Are Virtually Nonexistent

State programs range from well developed to nonexis tent

NRDC conducted a detailed survey sent to all 50 sta tes' bottled water programs, summarized in Appendix C. As a result, we have lear ned that while some states, such has California, Massachusetts, New Jersey, Texas, and W ashington have bottled water programs that are relatively well developed, other states have no or virtually no program. Most have not adopted the IBWA model code, some hav e not adopted all of FDA's standards, and most have few resources dedicated to implementing the program. This makes FDA's heavy reliance upon state programs subj ect to question.

States are under no legal obligation to adopt the F DA bottled water standards. In fact, FDA has no formal system to track the adequacy of state regulations, inspection results, enforcement, source-water approvals, or other aspec ts of state bottled water programs. In response to questions from NRDC, FDA could not answ er even the most basic questions, such as how many states have adopted FDA standards, nor does FDA maintain its own inventory of all water bottlers. This means that of ten, if not most of the time, bottled water regulation falls to the states, some of which, as n oted below, are ill equipped to take on this role.

State resources

The lack of state resources for bottled water is a major problem. Among the 50 states and the District of Columbia, 13 states told NRDC that they have no resources, staff, or budgetary allotments specifically earmarked to impl ement the state bottled water programs. [209] In addition, 26 states reported having less than one full-time staff equivalent (FTE) dedicated to running the state's bottled wate r program. Only seven states reported having one or more full-time staff people dedicated to implementing and maintaining the state's bottled water program. [210] This makes FDA's heavy reliance upon state program s problematic.

As is detailed in Appendix C, state bottled water p rograms range from being stricter than FDA's requirements in some areas (e.g., California, Georgia, Montana, New Jersey, New York, Pennsylvania, Texas and Vermont), to proudly proclaiming that they are less strict than federal rules. A few examples of states with l ess developed programs include:

• Alaska, which reports that it does not require bot tlers to conduct annual testing for chemical and radiological contaminants [211] (despite FDA rules requiring such annual monitoring.

• Arizona, which reported to NRDC that "the State of Arizona does not currently regulate the bottled water industry." [212] The state says local county health departments have some authority to do so, and that it relies on FDA to deal with interstate water.

• Delaware, which conducts no active regulatory over sight of the FDA's requirements, nor does it have a permit program. De laware has no separate state code addressing bottled water and says it has no bo ttlers in the state.

• Illinois, which has no state certification or perm itting process. Moreover, the source of bottled water is inspected by the state o nly upon request by the bottler (i.e, no mandatory testing of source waters). Occas ionally, however, health inspectors may inspect bottlers as part of an inspe ction of an otherwise-regulated facility (such as a restaurant or hotel).

• Indiana, which does not have a separate state code regulating bottled water processing, does not certify sources and does not h ave a state permit or licensing program.

• Kansas, which has no separate state regulations an d no permit program. In a recent telephone interview, a Kansas state official reported that "Kansas has no statutory authority to issue permits, licenses, or certificates for bottled water processors, plants, or distributors." [213]

• Missouri, which regulates microbiological contamin ants in bottled water and inspects bottled water plants but does not regulate chemical and radiological contaminants -- despite FDA rules requiring such an nual monitoring. [214]

• North Dakota, whose Health Department reported to NRDC that "State regulations are far less stringent tha[n] those administered by " FDA. The Health Department also reported that "no enforcement actions" have be en taken by the state in the past four years, that "no documented violations or data [are] available," and that "very little, if any, bottled water is tested by ou r agency. I know of no other State agency that tests bottled water." [215] Additionally, the state does not require bottlers to submit source analysis prior to initiating bottl ing operations.

• Texas, whose bottled water program, while stronger overall than that of many states, has less than one FTE dedicated specificall y to the state's bottled water program. Texas reports that there are currently mor e than 300 bottlers operating within its borders. [216]

• Utah, which does not currently approve sources and does not have a permitting program for water-bottling facilities.

• Virginia, which does not certify sources, nor does it have a permitting program. Virginia reports that it is not "empowered to permi t or license." [217]

Thus, it is apparent that some states have put few if any resources into their bottled water program. FDA's reliance upon state programs to assu re compliance is, in many states, misplaced.

There are noteworthy exceptions to our general find ing that state programs lack the necessary resources and programs to justify FDA's r eliance. Encouragingly, a handful of states seem to have placed a greater priority on ma king sure that bottled water is

consistently safe, healthy and free of contaminants for consumers. In addition, some states, while not necessarily imposing strict and c omprehensive bottled water programs across the board, have adopted small but significan t advances that may help to improve bottled water protection at least somewhat.

States that have adopted at least some progressive regulatory innovations include:

• California, which has adopted stricter regulations for many contaminants than FDA, including lower allowable THHM levels and toug her disinfection rules, and has a fairly well developed regulatory program. Mor eover, California citizens have adopted Proposition 65, a law that requires, among other things, that those doing business in the state must provide a clear and reas onable warning if they or their products expose people to toxic chemicals. This law applies to bottled water as well as to other consumer products.

• Florida, which reports that it has two full-time s taffers dedicated to its bottled water program and has its Food Laboratory collect a nd analyze random samples of bottled water off retail food shelves. However, the state does not routinely publish the results of its testing to consumers.

• Louisiana, which samples end product every three m onths, from both in- and out-of-state bottlers. As in Florida, however, Louisian a does not publish its test results to inform consumers.

• Maine, which, in addition to following FDA labelin g rules requiring that finished-product bottled water violating FDA standards must say so on the label, also requires that contaminants that exceed maximum cont aminant levels (MCLs) in the source water be listed on the label. Although the state does no t require that bottlers list analytical results on the labels (mak ing this optional at the prerogative of the bottler), it does require that a bottler lis t on its label any altered water quality.

• Maryland, which requires that bottlers conduct an EPA primary drinking water analysis of its source.

• Massachusetts, which publishes an annual public re port that summarizes the bottler-filed bottled water quality testing results . The report can be misleading, however, because in many cases it does not mention known contamination incidents.

• Mississippi, which tries to sample each bottled wa ter product sold in the state on a monthly basis for E. coli . and other bacteria.

• Montana, which requires that all in-state bottlers become Public Water Systems and meet EPA drinking water standards prior to star t-up.

• Nevada, which requires that a bacteriological anal ysis be submitted every week to the Department of Human Resources, Health Division, if a plant is in full operation.

• New Jersey, unique in its requirement that a bottl er list a two-year expiration date (from time of bottling) on its label, also mandates by state statute that an annual enforcement/violation report be compiled and submit ted to the state legislature.

New Jersey also conducts a limited number of "spot checks" of bottled water sold and produced within the state.

• Ohio, which requires that any additives to bottled water be listed on labels.

• Texas, which in addition to having stricter standa rds and more frequent inspections than FDA, also requires source labeling and certification of operators under its unique Bottled Water Certification Progra m. Under the program, bottlers are required to attend training/awareness courses s ponsored by the state and earn different "grade" levels (grade A being the most st ringent) based upon number of classes attended and years in operation. Texas also requires that bottlers resubmit a water-quality analysis annually to an EPA certifi ed lab in order to renew licenses (unless source is municipal).

• Vermont, which has more stringent testing regulati ons and labeling requirements than FDA. Vermont requires that the source, the nam e and address of the bottler, and finished-product levels of arsenic, lead, sodiu m, and nitrates be listed on bottled water labels.

• West Virginia, which has more stringent reporting requirements than FDA: Bottlers must test weekly for bacteriological contaminants a nd submit their reports to the state agency by the 10th of each month. Additionall y, West Virginia requires that the source be protected from outside contamination at the point of discharge and the draw area.

• Wisconsin, which requires, by statute, publication of an annual bottled water quality analysis report. This report evaluates only about a dozen waters sold in the state, however. There are about 24 bottlers in Wisc onsin and many more waters imported from out of state.

.

State regulatory programs, such as those just liste d, that have attempted to innovate or to "put some teeth" into both federal and state regula tions are to be applauded. Not all state regulatory agencies are provided the resources or l egislative authority to implement all of the innovations just described, and many agencies a re constantly being challenged to make less do more. Yet, several of the innovations require a relatively low investment of time and state funds, and could be adopted with min imal additional demands on state resources.

One good example of a low-cost, high-return regulat ory innovation is the requirement adopted by several states that bottlers submit copi es of state and/or federally mandated water-quality tests to the appropriate state agency on a weekly, monthly, or yearly basis rather than merely requiring that bottlers keep cop ies on hand at the plant. Similarly, additional contaminant disclosure labeling requirem ents to require public information about contaminants in the water, have a beneficial effect and carry out the public's right to know. Such requirements, while not compelled under federal regulations, would go a long way in flagging potential health risks early on, wh ile at the same time would provide an obvious incentive for bottlers to remain in complia nce with the regulations. Certainly, some of these or similar types of programs are wort h consideration by other states when the payoffs are less risk to the consumer and more compliance with the law.

No guarantee of compliance with FDA requirements

Even in states that have adopted FDA standards, the re is no assurance that the states are actively enforcing those standards. For example, Al aska has adopted bottled water standards that generally are equal to EPA drinking water standards, in addition to codifying IBWA and FDA standards. Curiously, howeve r, the state of Alaska has unilaterally decided it will not require annual bot tlers to conduct chemical and radiological contaminant testing as required under FDA's regulat ions. Calling such tests "expensive and not necessary," [218] Alaska has decided it will not require these tests . While it is commendable that the state of Alaska generally has adopted strict regulations for its bottled water, we fail to see the logic (or legalit y) in openly flaunting a critical portion of the FDA's bottled water regulatory requirements.

It is unclear how many states have unwritten polici es of not enforcing part or all of their own or FDA's rules. Such disregard for a federal re quirement is unsettling and sets a poor example for other states, which may, in the same sp irit as Alaska, simply choose to disregard other vital parts of the federal requirem ents. FDA relies upon voluntary compliance with federal requirements and has dedica ted no resources to auditing or evaluating state-program performance. Unfortunately , in light of the minimal FDA resources dedicated to the bottled water program, w e cannot afford to allow the states to pick and choose which federal requirements they are willing to comply with.

Nonregulated bottled waters

State adoption of FDA regulations becomes especiall y important when one considers that even the FDA regulations for bottled water have hug e gaps through which contaminated waters can easily flow. FDA says its rules do not a pply to intra state bottled waters (water that is bottled, sold, and distributed entirely wit hin the borders of any one state), nor do they apply to seltzer water, carbonated water, flav ored water, and certain other waters noted earlier. There are currently no specific stan dards (i.e., no required contaminant testing or water-quality standards) that cover the processing, testing, or distribution of these categories of bottled waters.

While many states have adopted their own standards to cover intrastate bottled waters, either by separate state code or by voluntarily ext ending the FDA regulations to intrastate bottlers, three states (Delaware, Indiana, and Kans as) and the District of Columbia have not adopted their own regulations to cover such wat er. Moreover, only 35 percent (18 out of 51 states and the District of Columbia) regulate seltzer, carbonated, and/or flavored waters under either the FDA standards or their own state standards. The undeniable conclusion from these statistics is that, although some states have taken the "extra" steps to ensure that all bottled water is subject to cruc ial contaminant testing (even where not required under federal law), many states have not. There remains an entir e category of bottled water actively being distributed to and con sumed by the general public that is not subject to any required testing at all in most stat es.

Source listing and labeling requirements

Only 14 states currently require source listing on the labels of bottled water products. [219] Other states reported having various other labeling requirements in addition to the FDA

requirements, mostly aimed at prevention of misbran ding. [220] Interestingly, Maine and Texas require bottlers to list contaminants if the source or end product exceeds maximum contaminant levels (MCLs). With the exception of th e states just mentioned, no other states have any requirements for source or contaminant listing on the labels of bottled water beyond FDA requirements.

Few enforcement actions

FDA generally relies on the states to enforce feder al bottled water regulations. Information gathered by NRDC over the last several years from F DA and state agencies charged with enforcing the federal regulations, however, indicat es that few, if any, serious enforcement actions have actually been instituted by the states . Of the 50 states and District of Columbia, only about half [221] report having taken any enforcement action in the past four years, and most of those were in the form of warnin g letters from the appropriate state agency requesting that bottlers come into complianc e with regulatory requirements. Only a handful of states reported having to shut down bo ttlers or enforce involuntary recalls in the last four years.

Optimistically, the lack of enforcement actions cou ld mean that all bottled water processors are virtually always in full compliance with all federal and state testing and health requirements. Yet experience and common sens e, as well as our review of state records in some states that gave us access under fr eedom-of-information laws, point toward a different, less optimistic reality. The sc arcity of state resources dedicated to implementation and enforcement of federal and state bottled water regulatory programs lends significant support to the suspicion that the lack of serious enforcement actions is due, in large part, to extreme shortages in state r esources for enforcement purposes, rather than lack of violations.

Violation data "unavailable"

Unfortunately, it is nearly impossible to confirm o r deny such suspicions. This is predominantly because data on the number and scope of bottled water violations are either not reported or are unavailable to the publi c in all but 10 of the states. [222] If such violation data were available, a truer picture of t he enforcement-to-violation ratio could be compiled, by conducting a relatively simple compari son between the number and scope of enforcement actions in any given state with the num ber and scope of reported violations.

Without violation data, we are left in somewhat of a void when it comes to rating the quality of enforcement, having only half of the sto ry on which to base our conclusions. Computerized databases would greatly facilitate bot h record keeping and public access to violation data, and, subsequently, increase account ability of violating bottlers and state enforcement divisions alike. Some states (such as G eorgia, Missouri) are to be applauded for developing databases or working toward that end . Most states, however, are unable or unwilling to provide summaries of violations.

State permit programs

It is encouraging that most states report that they have developed and maintain a state permitting or licensing program for bottled water p rocessors. State licensing programs can vary widely from state to state but serve an im portant function in the battle against compromised bottled water quality. State-issued per mits can be a powerful regulatory tool (oftentimes the only enforcement tool used).

As one state official observed, state licensing pro grams "provide control and leverage both administratively and to the regulatory scheme. " [223] Nearly all the states require that bottlers, prior to being issued a license or permit , submit a water quality analysis for both source and end product that is at least as stringen t as the FDA requirements. While most permits must be renewed annually, some do not need to be renewed or have renewal periods of three or more years. Notably, California , New Hampshire, New Jersey, New York, Ohio, Rhode Island, Texas, and West Virginia require that a water-quality analysis be resubmitted every year as a prerequisite to license renewal. Yet, even though state licensing is one of the few tools states have at th eir disposal with proven compliance-forcing clout, nine states and the District of Colu mbia have not adopted permitting or licensing programs for bottled water processors (De laware, Illinois, Indiana, Kansas, Michigan, North Carolina, South Dakota, Utah, and V irginia).

State programs may bend to bottlers' political influ ence

In addition, even a state that has a well developed program apparently may bend to political pressure from major bottlers. For example , in Massachusetts, Dr. Elizabeth Bourque, a biochemist who for many years ran the st ate's bottled water program, made a name for herself as an aggressive bottled water reg ulator.

As noted earlier, the Ann & Hope company's well in Millis, which provided water for several brands of bottled water, became contaminate d with industrial chemicals, including trichloroethylene at a level above EPA and FDA stan dards. Dr. Bourque insisted that strict controls be imposed. [224] She also demanded that when a product from major b ottlers, such as Perrier's Poland Spring water, contained hi gh levels of HPC bacteria or chlorine, that action be taken. [225]

After many such aggressive interventions, Dr. Bourq ue was asked by her supervisors to stop working on these important problems and to ins tead focus on other work. She did not relent. However, after industry complaints to the M assachusetts Department of Public Health (MDPH) management, and a December 5, 1996, m eeting of Nancy Ridley, MDPH Assistant Commissioner, attorneys from a blue-chip Washington, D.C., law firm (representing Perrier), and an official from a bott ler that used Ann & Hope water, Dr. Bourque was reassigned to other duties. [226] She also received a written "gag order" that prohibited her from speaking about bottled water to the press, water-analysis labs, federal, state, or local agencies, or bottlers. [227] She and the union that represents state employees protested, alleging that the reassignment was punit ive, but got nowhere. [228] State officials maintain that the reassignment was not punitive and was unrelated to any discussions with bottled water companies. Dr. Bourque recently retired.

An investigation by Senator Cheryl Jacques, a state senator who represents Millis, ensued. Senator Jacques' request for all state reco rds relating to the Ann & Hope affair was responded to incompletely, with several key doc uments apparently not provided to the senator. [229]

It is difficult to know or to document how widespre ad the bottled water industry's political arm-twisting may be. Still, it appears clear that e ven in states with relatively comprehensive programs for bottled water, there may be serious limitations to state regulators' ability to vigorously implement the law .

Conclusions about state bottled water programs

A close look at the results of the NRDC surveys of states' bottled water programs makes it difficult to share FDA's confidence in the states' ability to ensure compliance with federal requirements, especially when some states lack even rudimentary permit programs. The reality is that, with few exceptions, state program s lack the necessary resources to provide adequate oversight and enforcement of the s tate and federal regulatory scheme.

By and large, most state programs appear to be afte rthoughts, tacked onto the backs of other state regulatory programs, with little, if an y, staff and resources dedicated to ensuring acceptable, healthful bottled water qualit y. Without the deterrent of consistent, tough rules and meaningful enforcement, water bottl ers have little incentive to comply with either federal or state requirements.

Our review of bottled water quality in previous cha pters suggests that some bottled water is not of the highest quality. It is likely that a significant amount of bottled water is being consumed without having been subjected to proper an d adequate quality testing, putting consumers' health at potential risk. This might not be occurring if states in fact had sufficient resources dedicated to bottled water pro grams. Moreover, even in states with resources dedicated to bottled water, such as Massa chusetts, it is important that meaningful outside oversight take place so powerful political interests or bottlers cannot bend the state agencies to their advantage.

Voluntary Industry Standards, While Commendable, Are No Substitute for Enforceable Health Protection Standards

The International Bottled Water Association (IBWA) has long sought to encourage the industry (particularly the self-proclaimed 85 perce nt of the industry IBWA claims as its members) to comply with the IBWA model code, and to accept annual inspections by IBWA's contractor NSF International.

While these voluntary industry efforts are commenda ble, they cannot be viewed as an effective substitute for a strong and enforceable f ederal regulatory program. IBWA itself seems to have recognized this fact in that it has o ften petitioned FDA to adopt the IBWA Model Code and other important regulations.

The problems with FDA's and the industry's heavy de pendence and faith in the effectiveness of the IBWA voluntary standards are m any:

• Voluntary standards apply only to those who agree to them--that is, members of the industry who choose to be IBWA members. By IBWA 's count, about 15 percent of the industry does not belong to the organization .

• Industry members who choose to leave IBWA to avoid compliance with the IBWA standards suffer no real consequence.

• Many companies bottle water (such as seltzer, spar kling, or other water) that is not covered under the narrow definition of "bottled wat er" adopted by FDA rules and the IBWA Model Code. Thus, these waters are exempt from the voluntary industry standards and are not subject to the specific FDA c ontaminant standards that apply only to "bottled water" (as that term is narr owly defined).

• While some states (according to IBWA, about 16) ha ve adopted the IBWA standards as binding and enforceable, most states h ave not done so.

• The inspection results after NSF inspections are n ot shared with regulators or the public, so it is impossible to determine how effect ive these inspections and IBWA standards truly are.

Thus, while the voluntary industry efforts are help ful, they cannot be a substitute for regulatory controls.

Chapter Notes

4a. Some observers have noted that all of the bottl ed water sold in the United States today is part of a stream of interstate commerce that begins with the extraction of the raw material for the bottles, often out of state, continues with the manufacture of the bottles, labels, caps, and s hipping materials, moves on to the bottling facilit ies and the water extraction itself, the shipping of the water, and u ltimately the sale of the water. Each of these step s in producing, packaging, and shipping water generally involves in terstate commerce, and individuals who buy water bo ttled and sold in one state may be from out of state. In addition, any problem with the water (such as illnesses) cle arly could directly affect interstate commerce. Interestingly, the IBWA has implicitly argued that FDA's jurisdiction exte nds to intrastate sales of bottled water. At a congressional hearing at which the inapplicability of FDA rules to intras tate sales was noted, IBWA's then-CEO said:

a statement was made this morning which might be co nfusing, and that is that most bottled water is not in interstate commerce. To the contrary, most bottled water is, b ecause most of the products that are used in the bo ttled water plants, the bottles, the resin, the coolers, the ca ps, and labels all come from somewhere else, so in the strictest interpretation, interstate commerce is involved in just about all of our products. Statement of William Deal, CEO, IBWA, in "Bottled W ater Regulation," Hearing of the Subcommittee on Ov ersight and Investigations of the House Committee on Energy and Commerce, Serial No. 102-36, 102nd Cong., 1st Sess ., p. 107 (April 10, 1991). Therefore, to the extent FDA has interpr eted its jurisdiction over bottled water to include only water that crosses state boundaries, some have argued that FDA 's interpretation is unduly narrow.

4b. Acrylamide and epichlorhydrin are chemicals som etimes used in drinking water treatment. EPA requir es that any public water system using these chemicals must meet a "treatment technique" intended to ensure safe us e of these chemicals. FDA has adopted no such requirement.

4c. 40 C.F.R. § 141.30. These tap water monitoring requirements (except for THMs) can sometimes be red uced in frequency for some small systems, or others that th e state finds have been demonstrated not to be vuln erable, and that did not detect the contaminant in initial rounds of monitoring. See 40 C.F.R. §§ 141.24 & 141.61(a); see also Safe Drinking Water Act § 1418 (granting monitoring relief in cer tain cases to small public water systems).

4d. Both EPA and FDA require annual or less frequen t testing for most inorganic contaminants. see FDA rules at 21 C.F.R. § 165.110, and EPA rules at 40 C.F.R. § 141. 23(c). Additionally, Congress mandated in 1996 that unless FDA issued standards for nine contaminants (antimony, berylliu m, cyanide, dioxin, diquat, endothall, glyphosate, nickel, and

thallium) by August 6, 1998, EPA's tap water standa rds for these chemicals (including testing requirem ents) would automatically apply to bottled water. In May 1998, FDA issued a direct final rule stating it would app ly EPA tap water standards for these contaminants in response to thi s mandate. 63 Fed. Reg. 25764 (May 11, 1998). That rule said, however, that rather than tracking EPA's tap water testing regime, FDA would set the monitoring frequency at once per year (instead of following EPA's rules requiring qu arterly testing for some organics, and annual or so metimes less frequent testing for inorganics). Because water bot tlers objected to some of these monitoring requirem ents as burdensome, FDA stepped back, saying it could not f inalize the monitoring provisions in light of "sign ificant adverse comments," and instead allowed the law to automatic ally impose the monitoring by the EPA tap water rul es. The EPA (and now FDA) testing rules also allow waivers -- a provision FDA has not yet explained whether it wil l use. Thus, how FDA intends to implement the monitoring requirement s for these contaminants is murky. See 63 Fed. Reg. at 42198-99 (August 6, 1998).

Report Notes

103. Statement of William Deal, CEO, IBWA, in "Bott led Water Regulation," Hearing of the Subcommittee on Oversight and Investigations of the House Committee on Energy and Commerce, Serial No. 102-36 , 102nd Cong., 1st Sess., p. 108 (April 10, 1991).

104. Ibid. p. 112.

105. IBWA, "Frequently Asked Questions About Bottle d Water," (available at www.bottledwater.org/faq.ht ml), (printed 11/20/1998).

106. Ibid. (emphasis added)..

107. FFDCA § 410, 21 U.S.C. § 349 (1995); later ame nded by § 305 of the SDWA Amendments of 1996, Pub. L. 104-182 (August 6, 1996).

108. Ibid.

109. Senate Environment & Public Works Committee, Safe Drinking Water Act Amendments of 1995: Report of the Committee on Environment and Public Works, United S tates Senate, on S. 1316, Report No. 104-169 , 104th Cong., 1st Sess., p. 96 (November 7, 1995).

110. "Bottled Water Regulation," Hearing of the Subcommittee on Oversight and Invest igations of the House Committee on Energy and Commerce, Serial No. 102-36 , 102nd Cong., 1st Sess. (April 10, 1991); General Accounting Office, Food Safety and Quality: Stronger FDA Standards and Over sight Needed for Bottled Water, GAO/RCED-91-67 , pp. 16-17 (March 1991).

111. FFDCA § 410, 21 U.S.C. § 349 (1997).

112. Ibid.

113. The FDA bottled water rules are codified at 21 C.F.R. parts 129 and 165 (1997).

114. Personal Communication with Terry Troxel and S hellee Davis, FDA, September 18, 1997.

115. Personal Communication with Ron Roy, FDA, comp liance programs, November 20, 1998.

116. See, e.g., NRDC, Think Before You Drink (1993); NRDC, Victorian Water Treatment Enters the 21st Century ( 1994); NRDC, The Dirty Little Secret About Our Drinking Water (1 995); NRDC, You Are What You Drink (1995) , NRDC, USPIRG, and Clean Water Action, Trouble on Tap (1995) .

117. Statement of Frank Shank, Director, FDA Center for Food Safety and Applied Nutrition, reprinted in, "Bottled Water Regulation," Hearing of the Subcommittee on Oversig ht and Investigations of the House Committee on Ene rgy and Commerce, Serial No. 102-36 , 102nd Cong., 1st Sess. 65, p. 75 (April 10, 1991) .

118. FDA, "Beverages; Bottled Water: Final Rule," 6 0 Fed. Reg. 57,076, at 57120 (November 13, 1995).

119. Ibid. , p. 57, 120 (citing FFDCA §§ 301 & 304, 21 U.S.C. §§ 331 & 334).

120. General Accounting Office, Food Safety and Quality: Stronger FDA Standards and Oversight Needed for Bottled Water, GAO/RCED-91-67 , pp. 16-17 (March 1991).

121. FDA Regulations, 21 C.F.R. § 165.110(a).


123. See California Health and Safety Code § 111070(a); see also Appendix C (summarizing state programs and noting whether they regulate seltzer, etc. as bottled wate r).

124. Anon., "1996 Alternative Beverages: Still Wate r Supply Up Sharply, Perrier, Coke, Pepsi, and Sunt ory Gain Share, Beverage Digest (April 25, 1997), (www.beverage-digest.com/970425. html), (printed 9/25/1997). (In 1996, there reporte dly were 731 million cases of still waters-- some of wh ich may have been exempt also because they were lab eled "filtered water," etc., -- and 152.2 million cases of sparkli ng water.)


126. FFDCA § 410, 21 U.S.C. § 349 (1997).

127. Interview with Terry Troxel, FDA, September 18 , 1997.

128. 40 C.F.R. § 141.63.

129. See, 21 C.F.R. § 165.110(b)(2).

130. 21 C.F.R. § 165.110(b)(2).

131. 58 Fed. Reg. 52042, at 52045 (October 6, 1993) .

132. Personal Communication with Henry Kim, FDA, Se ptember 18, 1997.

133. 40 C.F.R. §§ 141.72(a)(4) & (b)(3).

134. 58 Fed. Reg. 52042, at 52047 (October 6, 1993) , (emphasis added).

135. 40 C.F.R. § 141.21. However, under EPA's rules , however, smaller tap water systems can test less frequently--so systems serving under 4,100 people can test once a week or less often for total coliform bacteria. Ibid.

136. 21 C.F.R. § 129.80(g)(1).

137. FFDCA § 410, 21 U.S.C. § 349 (1997).

138. 40 C.F.R. § 141.72.

139. 21 C.F.R. § 165.110.

140. 21 C.F.R. § 165.110(b)(3)(i); under a negotiat ed rule to be issued in late 1998, the turbidity st andard will drop to a maximum of 1 NTU, with a 95 percentile level of 0.3 NTU. 63 FED. REG. 69477 (December 16, 1998).

141. 40 C.F.R. § 141.73.

142. Studies show a clear link between drinking wat er turbidity and illnesses. See, R.D. Morris, E. N. Naumova,. and J.K. Griffiths, "Did Milwaukee Experience Waterborne Cry ptosporidiosis Before the Large Documented Outbreak in 1993?" Epidemiology vol. 9, no. 3 , pp. 264-270 (May 1998). For exampl e, in the Milwaukee Cryptosporidium outbreak turbidity increases were the only indicator of a water qualit y problem. Even with turbidity monitoring in Milwau kee, illnesses already had started by the time a spike in turbidit y was noticed and action taken. See, e.g. , W. R. MacKenzie, et al., "A Massive Outbreak in Milwaukee of Cryptosporidium In fection Transmitted Through the Public Water Supply ," New Engl. J. of Med. vol. 331, no. 3, pp. 161-167 (July 21, 1994). It sh ould be noted, however, that in at least in one Cry pto outbreak in Las Vegas, it was found that people who drank on ly bottled water had a far lower risk of getting th e disease than did tap water drinkers). S.T. Goldstein, D.D. Juranek, O. Ravenholt, A.W. Hightower, D.G. Martin, J.L. Mes nik, S.D. Griffiths, A.J. Bryant, R.R. Reich, B.L. Herwaldt, S. Goldstei n, "Cryptosporidiosis: An Outbreak Associated With Drinking Water

Despite State-of-the-Art Water Treatment," Ann Intern Med. vol. 124, no. 5, pp. 459-468 (March 1, 1996); S. Go ldstein, National Center for Infectious Disease, Centers for Disease Control, "An Outbreak of Cryptosporidiosis in Clark County, Nevada: Summary of Investigation," CDC (1995).

143. See, e.g. , W.R. MacKenzie,, et al., "A Massive Outbreak in M ilwaukee of Cryptosporidium Infection Transmitted Through the Public Water Supply," New Engl. J. of Med. vol. 331, no. 3, pp. 161-167 (July 21, 1994); Maryi ln Marchione, "Silent Disaster: Crypto Has Killed 104-And Countin g," Milwaukee Journal , p. 1 (March 27, 1994).

144. International Bottled Water Association, "Freq uently Asked Questions About Bottled Water," (avail able at www.bottledwater.org/faq.html), (printed 11/20/98).

145. The CDHS review noted that the bottled water i ndustry in California is "aware of the significance of cryptosporidiosis and passed a resolution...which w ould recommend their members to filter water throug h 1 um absolute filters." California Department of Health Service, Food and Drug Branch, "Bottled Water-- Cryptosporidium ," (2/14/95). This is similar to national "recommendat ions" from the International Bottled Water Associat ion to their members that they are "encouraged" to use effective Cryptosporidium treatment, also not binding. International Bottled Water Association, "Frequently Asked Questions Abou t Bottled Water," (available at www.bottledwater.or g/faq.html), (printed 11/20/1998).

146. Sylvia Swanson, "IBWA in the Forefront," Bottl ed Water Reporter 30, p. 37 (December/January 1996) .

147. Information Collection Rule, 61 Fed. Reg. 2435 4 (May 14, 1996); see also, 40 C.F.R. §§ 141.70-141 .75.

148. 21 C.F.R. § 165.110.

149. Compare, 40 C.F.R. part 141 with 21 C.F.R. § 1 65.110(b)(4).

150. Ibid. FDA announced in a 1996 rule that it was "deferrin g final action" on its proposed DEHP maximum contam inant level for bottled water after industry commenters o bjected to the standard. 61 Fed. Reg. 13258 (March 26, 1996).

151. 61 Fed. Reg. 13258, at 13260 (March 26, 1996).

152. Ibid. ; Comments of Grace Container Products, dated May 1 1, 1995, FDA Docket 93N-0085, Document C11.

153. Comments of Grace Container Products, dated Ma y 11, 1995, FDA Docket 93N-0085, Document C11.

154. See, Tyrone Wilson, IBWA Technical Director, C omments on August 4, 1993 FDA Proposed Rule for Bot tled Water Quality Standards at 8 (dated October 4, 1993), FDA Docket 93N-0085.

155. 61 Fed. Reg. 13258, at 13260 (March 26, 1996).

156. FFDCA § 410, as amended by the Safe Drinking W ater Act of 1996, codified at 21 U.S.C. § 349.

157. Codified at 21 C.F.R. § 165.110(b)(4)(iii)(A) & (b)(4)(iii)(C).

158. FFDCA § 410, as amended by the Safe Drinking W ater Act of 1996, codified at 21 U.S.C. § 349.

159. FDA, "Beverages: Bottled Water: Direct Final R ule," 63 Fed. Reg. 25764-25769 (May 11, 1998).

160. FDA, Direct Final Rule; Confirmation. Beverage s: Bottled Water, 63 Fed. Reg. 42198 (August 6, 199 8).

161. Ibid.

162. 40 C.F.R. §§ 141.24 & 141.61(a).

163. 40 C.F.R. § 141.40.

164. 40 C.F.R. § 141.28.

165. General Accounting Office, Food Safety and Quality: Stronger FDA Standards and Oversight Needed for Bottled Water, GAO/RCED-91-67 , p. 8 (March 1991).

166. 58 Fed. Reg. 393, p. 403 (January 5, 1993).

167. 60 Fed. Reg. 57076, p. 57116 (November 13, 199 5).

168. 21 U.S.C. § § 331-337; 371.

169. 21 U.S.C. § 349.

170. SDWA § 1419, 42 U.S.C. § 300g-8.

171. 58 Fed. Reg. 393, at 403 (January 5, 1993).

172. 60 Fed. Reg. 57076, at 57116 (November 13, 199 5).

173. 21 C.F.R. §§ 129.3(a) & 129.35(a)(3).

174. 21 C.F.R. §§ 129.3(a).

175. International Bottled Water Association, "Freq uently Asked Questions About Bottled Water," (avail able at www.bottledwater.org/faq.html), (printed 11/20/1998 ).

176. S. Marquardt, V. Smith, J. Bell, and J. Dinne, Environmental Policy Institute, Bottled Water: Sparkling Hype at a Premium Price , p. 3 (1989).

177. Memorandum to Members, Subcommittee on Oversig ht and Investigations, from John Dingell, Chairman, in "Bottled Water Regulation," Hearing of the Subcommittee on Oversight and Invest igations of the House Committee on Energy and Commerce, Serial No. 102-36 , 102nd Cong., 1st Sess. 5, p. 9 (April 10, 1991).

178. SDWA § 1453, 42 U.S.C. § 300j-13.

179. Ibid.

180. Massachusetts Department of Public Health, Ann & Hope Water Incident Files, 1993-1997; Memorandum from Dr. Elizabeth Bourque, MDPH, to Paul Tierney, MDPH, Dec ember 13, 1996, (MDPH Memoranda Provided to NRDC Pu rsuant to Freedom of Information Request), Personal Communica tion with Dr. Bourque, MDPH, August 1997; Letter fr om Shellee Davis, FDA, to Dr. Elizabeth Bourque, MDPH, June 6, 1996.

181. 21 C.F.R. § 165.110(c).

182. New Jersey Department of Health & Senior Servi ces, Report to the New Jersey Legislature, Summarizing L aboratory Test Results on the Quality of Bottled Drinking Wat er for the Period January 1, 1995 through December 31, 1996, p. 17 (July 1997).

183. 61 Fed. Reg. 13258, at 13259-60 (March 26, 199 6).

184. Ibid.; see also , 21 C.F.R. § 165.110(d).

185. 40 C.F.R. §§ 141.31 & 142.15.

186. Ibid.

187. Ibid. § 142.15.

188. 40 C.F.R. § 141.33.

189. 60 Fed. Reg. 57076, 57118 (November 13, 1995).

190. 60 Fed. Reg. 57076, 57118 (November 13, 1995).

191. 21 C.F.R. § 129.80(h).

192. 40 C.F.R. § 141.33.



195. 21 C.F.R. § 129.80(g).


197. Ibid. at 57108.

198. L. Moreira, P. Agostinho, P.V. Morais, and M.S . da Costa, "Survival of Allochthonous Bacteria in Still Mineral Water Bottled in Polyvinyl Chloride (PVC) and Glass," J. Applied Bacteriology , vol. 77, pp. 334-339 (1994); P.V. Morais, and M.S . Da Costa, "Alterations in the Major Heterotrophic B acterial Populations Isolated from a Still Bottled Mineral Water," J. Applied Bacteriol. , vol. 69, pp. 750-757 (1990); P.R. Hunter, "The Mi crobiology of Bottled Natural Mineral Waters," J. Applied Bacteriol. , vol. 74, pp. 345-52 (1993); F.A. Rosenberg, "The Bacterial Flora of Bottled Waters and Potential Problems Associated With the Presence of Antibiotic -Resistant Species," in Proceedings of the Bottled Water Workshop , September 13 and 14, 1990, A Report Prepared for th e Use of the Subcommittee on Oversight and Investig ations of the Committee on Energy and Commerce, U.S. House of Rep resentatives, Committee Print 101-X, 101st Cong., 2 d Sess. pp. 72-81 (December, 1990); .D.W. Warburton, B. Bowen, and A. Konkle, "The Survival and Recovery of Pseudomonas aeruginosa and its effect on Salmonellae in Water: Methodolog y to Test Bottled Water in Canada," Can. J. Microbiol. , vol. 40, pp. 987-992 (1994); D.W. Warburton, J.K. McCorm ick, and B. Bowen, "The Survival and Recovery of Aeromonas hydrophila in Water: Development of a Methodology for Testing Bottled Water in Canada," Can. J. Microbiol. , vol. 40, pp. 145-48 (1994); D.W. Warburton, "A Review of the Mic robiological Quality of Bottled Water Sold in Canad a, Part 2: The Need for More Stringent Standards and Regulations," Canadian J. of Microbiology , vol. 39, p. 162 (1993); A. Ferreira, P.V. Morais, and M.S. Da Costa, "Alterations in Total Ba cteria, Iodonitrophenyltetrazolium (INT)-Positive B acteria, and Heterotrophic Plate Counts of Bottled Mineral Water ," Canadian J. of Microbiology , vol. 40, pp. 72-77 (1994).


200. Statement of Frank Shank, Director, FDA Center for Food Safety and Applied Nutrition, reprinted i n "Bottled Water Regulation," Hearing of the Subcommittee on Oversight and Invest igations of the House Committee on Energy and Commerce, Serial No. 102-36 , 102nd Cong., 1st Sess. 65, p. 76 (April 10, 1991) .

201. Personal Communication with Terry Troxel and S hellee Davis, FDA, September 18, 1997; Personal Com munication with Ron Roy, FDA, compliance programs, November 20 , 1998.

202. Ibid. ; 60 Fed. Reg. 57076, p. 57117 (November 13, 1995).






208. Ibid; General Accounting Office, Food Safety and Quality: Stronger FDA Standards and Oversight Needed for Bottled Water, GAO/RCED-91-67 , at p. 7 (March 1991).

209. Alaska; Arkansas; Delaware; District of Columb ia; Georgia; Idaho; Illinois; Iowa; Kentucky; Maryl and; Minnesota; Nebraska; and Pennsylvania. Four states --Michigan, New Mexico, North Carolina, and Tennessee-- either did not respond to this query or chose not to comment.

210. California (2 FTE, 9 investigators state-wide) ; Florida (2 FTE); New Jersey (1 FTE); New York (1 - 1 ½ FTE); Ohio (Approximately 1 FTE); Oklahoma (1 FTE); and Virgin ia (1-2 FTE).

211. Personal communication with Nancy Napolli, Pro gram Manager, Environmental Sanitation and Food Saf ety, State of Alaska, April 7, 1998.

212. Letter from Brock Marlin, Program Manager, Ari zona Department of Health Services, to NRDC, Novemb er 27, 1995.

213. Personal communication with Mr. James Pyles, C onsumer Product Safety Officer, Kansas Department o f Health and Environment, April 21, 1998.

214. General Accounting Office, Food Safety And Quality: Stronger FDA Standards And Oversight Needed For Bottled Water, GAO/RCED-91-67 , at p. 17 (March 1991).

215. Letter from Kenan L. Bullinger, Director, Nort h Dakota Department of Health Services, to NRDC, No vember 13,1995.

216. Personal communication with Joe Dixon, Evaluat ions Auditor, Manufactured Foods, Texas Department of Health, June 12, 1998.

217. Personal communication with Bryan Davis, Progr am Supervisor, Virginia Department of Agriculture, Consumer Services, June 3, 1998.

218. Personal correspondence with Ms. Nancy Napolil li, Program Manger, Environmental Sanitation and Fo od Safety, Department of Environmental Conservation, State of Alaska, April 7, 1998; accord, Ms. Nancy Napolilli, Comments of the Alaska Department of Environmental Conservation, Di vision of Environmental Health, Environmental Sanit ation and Food Safety, on FDA Feasibility Study of Appropriat e Methods of Informing Consumers of the Contents of Bottled Water (dated December 12, 1997), (FDA Docket 97N-0436).

219. California (including whether municipal), Mary land, Massachusetts, Michigan, Nevada, New Hampshir e, New Jersey, New York, Ohio (unless municipal), Pennsylvania (mu st also list name of public water system), Rhode Is land (but only municipal waters without deionization process must list source), Texas, Vermont, and Wyoming (municipa l water must be listed as "drinking water") reported requiring s ource listing on bottled water labels.

220. Connecticut ("separate state regulations" for labeling); Hawaii (prohibition against misbranding) ; Idaho (intrastate labeling law prohibits misbranding); Maine (if sour ce or end-product exceed MCLs, must be listed on la bel; must also list if "altered water quality"); Michigan (declaration of identity & carbon dioxide content); Minnesota (s tate rules); Montana (if labeled "organic" must be verified by third par ty "Organic Certification" group); Nevada (if makin g any claims such as low sodium or fluoride content, must list levels fo und in product); New Hampshire (no misleading brand names); New Jersey (two year expiration date); New York (nutrit ional claims must be consistent with FDA regulation s; variances must be listed on label); Ohio (any additives must be li sted); Oklahoma (separate state regulations); Texas (chemicals or bacteria that exceed MCLs must be listed and must s tate on label "contains excessive bacteria"); and V ermont (must list finished end-product levels of arsenic, lead, sodiu m, and nitrates).

221. California, Colorado, Georgia, Illinois, Iowa, Kentucky, Louisiana, Maryland, Massachusetts, Mont ana, Nevada, New Hampshire, New Jersey, New Mexico, New York, North Carolina, Ohio, Oregon, Pennsylvania, Rhode Island, South Carolina, Texas, Utah, Vermont, Virginia, Washingto n, and West Virginia.

222. Hawaii (available through FOIA request); Maine (listed in database; would require approximately ½ hour to gather); Nebraska (but data available would have more to do with sanitation violations than analytical results) ; New Jersey (annual summary of test results and enforcement & v iolation data mandated by state statute); Oklahoma (inspection reports); Oregon (summary report of violations for period 1/1/94 - 12/31/97); South Dakota (computeriz ed database of violations); Vermont (computerized data base of vio lations); Virginia (information kept in database; w ill provide for fee); and Wyoming (violation data stored in computer data base).

223. Elizabeth Watkins, Food Processing Coordinator , Illinois Department of Health. Telephone intervie w with NRDC, April 27, 1998.

224. Massachusetts Department of Public Health , An n & Hope Water Incident Files, 1993-1997; see, e.g. Bourque Memoranda of 10/31/1996; 12/13/1996; 12/26/1996; 1/ 28/1997; Bourque Letters of 7/11/1996; 7/19/1996; 7 /22/1996; 8/7/1996; 9/16/1996; 9/20/1996; 10/16/1996; 10/21/1 996; MDPH Memo of 12/9/1996; D. Talbot, "Bottled Wa ter Flows from a Troubled Well," The Boston Herald , p. 1 (December 16, 1996).

225. Mass. DPH, Poland Spring HPC file, and Poland Spring excess Chlorine Contamination File; see also Chemical Contamination and Microbial Contamination chapters.

226. Massachesetts Department of Public Health, Ann & Hope Water Incident Files, 1993-1997; see, e.g. Ridley desk calendar and agenda for 12/5/1996; Memo of 12/4/199 6; Massachusetts Organization of State Engineers an d Scientists 12/23/1996 and 3/4/1997 Letters to Milligan and Rid ley, respectively; Memo from Richard Waskiewicz. MD PH, 12/9/1996; Bourque Memoranda of 10/31/1996; 12/13/1996; 12/26/ 1996; 1/28/1997; Bourque Letters of 7/11/1996; 7/19 /1996; 7/22/1996; 8/7/96; 9/16/1996; 9/20/1996; 10/16/1996; 10/21/199 6; MDPH Memo of 12/9/1996; D. Talbot, "Bottled Wate r Flows from a Troubled Well," The Boston Herald p. 1 (December 16 , 1996). 227. Waskiewicz Memo to Bourque, 12/9/96. 228. Massachusetts Organization of State Engineers and Scientists Letter to Mulligan, 12/23/96; MOSES Letter to Ridley 3/4/97; personal communication with Dr. Bourque, Au gust 1997.

229. Compare Letter from Mulligan to Sen. Jacques, January 3, 1 997 and attached list of documents, with, MDPH Ann & Hope files.

Chapter 5

MISLEADING BOTTLED WATER LABELING AND MARKETING

In 1995, FDA issued "standards of identity" -- esse ntially labeling rules, in response to a petition from the International Bottled Water Assoc iation (IBWA). [230] These rules were widely acclaimed as a breakthrough that would prohi bit misleading claims by unscrupulous water bottlers. While the rules do pro hibit some of the most egregiously deceptive labeling practices by bottlers, they have by no means eliminated the problem.

Some Bottled Water Labels Remain Misleading to Consumers

The Institute of Medicine, an arm of the National A cademy of Sciences, found in a 1992 study that deceptive bottled water labeling was a w idespread practice, with state authorities exasperated about FDA inaction in the f ace of frequent statements and vignettes indicating or implying that the bottled w ater was far purer than tap water or came from specific sources or had purity levels that may not have been justified. [231]

Many of these practices continue. For example, FDA rules allow bottlers to call their product "spring water" -- which seems to carry cach et with consumers as being especially natural and pure -- even though it may be brought t o the surface using a pumped well, and even though it may be treated with chemicals. FDA m erely requires that the geologic formation that is tapped by the well must come to t he surface somewhere, sometimes, to allow the water pumped to the surface in a well to be called spring water. [232] Among the more interesting labels we have run across:

• "Spring water" (with mountains and a lake on the l abel) actually from an industrial parking lot next to a hazardous waste site, ruled n ot misleading. A well located in the middle of an industrial warehouse facility and next to a state-designated industrial waste site in Millis, Massachusetts, pro duced this water, contaminated with industrial solvents including trichloroethylen e at levels above EPA and FDA standards. The label gracing at least one of the ma ny brands that used this water depicted a beautiful mountain in a reflection off a lake and was called "spring water." In response to a request from the state of Massachusetts, FDA opined that this label was acceptable so long as the water does come to the surface sometimes (it sometimes does in an unpaved area nea r the parking lot), and as long as "there is no claim to the effect that the l ocation pictured in the vignette is the actual spring, we would not consider the label vignette to be in violation of our requirements." [233] Apparently, after public disclosure of the true so urce of the

water and contamination problems, this well is no l onger being used for bottled water.

• "Alasika™ - Alaska Premium Glacier Drinking Water: Pure Glacier Water From The Last Unpolluted Frontier, Bacteria Free" apparently from a public water supply. This water actually came from "Public Water System #111241" (a public water system in Juneau, Alaska), according to documents i n Washington State files. The bottler evidently was told that when it reordered i ts labels, it had to state that the water is "from a municipal source" or "from a commu nity water system," in keeping with FDA rules; the phrase "pure glacier wa ter" was, per documents in state files, "considered false and misleading." The bottler was required to drop the "bacteria free" claim, as this was "considered syno nymous with sterile and false." This water no longer claims to be "glacier water" o r "bacteria free." However, NRDC has found several other brands sold as "glacier" water even though they apparently come from groundwater nowhere near any c urrent glacier. [234]

• Vals Water "Known to Generations in France for its Purity and Agreeable Contribution to Health...Reputed to Help Restore En ergy, Vitality, and Combat Fatigue." While the IBWA voluntary code prohibits h ealth claims, some bottlers still make such claims.

In addition to these instances of bottled water lab els, far more common -- in fact exceptionally widespread -- is the use of descripti ve terminology that suggests bottled water is extraordinarily pure and uncontaminated. A s an example, our review of the labels and Web site vignettes and advertising of about 50 IBWA members found the following terms used:

• "Pure" -- eight bottlers. • "Purest" or "Purity" -- three bottlers. • "Pristine" -- five bottlers. • "Glacial" -- two bottlers. • "Natural" or "Prepared by Nature" -- eight bottler s. • "Naturally Purified" or "Naturally Occurring" -- t hree bottlers. • "Premium" -- five bottlers. • "Mountain Water" -- seven bottlers. • "Clean" -- two bottlers. • "Good Health" or "Healthy" -- two bottlers • "For Health Conscious" -- two bottlers

Thus, representations about bottled water purity, p remium and natural sources, and healthfulness remain extremely widespread. The FDA rules seem to have little effect on bottlers' claims of water purity and cleanliness.

Bottled Water Marketing is Often False or Misleading

Bottled water marketing seeks to emphasize the supp osed purity of bottled water, in many cases contrasting "pure" and "protected" bottled wa ter with "inconsistent" or unpredictable tap water quality. In the words of a leading industry consultant, "Water bottlers are selling a market perception that water is 'pure and good for you'...." [235]

This effort to create a "market perception" of puri ty is an advertising mandate for the industry, notwithstanding the fact that just becaus e water comes from a bottle does not mean that it is any purer than tap water, as we hav e seen in previous chapters. Among the common industry claims about bottled water that are of questionable veracity or that are clearly incorrect are:

• Bottled water contains "no" chlorine or harmful ch emicals. This claim is boldly featured on IBWA fact sheets and its Web site. [236] It clearly is false, as previous chapters have shown.

• Bottled water is always high quality, whereas tap water is of inconsistent quality. IBWA often points out that "unfortunately, tap wate r can be inconsistent -- sometimes it might be okay and other times it is no t." On the other hand, IBWA says, "quality is in every container of bottled wat er. It's consistent and it is inspected and monitored by governmental and private laboratories." [237] What IBWA neglects to point out, however, is that in man y cases bottled water does contain contaminants, that most tap water is requir ed to be monitored more often than bottled water (and testing must be done by gov ernment-certified labs, which is not the case for bottled water), and that about one fourth or more of the bottled water sold in the United States is derived from the same tap water IBWA says is of inconsistent quality.

• No waterborne illness has been traced to bottled w ater. IBWA claims that "According to the Centers for Disease Control and P revention (CDC), bottled water has never been responsible for an outbreak of water borne illness." [238] In fact, as discussed in the Technical Report (print report only) and Appendix B, there have been waterborne-disease outbreaks traced to bottled water. For example, a bottled water-related cholera outbreak in U.S. territory in the Pacific was written up in 1996 in CDC's flagship journal, Morbidity and Mortality Weekly Report , and other outbreaks traced to bottled water in Portugal and e lsewhere have been documented. [239]

• Cryptosporidium cannot get into bottled water. The IBWA's fact she ets and Web site make the repeated claim that FDA rules "ensure that surface water contaminants such as Cryptosporidium and Giardia are not present" in bottled water derived from groundwater, and that all IBWA m embers using municipal water "reprocess this water [and] employ methods such as reverse osmosis, deionization, distillation, and filtration," implyi ng this eliminates any risk. IBWA also implies that bottled water is safe for the imm unocompromised. [240] There is no evidence that bottled water is truly immune from Cryptosporidium or Giardia unless it is fully protected and treated with EPA-C DC recognized best available technologies, and much bottled water does not recei ve this treatment. Indeed, internal industry communications highlight that IBW A is well aware that some bottlers do not use these treatment technologies. [241]

• Imported bottled water must meet all U.S. rules. I BWA states that "any bottled water sold in the United States must meet all of th e same regulations as domestically produced water." [242] But what is not mentioned is that FDA's Good Manufacturing Practices, source approval, and sourc e-water-testing requirements apply at the source or bottling facility and are im possible for FDA to enforce when such facilities are outside of the United States. F DA does not conduct any foreign inspections of bottlers, so the degree to which for eign bottlers comply with these FDA rules is not known. What is clear, however, is that these FDA rules do not apply equally to foreign bottlers.

Although these claims may not be the most exaggerat ed of those made by the industry, they are troubling in that all of them are made by the leading industry trade association.

Also of concern is a major IBWA public relations ca mpaign intended to persuade the public to drink more bottled water. The campaign, f unded by IBWA members, is aimed to be "a comprehensive campaign to educate third-party groups and the media about the safety and quality of bottled water." The campaign includes slick advertising and fact sheets. Also central are briefings of the media, no nprofit health organizations, and groups representing the immunocompromised and retired pers ons. The campaign has also taken other steps, such as the sponsorship of an American Dietetic Association meeting. Mailings have been made to thousands of advocacy gr oups, members of the media, environmental and health groups. Several news stori es have been placed, and expanded briefings in more cities were planned.

Thus, in a well-orchestrated effort, the bottled wa ter industry has made major inroads into the public psyche, reinforcing perceptions about th e purity of bottled water. While this clearly is within the industry's rights, it is impo rtant that bottlers not overstate their case or mislead the public into believing that bottled w ater is safer or better protected than is the case.

Report Notes

230. Codified at 21 C.F.R. Part 165.

231. IOM, Committee on State Food Labeling, Food an d Nutrition Board, National Academy of Sciences, Food Labeling: Toward National Uniformity (1992); 58 Fed. Reg. 389, p. 406 (January 5, 1993) .

232. 21 C.F.R. § 165.110(a)(vi).

233. Letter from Shellee Davis, FDA, to Dr. Liz Bou rque, MDPH, June 6, 1996.

234. Washington State Department of Agriculture Foo d Establishment Inspection Report April 17, 1997, a nd attachments; WSDA Food Establishment Inspection Report October 4 , 1996, and attachments; WSDA Food Processor Licens ing Worksheet and Attachments, and WSDA Food Establishm ent Inspection Report and Attachments, March 20, 19 96. Personal communication with Shelly Haywood, USDA, J an. 1999. For other waters claiming to be "glacier" water, see e.g., "Bottled Water/Carbonated Beverage Files: Cur rent Permitholders," MDPH (January 1999).

235. H.R. Hidell, "Water: The Search for a Global B alance," Bottled Water Reporter , p. 53 (June/July 1995), (emphasis added).

236. See, e.g., IBWA's Bottled Water FAQs, "www.bot tledwater.org/faq."

237. Ibid.

238. Ibid.

239. CDC, "Surveillance for Waterborne-Disease Outb reaks--United States, 1993-1994, Morbidity and Mortality Weekly Report vol. 45, no. SS-1 (April 12, 1996). See also Appen dix B regarding waterborne disease outbreaks.

240. Ibid. , and "www.bottledwater.org/facts/immuno.html."

241. As noted in a previous chapter, for example, a n article in the IBWA's in-house organ that urged b ottlers to upgrade their treatment to be sure it meets CDC guidelines for removing Crypto , pointed out: "How can we expect health groups

to endorse our product if we don't ALL meet the [CD C Crypto removal] guidelines!" Sylvia Swanson, "IBWA in the Forefront," Bottled Water Reporter , p. 37 (December/January 1996).

242. See, e.g., IBWA's Bottled Water FAQs, "www.bot tledwater.org/faq."

Chapter 6

ENSURING CONSUMERS' RIGHT TO KNOW ABOUT BOTTLED WATER

Under the 1996 SDWA amendments, tap water suppliers are required to issue annual reports to all of their consumers, which many call "right-to-know reports." These reports inform consumers of all contaminants found in their tap water and the standards and health goals for those contaminants, information on the system's compliance with EPA rules, and details on their water source. [243]

After a pitched battle in which consumer and enviro nmental groups fought to get a similar requirement adopted for bottled water, water bottle rs were successful at killing a measure that would have required such right-to-know informa tion from bottlers to be provided to consumers.

Right-to-Know Information for Tap Water, and Industry's Opposition to It for Bottled Water

The bottled water industry's opposition to a right- to-know requirement applying to bottled water is particularly disturbing in light of the in dustry's frequent citation of tap water quality problems as a rationale for switching to bo ttled water. It also is galling because of the industry's open admission that it has substanti ally benefited from labelling requirements for beverages such as diet soda, which have caused concern among many consumers about the ingredients in these drinks. Th e IBWA's primary spokeswoman recently noted, for example, that the recent burst in industry sales is linked in part to soda labels, which revealed to consumers just what they were drinking. "The more people realize what's in some of these drinks, the more th ey turn to water for what it doesn't have...." [244]

An internal communication from the IBWA executive d irector, obtained by NRDC, bragged about the industry's successful effort to keep cons umers in the dark about the quality of the bottled water they are buying:

During the [House-Senate SDWA] conference some memb ers wanted the same "right-to-know" provision enacted for bottled water. Although IBWA vociferously opposed any type of right-to-know for bottled water, we were informe d by Congressional staff that it was a non-negotiable part of the discussion. Nevertheless , we then met with the House and

Senate conference staff to communicate the industry 's concerns to this type of notification and were successful in getting...a dra ft study [evaluating the feasibility of requiring bottled water right-to-know, rather than instituting a requirement] into the bill....This has been a great victory for the IBWA and the entire bottled water industry! [245]

Thus, if the bottler finds coliform bacteria, Cryptosporidium , cancer-causing solvents, or other contaminants in the water, but no violation o f FDA's standards is triggered (either because there is no standard for the contaminant or because it was found at a level below the standard), there is no specific requirement in the FDA rules that such information be provided to consumers. [246]

Neither is the bottler required by FDA rules to dis close information about the source of the water, how well protected that source may be from c ontamination, or whether an assessment has been performed to determine its vuln erability to contamination. The bottler also has no obligation to disclose how and whether the water is treated.

Therefore, as a result of a successful vigorous lob bying campaign by the bottled water industry against right-to-know requirements for con sumers of bottled water, the public likely will know little or nothing about what conta minants are in their bottled water. The FDA "feasibility study" to evaluate requiring right -to-know information for bottled water consumers, referred to by IBWA in the internal comm unication just quoted, was included in the SDWA essentially as a consolation prize to c onsumer and environmental groups. [247] It has not yet been issued, even in draft, although the law required FDA to publish a draft by February 1998. FDA issued a Federal Register notice late in 1997 asking for public comment on the feasibility of requiring some kind o f disclosure for bottled water. [248] The study must be finalized by February 1999, [249] but FDA considers this study to be a low priority and has no firm date for its completion. [250]

The bottled water industry has continued to fight a gainst applying right-to-know rules to its product. When FDA asked for comments on the fea sibility of providing information to consumers about bottled water on labels, via the In ternet or otherwise, they were inundated by complaints from IBWA and many individu al bottlers. [251] IBWA opposed any right-to-know rules and charged that FDA had "excee ded its Congressional mandate" by even asking for comments on the type and contents o f reports that might be provided to consumers about bottled water contaminants. [252] One bottler argued that "only the EPA can think up something as dopey as applying" right- to-know requirements to a "discretely-packaged, easily identified, pure food product" [253] like bottled water.

As discussed next, NRDC contends that the time has come for bottled water right-to-know labeling. If right-to-know requirements are good en ough for the tap water industry, they're good enough for the bottled water industry, which i s charging consumers hundreds of times more for their water per gallon and claiming that consumers should switch from "unreliable" tap water to safer bottled water.

The Need for Right-to-Know Requirements for Bottled Water

As President Bill Clinton stated in signing into la w the 1996 Safe Drinking Water Act (SDWA) amendments, [254] the public has a right to know about what is in th eir drinking water, and whether it may pose a risk to their heal th. NRDC asserts that this right to know applies equally to bottled water as it does to tap water. The National Drinking Water

Advisory Council (the congressionally chartered adv isory body to EPA on federal drinking water policy) concurs. In its November 1998 recomme ndations, the council urged that EPA and FDA work together to ensure that information ab out bottled water be made available in as complete and readily accessible a form to bottle d water consumers as tap water information is now available to tap water users. [255]

Millions of Americans rely upon bottled water as an alternative or substitute for tap water -- often as a result of the advertising campaigns of bottlers that tout the purity of their water and occasionally denigrate the quality of tap water. The 1996 SDWA amendments require consumers to be directly informed by their tap water supplier about all contaminants in their water (and the health goals a nd standards for those contaminants), their supplier's compliance with applicable standar ds, and the source of their water. [256]

NRDC strongly concludes that similar information mu st be made available to bottled water consumers on the label so they can make an intelligent choice as to what water to drink, considering their own and their family's health nee ds. For example, immunocompromised persons clearly could make use of label information on the microbiological quality of the water, its source, the treatment processes used, if any, and other relevant information. The label should include information about contaminants in the water found at levels above health goals and what health effects those contamin ants have, the health goals and acceptable levels of those contaminants, bottler co mpliance, fluoride and sodium levels, key information on the source and treatment of the water, and a note on how consumers can get more information.

Only if the information is available on the label w ill consumers be able to make informed choices among the many brands of bottled water, or between bottled water and tap water. To put it bluntly, if, as the industry argues, bott led water is so pure and there is nothing for consumers to be concerned about, why not prove it w ith full disclosure on the label?

Methods for Conveying Information to Consumers

Several methods should be used to inform consumers about their bottled water, but the backbone of the effort must be label information.

1. Labels should be used to provide consumer inform ation.

To make information useful to consumers, it must be placed on the label. The label on bottled water is the most important means for co mmunicating information, to consumers. The label should be of sufficient size a nd contain sufficient information presented in a simple, understandable w ay, to enable those most at risk from waterborne disease, such as parents of in fants, the elderly, and the immunocompromised (or those wishing to reduce or el iminate their intake of carcinogenic or otherwise toxic chemicals) to make informed decisions when choosing a particular brand of water.

Making information available in a usable and unders tandable form on the label is the most effective way to provide informed consumer choice. After all, bottlers devote an enormous effort and spend millions of dol lars to create the wording and appearance of their labels and bottles, precisely b ecause they know that often this is the factor that can most effectively influence c onsumer choice. The point at

which most consumers evaluate products and make fin al purchasing decisions generally is at the store when the bottle is purcha sed.

If the information on contaminants is not included on the bottles, it will not add much to consumer awareness or better-informed buyin g. This is precisely the reason that nutrition information is required by th e Nutrition Labeling and Education Act of 1990 to be prominently placed on f ood labels.

The alternative methods for providing information t o consumers suggested by FDA in a recent Federal Register notice [257] other than label disclosure -- such as including a phone number or address that the consum er can use to contact the bottler for more information -- are unlikely to res ult in any significant additional information reaching the vast majority of consumers . If the information is not available on the label when the consumer is making a purchase, it is far less likely to inform or influence consumer decision making.

To make this point another way, how many bottlers w ould be satisfied with selling their water in plain, unadorned generic bottles and having their florid vignettes, eye-catching graphics, label language, and attracti ve bottle shapes available to consumers only upon request to a toll-free number? The answer is virtually none, because this would eliminate the impact of the info rmation and advertising on consumer decision making.

Mere reference to a toll-free number or address of the bottler also will be of little value, in part due to the pervasive consumer view ( fueled by heavy industry advertising) that bottled water is extremely pure, and thus most consumers rationally may assume there is no reason to expend the time to learn what is contained in the bottled water they are about to pu rchase. If consumers have no reason to believe there may be contaminants in thei r water, they will have little or no motivation to make the extra effort necessary to contact their bottler.

Therefore, we urge that bottled water labels should include the following information:

• The level, expressed in whole numbers (as required by EPA tap water right-to-know rules), of any contaminant found in the wat er at a level in excess of a health goal, [6a] plus the fluoride level (because of this element's asserted public-health benefits at low levels and, at high l evels, its detrimental effects), sodium level (to assist those seeking to reduce their sodium intake for health reasons).

• The health goal and allowable level for those cont aminants, and fluoride and sodium, found in the water, in the same units.

• A statement as to whether the bottler is in substa ntial compliance with state and federal regulations (based upon an annual certification sent to the state and FDA and not disagreed with in writing by either), and, if not, what violations occurred.

• A one-sentence layperson-readable summary of the h ealth effects associated with any contaminant found at a level in excess of a health goal (taken from model language written by FDA and EPA).

• A simplified restatement of the EPA-CDC advice to immunocompromised consumers about the types of bottled water treatmen t necessary to avoid

Cryptosporidium contamination, and whether the bottled water meets those criteria.

• The specific source (e.g., "Houston public water s ystem") and treatment (e.g., "reverse osmosis and ozonation") of the wate r.

• An FDA toll-free number for consumers to obtain mo re information (or a referral to EPA's drinking water hot line);

• The bottler's street address, phone number, and We b or e-mail address (if any), for further information.

2. Information should also be available on request and on the Internet. In addition to labeling, but not as a substitute fo r it, a more detailed consumer brochure should be available from bottlers. It shou ld include a summary of all contaminants tested for and the range of levels fou nd, detailed information on water treatment and on any source-water assessment and protection, and further information on the items noted in the first six bul lets, above, as well as all other information that would be required to be provided b y a public water system in public-notification and consumer-confidence reports required under section 1414(c) of the SDWA. Such brochures could be disseminated on the Interne t (World Wide Web and e-mail response) and in response to written requests or telephone inquiries (e.g., via a menu-driven phone mail that provides automated ma il or faxed responses). These methods of providing information could be a u seful supplement to labeling but, for the reasons previously discussed, would not be an effective substitute for product labels.

3. Brochures and labels are needed for delivered water. Water that is delivered to homes or businesses shou ld include the same information on a label on the carboy (large bottle) , because many people consuming it (e.g., in an office, school, hospital, or other workplace setting) may not have access to a mailed or hand-delivered broch ure. For example, an immunocompromised person visiting or working at suc h a location could benefit from being able to review that information even if a brochure has been misplaced or is no longer available. We do believe, however, that mailing or delivering a detailed water report to the person responsible for the bill would also be advis able, as that person has the most influence over which water to purchase and may make important use of the information.

Feasibility of Appropriate Methods

It is quite clear that labeling of bottled water to include the information previously noted is feasible. Labels on currently sold bottled water ha ve ample space available to include such information, and previous industry experience with nutrition-label information has shown the ability to include more information on su ch labels.

We are aware that there may be concerns expressed b y the industry about the feasibility of including such information on the labels of bott led water due to space limitations, costs, or other problems. However, several other fa ctors demonstrate the feasibility of such labeling:

• Our informal survey of the bottles of water common ly sold in major local stores indicates that such information clearly could fit o n the label. On all bottles now on the market that we have seen, there is ample free s pace for additional label information. In the vast majority of cases, substan tially less than half of the bottle's surface area that could be used to provide written information is used to provide this under current labeling practices. For every br and we have seen, at least 50 percent of the bottle's surface area, and generally a far greater percentage of the surface area (our estimate is that on average, less than 25 percent of the surface area of the average bottle of water is covered with label information), is available for additional label information.

• In unusual cases in which for some reason labels c ould not be immediately changed, temporary stickers could be used, or bottl ers could use a bottle neck hanger (as is currently used by Apollinaris), so lo ng as the sticker or hanger contains all required information and is required t o remain on the bottle until sale.

• If industry assertions of the general purity of bo ttled water are correct, there should be very few contaminants found at levels abo ve health goals that would need to be noted on the label, so little additional space would be required for such information, or for health-effects information rega rding such contaminants. For example, the International Bottled Water Associatio n says flatly that there are "no" harmful chemicals in bottled water. If so, little o r no label space will be required for information on contaminants.

• Many bottlers already include substantial informat ion (albeit generally without the important contextual explanation consumers need to understand the data) on the levels of total dissolved solids, the minerals foun d in their water, and the levels of those minerals in their water. For example, detaile d information on the levels of total dissolved solids, as well as levels of sodium , potassium, calcium, magnesium, chlorides, sulfate, nitrates, bicarbonat e, silica, and pH are included on the labels for Evian, Naya, Strathmore Mineral Water, Vittel, Volvic, Spa, Aqua Cool, and many other waters. Other bottlers include selec ted water-quality information on their bottle labels , for example: S. Pellegrino (total-dissolved-solid , sodium, and calcium levels); Fountainhead (lead, arsenic, sodiu m, and nitrate levels); Gerber Baby Water (fluoride, arsenic, lead, sodium, and ni trate levels); Quibell (calcium, magnesium, sodium, pH, and total-dissolved-solid le vels); Apollinaris (magnesium, sodium, and total-dissolved-solid level); Vals (sod ium and total-dissolved-solids); and Solé (total-dissolved-solids, sodium, and pH le vels)

• In Europe, mineral water already must include such total-dissolved-solids and mineral-composition information. It is therefore cl early possible to identify on the label the levels of what are hoped to be at most a small number of contaminants found at levels over health goals.

• Some states already require information on the sou rce of the water (e.g., Massachusetts) and on arsenic and lead levels (e.g. , Vermont), etc., on the label, and many bottlers already include such information on their labels, so a national requirement for such information would not add to t he burden of many bottlers.

• Many bottlers making claims about low- or no-sodiu m content include nutritional information already, information that rivals or exc eeds the space requirements necessary to include the information previously not ed.

• The costs of relabeling will be trivial when compa red with the profit margin in the industry. The food-nutrition label has not been a s ignificant burden on the food industry, and profit margins in this industry are g reater. For example, a bottler selling water taken from a public water supply and then filtered is likely to sell that water for hundreds of times more per liter than the bottler paid the water supply for the water, and will have spent a small amount per g allon for treatment.

• If public water suppliers, who are charging far le ss per gallon of water, can supply such information to consumers, it is imperative and feasible for bottlers to do so as well.

Conclusions Regarding Right-to-Know Information for Bottled Water

Consumers have a right to know about what is in the ir drinking water and whether it poses any risk to their health. For this reason, water bo ttlers should be required to disclose information about bottled water contaminants, bottl er compliance, water treatment, the source of the water, and health issues on the label . Without such label disclosure, informed consumer decision making about whether to purchase bottled water will be seriously undermined.

Chapter Notes

6a. The term "health goal" refers to an EPA Maximum Contaminant Level Goal (MCLG), see SDWA §1412(b)(4)(A)), if any, or, if there is no MCLG, the lowest EPA Health Advi sory Level (HAL), see SDWA § 1412(b)(1)(F)), or if there is no MCLG or HAL, the lowest EPA human health-based water qualit y criteria for that contaminant (see Clean Water Ac t §§ 303-304). For contaminants with an MCL but no MCLG, it is par ticularly important for the health-based water qual ity criteria to be noted on the label (until an MCLG is published), si nce such standards (like arsenic) have not been rev ised since 1942 and thus do not reflect up-to-date science.

Report Notes

243. SDWA § 1414(c)(4).

244. Constance Hayes, "Now, Liquid Gold Comes in Bo ttles," The New York Times , p. D1 (January 20, 1998).

245. Sylvia Swanson, IBWA Executive Director, "Safe Drinking Water Act Becomes Law," reprinted in Aqua News: Northeast Bottled Water Association , p. 5 (Summer 1996).

246. While theoretically bottlers are obliged to in clude on the label a statement that their product " Contains Excessive Chemical Substances [or Bacteria]" if it violates a n FDA standard, the bottler's obligations to disclo se under the FDA rules about end there.

247. SDWA Amendments of 1996, Pub. L. No. 104-182, § 114(b).

248. 62 Fed. Reg. 60721 (November 12, 1997).

249. SDWA Amendments of 1996, Pub. L. No. 104-182, § 114(b).

250. Personal Communication with Henry Kim, FDA Cen ter for Food Safety and Applied Nutrition, November 20, 1998.

251. See, e.g.Sylvia Swanson, IBWA Comments on Bottled Water Stud y: Feasibility of Informing Consumers of the Contents of Bottled Water, November 12, 1997 (comme nts dated December 12, 1997); Kim Jeffrey, Perrier Group of America, Comments on Bottled Water Study: Feasibili ty of Informing Consumers of the Contents of Bottle d Water, November 12, 1997 (comments dated December 12, 1997 ); Jack West, Puro Water Group, Comments on Bottled Water Study: Feasibility of Informing Consumers of the Co ntents of Bottled Water, November 12, 1997, (commen ts dated December 11, 1997) [FDA Docket 97N-0436].

252. Sylvia Swanson, IBWA Comments on Bottled Water Study: Feasibility of Informing Consumers of the C ontents of Bottled Water, November 12, 1997 (comments dated De cember 12, 1997).

253. Jack West, Puro Water Group, Comments on Bottl ed Water Study: Feasibility of Informing Consumers of the Contents of Bottled Water, November 12, 1997 (comme nts dated December 11, 1997) [FDA Docket 97N-0436].

254. Pub. L. No. 104-182 (August 6, 1996).

255. Recommendations of the National Drinking Water Advisory Council, November 1998.

256. SDWA § 1414(c).

257. 62 Fed. Reg. 60721 (November 12, 1997)

Appendix A

SUMMARY OF NRDC'S TEST RESULTS Bottled Water Contaminants Found

Note: To print portions of this chart, in the Print dialogue box choose Properties and Paper and set to Legal and Landscape and click OK; under Print Range choose "from 1 to 1" and click OK (this will print one page and lock in sett ings); then use Print Preview to determine which page(s) to print.

Brand(a)

Test #

Water Type

Purchase Location



Lab Rep. #

Comments









Other

365 1 Natural Spring Water (1.5 liters)

Berkeley, CA

Bottled in Austin, TX

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected


10 (composited)

SA-711-1402

Albertson's A+



Palomar Mtn. Spring

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

0.8 10 (composited)

SA-712-0390

Alhambra

1 Crystal Fresh Drinking Water (1 gal.)

San Francisco


45 Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

0.1 Toluene detected at 12.5 ppb o-xylene at 2.7 ppb


EQI-1-27-29

Toluene and o-xylene are industrial chemicals found at levels below standards. Bottle claims "purified using. . .filtration, ozonation, reverse osmosis, and/or deionization."

Alhambra

2 Crystal Fresh Drinking Water (1 liter)

San Francisco


56 Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected



10 (composited)

SA-711-1403

Alhambra

1 Sport Top Crystal Fresh Drinking Water (16.9 fl. oz.)

San Francisco


Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected


EQI-1 -33a-f

Alhambra*†

1 Mountain Spring Water, "prepared using filtration and ozone" (1 gal.)

San Francisco


>5700†

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Coliforms found at >200*


EQI-1-30-32

HPC bacteria in excess of guideline, and coliforms in excess of FDA standards.

Alhambra†


San Francisco



Not Detected

Not Detected

Not Detected

Not Detected

Not Detected


No coliforms detected

10 (composited)

SA-711-1404

HPC bacteria in excess of guideline.

Apollinaris*

1 Sparkling

Berkeley,

Bad Neuenah

Not Detect

5.6* Not Detec

Not Detect

Not Dete

Not Dete

Not Detected

Results

Fluoride found at

10 (comp

SA-711-

Arsenic level

Mineral Water (1 liter)

CA r-Ahrweiler, Germany

ed ted ed cted cted not received

0.37 ppm, below std.

osited) 1405

exceeds CA Prop. 65 level.

Apollinaris*


No test 7.8* No test

No test

No test

No test

No test No test 10

(composited)

SA-806-2078


Aquafina

1 Purified Drinking Water -- "Purity Guaranteed" Non-Carbonated (1 liter)

Los Angeles

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected


EQI-1-LA6-LA8

Brand(a)

Test #

Water Type

Purchase Location



Lab Rep. #

Comments









Other

Aquafina

1 Purified Drinking Water -- "Purity Guaranteed" (1 liter)

Berkeley, CA

Laurel Bottling Co, Fresno, CA

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected


10 (composited)

SA-711-1406

Aquafina


Houston, TX


Not Detected

Not Detected


5 ppb (just below 6 ppb tap water standard)

Not Detected

Di(2-ethylhexyl) adipate found at 0.9 ppb ( below standard of 400 ppb)

10 (composited)

298808-965 (944-949)

Pthalate (DEHP) is often present as a result of migration from the bottle to the water. The level detected is just below

the EPA tap water standard for this chemical, though there is no bottled water standard (see text).

Aquafina


Houston, TX


Not Detected

No test

No test

No test

No test

No test

No test No test 10

bottles, individually

298-808-965 (934-943)

HPC bacteria test, none found in 10 bottles.

Arrowhead


San Francisco


Not Detected

3.2 Not Detected

Not Detected

Not Detected

Not Detected

Not Detected


EQI-1-37a-f

Arrowhead


Berkeley, CA


5 Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected


10 (composited)

SA-711-1407

Arrowhead


Los Angeles

Not noted

Not Detected

Not Detected

4.3 1.9 1.6 0.8 Not Detected

1.0 10 (composited)

SA 712-0807

Arrowhead


San Francisco


Not Detected

3.1 Not Detected

Not Detected

Not Detected

Not Detected

Not Detected


EQI-1-34-36

Arrowhead


Berkeley, CA

Arrowhead MSW Co., L.A. , CA

Not Detected

Not Detected


Not Detected

Not Detected


10 (composited)

SA-711-1408

Beechnut

1 Water, Fluoride Added (1 gallon)

San Dimas, CA

Palomar Mountain, bottled by Famous Ramona, Ramona, CA

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Fluoride at 0.71 ppm

10 (composited)

SA-712-0392

Black Mountain†


Berkeley, CA



4 1.4 1.8 0.8 Not Detected


10 (composited)

SA-711-1409

Level of HPC bacteria exceeds guideline.

Brand(a)

Test #

Water Type

Purchase Location



Lab Rep. #

Comments









Other

Black Mountain

2 Distilled Water

Not Detected

No test

No test

No test

No test

No test

No test No test

No total coliforms

10 (tested individually)

SA 806-2079

No HPC bacteria detected.

Black Mountain†

1 Fluoridated Water (1 gallon)

Berkeley, CA




Not Detected


Fluoride found at 0.93 ppm* (exceeds standard in warm areas)

10 (composited)

SA-711-1410

Fluoride above standard of 0.8 ppm for added fluoride in areas with average high temp. of 79.3°F. HPC bacteria over guideline level of 500 cfu/ml.

Black Mountain†

2 Fluoridated Water

18,000† (1bottle) 30 (1 bottle) Not Detected (8 bottles)

No test

No test

No test

No test

No test

No test No test

No total coliforms

10 (individually)

SA 806-2080

1 bottle of 10 contained HPC level well over guideline level.

Black Mountain

3 Fluoridated Water

No test No test

No test

No test

No test

No test

No test No test

Fluoride found at 1.3 ppm (exceeds standard in warm areas)

4 (composited)

901-079

Fluoride above standard of 0.8 ppm for added fluoride in warm weather areas (average high over 79°F).

Black Mountain


Berkeley, CA


Not Detected

Not Detected


Not Detected


10 (composited)

SA-711-1411

Black 1 Spring San Black >5,700 3.6 Not Not Not Not Not 0.2 Total 3 (1 EQI Levels of

Mountain*†

Water (1 gallon)

Francisco

Mtn. Wtr.Co., San Carlos, CA

† Detected

Detected

Detected

Detected

Detected coliform count 27*; Toluene found at 8.9 ppb


-1-19-20

HPC bacteria exceed guidelines. Coliforms exceed FDA standards. Toluene is a component of gasoline or industrial chemicals.

Black Mountain

2 Spring Water (5 gal.)

San Francisco


330 Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected


10 (composited)

SA-712-0846

Black Mountain


Berkeley, CA


80 Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected


10 (composited)

SA-711-1577

Calistoga


Berkeley, CA


Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

10 (composited)

SA-711-1578

Calistoga


San Francisco


Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected


EQI-1-1a-f

Brand(a)

Test #

Water Type

Purchase Location



Lab Rep. #

Comments









Other

Calistoga†

2 Mountain Spring Water (6 gal.)

Oakland, CA



Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

0.6 10 (composited)

SA-712-0847

HPC bacteria found at levels substantially exceeding guideline.

Calistoga

3 Mountain Spring Water (1

San Francisco


Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

0.5 10 (composited)

SA-711-1579

liter) Calistoga


Not Detected to 1 cfu/ml

No test

No test

No test

No test

No test

No test No test

No total coliforms

10 (individually)

SA 806-2081

HPC bacteria within guidelines in all bottles tested.

Calistoga*

1 Sparkling Mineral Water, Original Napa Valley (1 liter)

San Francisco

Napa Valley

3 31.8* Not Detected

Not Detected

Not Detected

Not Detected

Not Detected


EQI-1-2-4


Calistoga Sparkl

ing Mineral Water, Original Napa Valley

San Francisco

Napa Valley


No test

No test

No test

No test

No test No test 8

(composited)

SA-901-0797

Arsenic retest found none

Calistoga


San Francisco


Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

10 (composited)

SA-711-1580

Calistoga



No test

No test

No test

No test

No test No test 10

(composited)

SA 806-2078

Canada Dry


Berkeley, CA


Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

0.6 10 (composited)

SA-711-1581

Canada Dry

1 Sparkling Water (1 liter)

San Francisco


1.0 Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Fluoride found at 0.13 ppm, well below std.

10 (composited)

SA-711-1582

Castle Rock

1 "Spring Water Bottled at the Source" (1 liter)

San Francisco

"The Cascade Mountains"

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected


EQI-1-16-18

Brand(a)

Test #

Water Type

Purchase Location



Lab Rep. #

Comments

HPC Bacter

Arsenic(d

TTHMs(e)

Chloroform

BDCM(f)

DBCM

Phthalate (DEHP)

Nitrate

Other

ia(c) (Guidelines 500 cfu/ml; no enforceable standard) in cfu/ml

) (CA Prop. 65 Level 5 ppb) in ppb

(CA & Industry bottled water standard 10 ppb) in ppb

(CA Prop. 65 Level l0 ppb) in ppb

(CA Prop. 65 Level 2.5 ppb) in ppb

(g) (CA Prop. 65 Level 3.5 ppb) in ppb

(Tap water standard 6 ppb) no bottled water standard

(Fed. & CA standard 10 ppm) in ppm

Cobb Mountain


Berkeley, CA

Cobb Mtn. Spring Water Co., Cobb, CA

Not Detected

Not Detected

1.2 Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Bromoform (a trihalomethane) found at 1.2 ppb, below standard

10 (composited)

SA-711-1583

Crystal Geyser*

1 Alpine Spring Water (16.9 oz.)

San Francisco

CG Roxane source, Eastern Sierra, bottled at Olancha, CA


Not Detected

Not Detected

Not Detected

Not Detected

Not Detected 3 (1


EQI-1-26a-f


Crystal Geyser*

2 Alpine Spring Water (1 liter)

San Francisco

CG Roxane source, Eastern Sierra, Olancha, CA

Not Detected

11* click for update

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected


10 (composited)

SA-711-1585

Arsenic level exceeds CA Prop. 65 limit; fluoride level is below standard of 1.4 ppm in warm areas (if natural) but above the warm area standard of 0.80 ppm if added.

Crystal Geyser*

3 Alpine Spring Water

No test 12* click for update

No test

No test

No test

No test

No test No test 10

(composited)

SA 806-2078

Arsenic exceeds Prop. 65 limit and WHO/EU standard.

Crystal Geyser*

1 Napa Valley Sparkling Mineral Water Bottled at the Source (12 fl. oz.)

San Francisco

Napa Valley


Not Detected

Not Detected

Not Detected

Not Detected

Not Detected


EQI-1-25a-f

Arsenic exceeds Prop. 65 limit.

Crystal Geyser

2 Napa Valley Sparkling


No test

No test

No test

No test

No test No test 10

(composited)

SA 806-2078

No arsenic detected.

Mineral Water

Crystal Geyser*


No test 14 ppb click for update

No test

No test

No test

No test

No test No test


SA-901-0798

Arsenic exceeds CA Prop. 65 limit and WHO/EU standard.

Crystal Geyser


Berkeley, CA

Crystal Geyser Water Company, Calistoga, CA

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

10 (composited)

SA-711-1584

Crystal Geyser

1 (1 liter)

Chicago, IL Not

Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

10 (composited)

297719-48 (43-48)

Crystal Geyser

1 (1 liter)

Chicago, IL Not

Detected

No test

No test

No test

No test

No test

No test No test 9

(individually)

297790-836 (810-818)

Brand(a)

Test #

Water Type

Purchase Location



Lab Rep. #

Comments









Other

Dannon 1 Natural Spring Water (1.05 pint )

San Francisco


6 Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected


EQI-1-24a-f

Dannon 2 Natural Spring Water (1 liter)

San Francisco


330 Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

0.8 10 (composited)

SA-711-1696

Dannon 3 Natural Spring Water

New York City


Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

1.2 Di-n-butyl-pthalate at 7.5 ppb; Methylene

10 (composited)

299863-942 (911-916)

Pthalate may be from leaching from bottle top or other packaging materials;

chloride at 1.5 ppb (below 5ppb statandard)

methylene chloride of unknown origin, and at 30% of FDA standard.

Dannon†


New York City



No test

No test

No test

No test

No test

No test No test 10

(individually)

299 863-942 (917-926)


Deer Park


New York City


Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

10 (composited)

299 863-942 (879-884)

Deer Park


New York City


Not Detected

No test

No test

No test

No test

No test

No test No test 10

(individually)

299 863-942 (885-894)

Deer Park


Washington DC

Hegin Township, PA

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

10 (composited)

298 808-965 (879-884)

Deer Park


Washington DC

Hegin Township, PA

Not Detected

No test

No test

No test

No test

No test

No test No test 10

(individually)

298 808-965 (869-878)

Dominick's


Chicago, IL Not

Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

0.6 10 (composited)

297719-48 (31-36)

Dominick's


Chicago, IL Not

Detected

No test

No test

No test

No test

No test

No test No test 9

(individually)

297 790-836 (828-836)

Brand(a)

Tes

Water Type

Purchase

Source of

Contaminant & Level Found(b) Number of

Lab Rep

Comments

t #

Location

Water (if listed)

Bottles Tested

. #









Other


San Francisco, CA


21 2.0 Not Detected

Not Detected

Not Detected

Not Detected

Not Detected


EQI-1-21-23


San Francisco, CA


63 Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

0.8 10 (composited)

SA-711-1697

Fiuggi 1 Natural Mineral Water (1 liter)

Berkeley, CA

A.S.T.I.F., Fiuggi, Italy

7 Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

2.5 10 (composited)

SA-711-1698

Gerber 1 Baby Water with Fluoride (1.5 liter)

Berkeley, CA

AquaPenn Springs, Graysville, PA

2 Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

0.6 Fluoride found at 0.46 ppm, below standard

10 (composited)

SA-711-1699

Gerolsteiner

1 Sprudel Sparkling Mineral Water (1 liter)

Berkeley, CA

Gerolstein, Germany

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

1.0 10 (composited)

SA-711-1700

Glacier Springs


Miami, FL Not

Detected

Not Detected


Not Detected

Not Detected

Not Detected

Aluminum found at 180 ppb (std. is 200 ppb)

10 (composited)

304085-165 (150-155)

Aluminum found at 180 ppb, just below the 200 ppb FDA bottled water standard, set based on taste, odor, and aesthetic concerns. FDA's standard for aluminum is not

applicable to mineral water, but is applicable to purified water.

Glacier Springs†

2 Purified Water

Miami, FL HPC

bacterial overgrowth detected in 1 of 10 bottles tested†

No test

No test

No test

No test

No test

No test No test 10

(individually)

304085-165 (304156-304165)


Hawaii 1 Purified Drinking Water (1.5 liters)

Berkeley, CA

MenehuneWater Co, Aiea, HI

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

10 (composited)

SA-711-1701


Berkeley, CA


Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

5.6 10 (composited)

SA-711-1702



Berkeley, CA


No test No test

No test

No test

No test

No test

No test 5.4 10 (composited)

SA 808-1663

Retest of elevated nitrate level; below FDA standard, of potential concern--see text.

Brand(a)

Test #

Water Type

Purchase Location



Lab Rep. #

Comments

HPC Bacteria(c) (Guidelines 500 cfu/ml; no enforceable standard) in


TTHMs(e) (CA & Industry bottled water standard 10






Other

cfu/ml ppb) in ppb

Hildon 1 Mineral Water-Still (750 ml)

Berkeley, CA


200 Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

5.6 10 (composited)

SA-711-1703


Hinckley Schmidt

1 (1 gallon)

Chicago, IL Not

Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

1.9 10 (composited)

297719-48 (25-30)

Hinckley Schmidt

2 (1 gallon)

Chicago, IL Not

Detected

No test

No test

No test

No test

No test

No test No test 10

(individually)

297 790-836 (790-799)

Hyde Park†


Miami, FL >5700

† Not Detected


Not Detected

Not Detected

10 (composited)

304085-165 (101-106)


Hyde Park

2 Purified Water

Miami, FL Not

Detected

No test

No test

No test

No test

No test

No test No test 10

(individually)

304085-165 (304107-304116)

Retest for HPC bacteria in 10 bottles found none

Ice Age 1 "Glacial Water" (1 liter)

Berkeley, CA

Alpine Creek, Manitoba Inlet, Canada

67 Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

10 (composited)

SA-711-1704

Janet Lee



Albertsons, Boise, ID, distrib.

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

0.7 10 (composited)

SA-712-0393

Janet Lee




Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

10 (composited)

SA-712-0394

Janet Lee




41 Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

10 (composited)

SA-712-0395


Chicago, IL Not

Detected

1.1 Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

10 (composited)

297719-48 (19-24)

Brand(a)

Test

Water Type

Purchase Locati

Source of Water

Contaminant & Level Found(b) Number of Bottles

Lab Rep. #

Comments

# on (if listed)

Tested









Other


Chicago, IL Not

Detected

No test

No test

No test

No test

No test

No test No test 10

(individually)

298 808-965 (800-809)


Houston, TX


1 Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

0.9 10 (composited)

298 808-965 (928-933)


Houston, TX


Not Detected

No test

No test

No test

No test

No test

No test No test 10

(individually)

298 808-965 (918-927)

Lady Lee


San Francisco

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Toluene at 13.9 ppb; o-xylene at 3.0 ppb


EQI-1-53-55




San Francisco

Plant #06-21

20 Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected


10 (composited)

SA-712-0025

Lady Lee


No test No test

Not Detected

Not Detected

Not Detected

Not Detected

No test No test

Toluene at 0.55 ppb, no xylene detected

10 (composited)

SA-806-2086

Lady Lee*

1 Purified Water purified by deionization (1 gallon)

San Francisco

Not Detected

6.5* 54.8* 54.8* Not Detected

Not Detected

Not Detected

0.1 Toluene at 9.5 ppb; ethyl-benzene at 2.0 ppb; m/p-xylene at 3.1 ppb; o-xylene at 6.3 ppb


EQI-1-50-52

Arsenic and chloroform at levels above CA Prop. 65 levels. TTHMs above CA and industry standard of 10 ppb. Toluene and xylene are gasoline

constituents and also used in some industrial chemicals.



San Francisco

Plant #06-21

1 Not Detected


Not Detected

Not Detected

Not Detected

10 (composited)

SA-712-0026

Lady Lee

3 Purified Water purified by deionization (1 gal.)

San Francisco

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

No test No test

Methylene chloride at 4.1 ppb (std. is 5 ppb)


SA-808-1666

Methylene chloride at level just below federal standard.

Lady Lee*


San Francisco

Not Detected

3.2 91.6* 88.9* 2.7* Not Detected

Not Detected

0.1 Toluene at 11.0 ppb; o-xylene at 2.9 ppb


EQI-1-56-58

THM levels in excess of CA & industry standards; chloroform and bromodichloromethane in excess of CA Prop. 65 level. Toluene and xylene are gasoline constituents and also used in industrial chemicals.

Brand(a)

Test #

Water Type

Purchase Location



Lab Rep. #

Comments









Other

Lady Lee*

2 Drinking Water

No test No test


Not Detected

No test No test

Toluene at 0.5 ppb; no xylene found

10 (composited)

SA-806-2085

THM levels in excess of CA & industry standards; chloroform in excess of CA Prop. 65

level. Toluene is a gasoline constituent and used in industrial chemicals.



San Francisco

Plant #06-21

8 Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected


10 (composited)

SA-711-1705

Lucky* 1 Seltzer Water (2 liters)

San Francisco

Salt Lake City, UT, distrib., Am Procurement & Logistics

Not Detected

Not Detected


Not Detected

Not Detected


10 (composited)

SA-712-0027

THM level exceeds CA & industry standards, and chloroform level exceeds CA Prop. 65 level. Fluoride level slightly over CA warm weather area standard of 0.8 ppm if fluoride added (if fluoride is natural, warm weather area standard is 1.4 ppm); identical FDA standard does not apply to seltzer (not defined as "bottled water").

Lucky* 2 Seltzer Water

No test No test


Not Detected

No test No test

n-isopropyl-toluene at 230 ppb; n-butyl-benzene at 21 ppb; Toluene at 1.8 ppb;

SA-806-2087

Chloroform level CA Prop. 65 warning level; THM level exceeds CA & industry standards. High level of n-isopropyl toluene and elevated level of n-butyl-benzene of unknown origin; CA law generally prohibits levels over 1 ppb of these VOCs in

source water, but may have been added in processing.

Lucky 1 Sparkling Water, Sugar Free Rasberry Bev. (1 liter)

San Francisco

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

0.2 p-isopropyl-toluene found at 5.4 ppb


EQI-1-41-43

Master Choice†


New York City

Stockbridge, VT

>5700†

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

1.7 10 (composited)

299863-942 (863-868)


Master Choice†


New York City

1 of 10 bottles had HPC bacterial overgrowth†

No test

No test

No test

No test

No test

No test No test 10

(individually)

299869-878


Mendocino


Berkeley, CA

Mendocino Bev., Comptche, CA

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

10 (composited)

SA-712-0028

Natural Value†


Berkeley, CA

Nat. Value, Sacramento, CA, distrib.


Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

10 (composited)

SA-712-0029

Level of HPC bacteria substantially exceeded guideline applied to bottled water by some states.

Naya 1 Canadian Natural Spring Water (1 liter)

Los Angeles


Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected


EQI-1-LA 15-LA 17

Brand(a)

Test #

Water Type

Purchase Location



Lab Rep. #

Comments









Other

Naya 2 Canadian Spring Water (1 liter)

San Diego, CA


Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

10 (composited)

SA-712-0396

Naya 3 Canadian Spring Water (1.5 liter)

New York City

Revelstroke, B.C., Canada

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

10 (composited)

299863-942 (927-932)

Naya 4 Canadian Spring Water (1.5 liters)

New York City

Canada Not Detected

No test

No test

No test

No test

No test

No test No test 10

(individually)

299 863-942 (933-942)

Niagara*


San Diego, CA

Irvine, CA

35 Not Detected

8.5 3.7 3.1* 1.7 Not Detected

Not Detected

10 (composited)

SA-712-0397

Bromodichlormethane found above CA Prop. 65 level.


No test No test

3.1 1.5 1.1 0.5 No test No test 1

(individual)

SA-901-0800


No test No test


No test No test 8

(composited)

SA-901-0800

Nursery 1 Drinking Water, sodium free fluoride added, not sterile, use as directed by physician or

San Francisco

Not Detected

4.5 ppb

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Toluene found at 12.4 ppb, o-xylene at 3.2 ppb, styrene at 3.0 ppb


EQI-1-47-49


by labeling directions for use in infant formula (1 gallon)

Nursery 2 Drinking Water

No test No test

Not Detected

Not Detected

Not Detected

Not Detected

No test No test

Toluene at 0.57 ppb

10 (composited)

SA-807-0079

Odwalla*

1 Geothermal Natural Spring Water (1 liter)

Berkeley, CA

Trinity Springs, Davenport, CA

1 3.8 Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected


10 (composited)

SA-712-0030


Odwalla*

2 No test 3.9 No test

No test

No test

No test

No test No test

Fluoride at 1.6 ppm*

10 (composited)

SA-807-0080


Brand(a)

Test #

Water Type

Purchase Location



Lab Rep. #

Comments









Other

Opal† 1 Spring Water (1.5

Berkeley, CA

Culver, OR

510† 2.4 Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Fluoride found at 0.16

10 (composited)

SA-712-003

Level of HPC bacteria

liter) ppm 1 exceeded guideline applied to bottled water by some states.


Houston, TX


1 Not Detected


Not Detected

Not Detected

10 (composited)

29808-965 (960-965)


Houston, TX


Not Detected

No test

No test

No test

No test

No test

No test No test 10

(individually)

298950-959

Palomar*


Los Angeles


2 5.8 ppb

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected


EQI-1-LA3-5

Arsenic level exceeds CA Prop. 65 warning level.


Venice, CA


Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

0.6 10 (composited)

SA-712-0398


Los Angeles



No test

No test

No test

No test

No test No test 10

(composited)

SA-808-1664

Pathmark


New York City

Guelph, Canada

1 Not Detected

2.4 Not Detected

Not Detected

0.1 Not Detected

Not Detected

Bromoform (a trihalomethane) was found at 2.2 ppb

10 (composited)

299863-942 (895-900)

Pathmark†


New York City

Guelph, Canada


No test

No test

No test

No test

No test

No test No test 10

(individually)

299 863-942 (901-910)


Pathmark


New York City

Guelph, Canada

Not Detected

No test

No test

No test

No test

No test

No test No test 10

(individually)

299 863-942 (879 & 885-

893) Perrier 1 Sparkl

ing Mineral Water (25 fl oz.)

San Francisco

Vergeze, France

19 Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected



EQI-1-44-46

Chlorotoluene of unknown origin

Brand(a)

Test #

Water Type

Purchase Location



Lab Rep. #

Comments









Other

Perrier 2 Sparkling Mineral Water (25 fl oz.)

Los Angeles

Vergeze, France

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected



EQI-1-LA 36- LA 38

Chlorotoluene of unknown origin.

Perrier*


San Francisco

Vergeze, France

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Di(2-ethylhexyl)Phthalate detected at 12 ppb*

4.3 No detection of 2-Chlorotoluene

10 (composited)

SA-712-0032

Exceeds 6 ppb tap water standard for Di(2-ethylhexyl) phthalate (DEHP), but there is no standard for bottled water for this chemical. California does not allow this DEHP level in the source water for bottled water, but sets no DEHP standard for finished bottled water.


San Francisco

Vergeze, France

No test No test

No test

No test

No test

No test

No test 4.1 No test 10 (composited)

SA-808-1662

Nitrate retest.

Poland Spring†


Washington, DC

750† Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

10 (composited)

298808-965 (819-824)

HPC bacteria found at levels exceeding guideline applied by some states to bottled water.

Poland Spring†


Washington, DC

5 of 10 bottles tested had HPC bacterial overgrowth†

No test

No test

No test

No test

No test

No test No test 10

(individually)

298 808-965 (809-818)



Washington, DC


Not Detected

Not Detected


Not Detected

Not Detected

0.8 Toluene detected at 2.5 ppb, (well below the standard of 1000 ppb)

10 (composited)

298 808-965 (851-856)

Toluene is often an indicator of the presence of gasoline or industrial chemicals, here of unknown origin.


Washington, DC


Not Detected

No test

No test

No test

No test

No test

No test No test 10

(individually)

298 808-965 (841-850)



Los Angeles

Not Detected

Not Detected

47.1* 16.7* 20.1*

10.3*

Not Detected


EQI-1-LA 26- LA 27




Venice, CA


66 Not Detected

22.3* 6.6 8.9* 6.8* Not Detected

Not Detected

10 (composited)

SA-712-0399

THM levels violated CA & industry standards for bottled water, and

bromodichloromethane, and dibromochloromethane exceeded CA Prop. 65 levels.

Private Selection (Ralph's)


Los Angeles

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected


EQI-1-LA 34-LA 35

Brand(a)

Test #

Water Type

Purchase Location



Lab Rep. #

Comments









Other



San Diego, CA


Not Detected

Not Detected

20.1* 8.4 7.4* 4.3* Not Detected

Not Detected

10 (composited)

SA-712-0582




Los Angeles


No test No test

10.4* 9.1 1.3 Not Detected

Not Detected

Not Detected

10 (composited)

SA-808-1665

THM levels violate CA & industry/IBWA standard for bottled water.


Miami, FL Not

Detected

1.3 45† 41 3.2 0.2 Not Detected

0.8 Acetone found at 11 ppb (no std.); styrene found at 0.6 ppb (below std. of 100 ppb)

10 (composited)

304085-165 (085-090)

THM levels violate industry/IBWA standard of 10 ppb (no longer enforceable in FL)





8 (composite sample)

361 436-37 (36)






1 bottle

361 436-37 (37)


Publix 4 Drinking Water (1 gallon)

Miami, Fl Not

Detected

No test

No test

No test

No test

No test

No test No test


304085-165 (304091-304100)


Miami, FL 1 Not

Detected

15† 14† 0.9 Not Detected

Not Detected

Not Detected

Styrene found at 0.2 ppb (below std. of 100 ppb)

10 (composited)

304085 (117-122)

THM found at level exceeding 10 ppb industry/IBWA standard (no longer enforceable in FL). Styrene from unknown source.


Miami, FL 5 of 10

bottles tested contained HPC "bacterial overgrowth"†

No test

No test

No test

No test

No test

No test No test

No test 10 bottles (individualy)

304085-165 (304123-304132)


Puritas 1 Drinking Water (1 gal.)

Los Angeles


Not Detected

3.2 Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected


EQI-1-LA1-LA2

Puritas†


Berkeley, CA


990† Not Detected

Not Detected

Not Detected

Not Detected

Not Detected


Not Detected

10 (composited)

SA-712-0033


Brand(a)

Test #

Water Type

Purchase Location



Lab Rep. #

Comments









Other

Ralph's 1 Mountain Spring Water (1.5 liter)

Los Angeles

"California Mountains," L.A., CA, distrib.

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected


EQI-1-LA 28- LA 30

Ralph's 2 Mountain Spring Water (1.5 liters)

San Diego

"California Mountains"

270 Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

0.6 10 (composited)

SA-712-0583


Houston, TX


Not Detected

Not Detected

0.4 Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Bromoform (a trihalomethane) found at 0.4 ppb

10 (composited)

298 808-965 (895-900)


Houston, TX


Not Detected

No test

No test

No test

No test

No test

No test No test 10


298 808-965 (885-894)

HPC retest found none.

Randalls†

1 Deja Blue Drinking Water (1 liter)

Houston, TX


>5700†

Not Detected

29.6† 14 12 3.6 Not Detected

Not Detected

10 (composited)

298 808-965 (911-916)

Levels of TTHM exceed IBWA/industry standards (not enforceable in TX).

Randalls 2 Deja Blue Drinki

Houston, TX

City of Irving Water

Not Detected

No test

No test

No test

No test

No test

No test No test 10

bottles (indivi

298 808-965

ng Water (1 liter)

Supply dually) (901-910)

Rocky Mountain

1 Drinking Water, non-carbonated (1.5 liter)

Los Angeles

"Deep Well Water"

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected


EQI-1-LA 31- LA 33

Rocky Mountain

2 Drinking Water, non-carbonated (1.5 liters)

San Dimas, CA

Santa Fe Springs, CA

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

10 (composited)

SA-712-0584

S. Pellegrino

1 Sparkling Natural Mineral Water, bottled at the source (25.3 oz.)

San Francisco


Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected


EQI-1-38-40

S. Pellegrino

2 Sparkling Natural Mineral Water (1 liter)

San Francisco


Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Fluoride found at 0.37 ppm (below standard)

10 (composited)

SA-712-0034

Brand(a)

Test #

Water Type

Purchase Location



Lab Rep. #

Comments









Other

Safeway*† (CA)


Berkeley, CA

Municipal Source, Safeway Inc., Oakland



Not Detected

Not Detected

Fluoride found at 0.81 ppm (above standard

10 (composited)

SA-712-0214

THM found at level above CA & industry bottled water

, CA, distrib.

in warm weather areas)

standards; chloroform and bromodichloromethane (BDCM) found at levels above CA Prop. 65 limits. Fluoride at level above FDA & state limit for areas with av. high temp. >79.3°F. HPC bacteria above guideline adopted by some states for bottled water.

Safeway* (CA)

2 Drinking Water

51,000† (1 bottle) 12,000†(1 bottle) 2-21 (4 bottles) Not Detected in 4 bottles (see notes)

No test


No test No test 10

(composited for chemical analysis) 10 (individually for bacteria analysis)

SA 807-0081

THM found at level above CA & industry bottled water standards, and chloroform found at a level above CA Prop. 65 limit. Retests of individual bottles that were initially found to contain 51,000 cfl/mu and 12,000 cfl/mu found no HPC and 6,000 cfu/ml, respectively, though these results are unreliable since they were retested beyond EPA-mandated "hold time" after opening.

Safeway (CA)

1 Key Lime Sparkling Water (1

San Francisco

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected


EQI-1-13-15

quart) Safeway*† (CA)


San Francisco

>5,700†

Not Detected

26.4* 26.4* Not Detected

Not Detected

Not Detected

0.1 Total coliforms count 5*; Toluene found at 8.4 ppb


EQI-1-7-9

Coliforms, HPC bacteria, trihalomethanes, and chloroform exceed guidelines/standards. Toluene is a constituent of gasoline and industrial chemicals that should be removed if treated with reverse osmosis. Label claims "prepared by deionization and/or reverse osmosis." Could have been added during processing.

Safeway* (CA)


San Francisco/ Berkeley, CA

Municipal Source, Safeway, Oakland, CA, distrib.

4 Not Detected


Not Detected

Not Detected

Toluene not detected, coliforms not detected

10 (composited)

SA-712-0585

THM levels violate CA & industry standards for bottled water., chloroform and bromodichloromethane exceeded CA Prop. 65 levels.

Safeway* (CA)

1 Select Club Soda (2 liter)

Berkeley, CA


Not Detected

Not Detected


Not Detected

Not Detected


10 (composited)

SA-712-0215

THM levels violate CA & industry standards for bottled water. Chloroform and bromodichloromethane exceeded CA Prop. 65 levels.

Safeway* (CA)

2 Select Club Soda

No test No test


No test No test 10

(composited)

SA-807-0082

Chloroform level exceeds CA Prop. 65 level; Trihalomethane levels over CA & industry standards.

Safeway*† (CA)

1 Select Seltzer

Berkeley, CA

Safeway, Oakland

Not Detected

Not Detected


Not Detected

Not Detected

Fluoride found at 0.83

10 (composited)

SA-712-021

THM levels violate CA & industry

Water (2 liter)

, CA, distrib.

ppm* above warm weather std. for added fluoride

6 standards. Chloroform level exceeds CA Prop. 65 level. Fluoride above 0.80 CA std. for areas with av. high >79.3°F (if fluoride added; if natural, warm weather area standard is 1.4 ppm); identical FDA standard does not apply to seltzer (not defined as "bottled water").

Safeway* (CA)

2 Select Seltzer Water

No test No test


Not Detected

No test No test 10

(composited)

SA-807-0083

THM levels violate CA & industry standards, chloroform level exceeds CA Prop. 65 level.

Safeway*† (CA)

1 Spring Water "Especially selected for its Natural Purity" (1 gallon)

San Francisco

>5700†

Not Detected

56.8* 53.3* 3.5* Not Detected

Not Detected

Not Detected

Toluene found at 14.2 ppb; o-xylene at 3.1 ppb, both below standards


EQI-1-10-12

Toluene and o-xylene are constituents of gasoline and industrial chemicals. This water apparently was chlorinated, suggesting that it could be tap water or if it is spring water, it was subjected to chlorination. Levels of TTHMs exceeded CA & industry standard; level of chloroform exceeds CA Prop. 65 level; HPC exceeded guidelines.

Brand(a T Water Purch Source Contaminant & Level Found(b) Numb Lab Comments

) est #

Type ase Location

of Water (if listed)

er of Bottles Tested

Rep. #









Other

Safeway* (CA)


Berkeley, CA


15 Not Detected


Invalid Not Detected

Fluoride found at 0.28 ppm, below std.; no toluene or xylene found

10 (composited)

SA-712-0217

THM levels violate CA & industry standards. Chloroform level exceeds CA Prop. 65 level.

Safeway (CA)


Berkeley, CA


No test No test

No test

No test

No test

No test

Not Detected

No test


SA 801-0364

Retest for phthalate and semivolatile organics, not detected.

Safeway (DC)


Washington, DC

Safeway Spring, NY

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

0.7 10 (composited)

298808-965 (835-840)

Safeway (DC)


Washington, DC

Safeway Spring, NY

1 of 10 bottles tested had overgrowth of HPC bacteria

No test

No test

No test

No test

No test

No test No test 10


298 808 965 (825-834)


Safeway (DC)

1 Safeway Spring

Washington, DC

Tower City, PA

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Toluene found at 4.7 ppb

10 (composited)

298808-965

Toluene is a constituent of gasoline

Water (1 gallon)

( below the standard of 1000 ppb)

(863-868)

and industrial chemicals, although its source here is unknown.

Safeway (DC)


Washington, DC

Tower City, PA

Not Detected

No test

No test

No test

No test

No test

No test No test 10

(composited)

298 808 965 (857-862, 917)

Sahara*

1 Drinking Water, "Premium" (50.7 oz.)

Los Angeles

1 Not Detected

37.9* 14.7* 14.9 8.3* Not Detected


EQI-1-LA9-11


Sahara*



Bear Spec. & Mktg., San Bernadino, CA, distrib.

Not Detected

Not Detected

15.9* 6.5* 6.6* 2.8 Not Detected

2.5 Fluoride at 0.54 ppm

10 (composited)

SA-712-0586

THM levels violated CA & industry standards for bottled water, and chloroform and bromodichloromethane exceeded CA Prop. 65 levels.

Save the Earth


Berkeley, CA

Baxter Springs, CA

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

10 (composited)

SA-712-0218

Schweppes


San Francisco, CA


Not Detected

Not Detected


Not Detected

Invalid test

Not Detected


10 (composited)

SA-712-0219

Brand(a)

Test #

Water Type

Purchase Location



Lab Rep. #

Comments

HPC Bacteria(c) (Guidelines 500 cfu/ml; no enforc

Arsenic(d) (CA Prop. 65 Level 5 ppb)

TTHMs(e) (CA & Industry bottled water


BDCM(f) (CA Prop. 65 Level 2.5 ppb) in

DBCM (g) (CA Prop. 65 Level 3.5


Nitrate (Fed. & CA standard 10 ppm

Other

eable standard) in cfu/ml

in ppb

standard 10 ppb) in ppb

ppb ppb) in ppb

) in ppm

Schweppes


San Francisco


No test No test

No test

No test

No test

No test

Not Detected

No test 10

(composited)

SA 801-0360


Schweppes


Berkeley, CA


Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Invalid test

Not Detected


10 (composited)

SA-712-0220

Schweppes


San Francisco


No test No test

No test

No test

No test

No test

Not Detected

No test 10

(composited)

SA 801-0361



Berkeley, CA


Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected


Not Detected


10 (composited)

SA-712-0221


Berkeley, CA


No test No test

No test

No test

No test

No test

Not Detected

No test 10

(composited)

SA 801-0365


Sparkletts†


Los Angeles



Not Detected

Not Detected

Not Detected

Not Detected

Not Detected


EQI-1-LA 12-LA 14

Heterotrophic Plate Count Bacteri (HPC) exceeded guideline.

Sparkletts

2 Crystal Fresh Drinking Water -- "Meet or Excee

Venice, CA


140 Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

10 (composited)

SA-712-0587

HPC level below guidelines in retest.

d all State and Federal Water Quality Standards" (1 liter)

Sparkletts

1 Distilled Drinking Water (1 gallon)

Venice, CA


190 Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

10 (composited)

SA-712-0588

Sparkletts†

1 Mountain Spring Water (33.8 oz.)

Los Angeles


>5700†

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected


EQI-1-LA 18-LA 20

Heterotrophic Plate Count Bacteria (HPC) exceeded guideline.

Sparkletts


Venice, CA


Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

10 (composited)

SA-712-0589

HPC Not Detected.

Brand(a)

Test #

Water Type

Purchase Location



Lab Rep. #

Comments









Other

Sparkling Springs

1 (1.5 liter)

Chicago, IL Not

Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

3.1 10 (composited)

297 719-48 (37-42)

Sparkling Springs

2 (1.5 liter)

Chicago, IL Not

Detected

No test

No test

No test

No test

No test


297 790 836 (819-827)

Vittel* 1 Mineral Water (1.5

Berkeley, CA

Vittel Bonne Source Well,

Not Detected

11* 9.3 9.3 Not Detected

Not Detected

Not Detected

Not Detected

10 (composited)

SA-712-0222

Arsenic level exceeds CA Prop. 65

liter) Vittel, France

level and WHO/EU arsenic water limit.

Vittel* 2 Mineral Water

San Francisco

No test 13 ppb

No test

No test

No test

No test

No test No test


SA-901-0799

Arsenic exceeds CA Prop. 65 level and WHO/EU water limit.


Berkeley, CA


11 14* Not Detected

Not Detected

Not Detected

Not Detected


1.3 Fluoride found at 0.17 ppm, well below standard

10 (composited)

SA-712-0223



Berkeley, CA


No test 12* No test

No test

No test

No test

No test No test


SA-808-1667


Volvic 3 Natural Spring Water (1.5 liter)

Berkeley, CA


No test No test

No test

No test

No test

No test

Not Detected

No test 10

(composited)

SA 801-0362



Los Angeles

Vons LA, distrib.

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected


EQI-1-LA 24- LA 25




Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Test invalid

Not Detected

10 (composited)

SA-712-0590


Los Angeles


No test No test

No test

No test

No test

No test

Not Detected

No test 10

(composited)

SA 801-0363


Vons 1 Natural Spring Water (1 liter)

Los Angeles

Vons LA, distrib.

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected


EQI-1- LA 21- LA 23

Vons 2 Natural Mountain Spring Water (1 liter)


Vons Co. LA, distrib.

1.0 Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

0.7 10 (composited)

SA-712-0591

Vons 1 Purified Water (1 gallon


Vons LA, plt. 06-2796

1 Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

10 (composited)

SA 712-0805

) Yosemite Waters†

1 Drinking Water (5 gallons)

Los Angeles /Santa Monica

Highland Park, CA


Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

1.3 10 (composited)

SA 712-0806

Level of HPC bacteria exceeds guidelines.

Zephyrhills


Miami, FL Not

Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

Not Detected

10 (composited)

304 085-165 (133-138)

Note: These tests used established FDA- or EPA-approved test methods, but are not necessarily statistically representative of all bottled water of the brand listed. See text for further discussion.

a Row with bold name indicates level exceeding standard or guideline: asterisk {*} indicates exceeds enforceable standard; dagger {†} indicates exceeds unenforceable guideline. See text and accompanying Technical Report (print report only).

b As discussed in the text, the California Proposition 65 ("Prop. 65") levels noted in this table are derived from the "No Significant Risk" levels established by the California Department of Health Services, and are based on the CDHS’s rules’ assumption that people drink 2 liters of water per day (the same assumption used by the U.S. EPA). Thus, for example, the Arsenic Proposition 65 level is 10 micrograms per day, so assuming 2 liters of water consumed per day, the Prop. 65 Arsenic level is 5 ppb.

c There is no enforceable FDA standard for HPC bacteria. We use 500 cfu/ml as an informal guideline. HPC bacteria are not necessarily harmful themselves but are often used as an indicator of overall sanitation during bottling. The European Union (EU) has adopted an enforceable bottled water standard of 100 colonies per 100 ml (at 22oC) at bottling. EPA’s tap water rules provide that water containing over 500 cfu/ml is treated as a coliform-positive sample absent proof of adequate disinfectant residual. The International Bottled Water Association recommends plants meet a level of <30 cfu/ml at bottling, and <200 cfu/ml in 90% of samples tested 5 days after bottling. Massachusetts and New York have an informal bottled water guideline (unenforceable) of 500 cfu/ml. Other states (such as RI) also have informal guidelines.

d Federal tap water and bottled water standards for arsenic, originally set in 1942 and not revised since, is 50 ppb. Congress has required updated standard by 2001. International (WHO/EU) standard is 10 ppb (see text).

e TTHMs are "total trihalomethanes," potentially cancer-causing chemicals created when organic matter reacts with chlorine. Recent studies also indicate TTHMs may also be linked to birth defects and spontaneous abortions. While California and International Bottled Water Association (industry trade association) standard is 10 ppb, new Federal tap water standard is 80 ppb, and FDA bottled water standard is 100 ppb (see text).

f BDCM is bromodichloromethane, a type of trihalomethane (see above).

g DBCM is dibromochloromenthane, a type of trihalomethane (see above).

Note re Crystal Geyser: The Crystal Geyser company has provided NRDC with test results indicating that beginning in April 1999, Crystal Geyser substantially reduced the arsenic levels in its spring water, in an agreement reached after they were sued (based on NRDC's previous test results) by the Environmental Law Foundation, a California Public Interest Group. This testing shows that as of April 1999, arsenic is either not found, or, if present, is found at levels between non-detectable (<2 ppb) and

4.8 ppb, maximum. These levels are below the California Proposition 65 arsenic warning level of 5 ppb and well below current federal standard, but EPA recently has proposed to drop the federal drinking water standard to 5 ppb.

Appendix B

DOCUMENTED WATERBORNE DISEASE FROM BOTTLED WATER

The bottled water industry (through IBWA) flatly de nies that bottled water has ever caused a disease outbreak--going so far as to assert that the Centers for Disease Control and Prevention (CDC) has found that there has never bee n an outbreak of waterborne disease from bottled water. 1 However, such outbreaks from contaminated bottled water have indeed occurred and are well documented by CDC and others in the scientific literature.

For example, in a published 1996 study of waterborn e disease in the United States, the CDC reported a 1994 outbreak of cholera associated with bottled water that occurred in Saipan, U.S. territory in the Marianas Islands in t he Pacific. 2 FDA bottled water standards apply to this U.S. territory to the same extent tha t they would in any U.S. state. 3 While there was not a full epidemiological study of all those w ho drank the water, CDC reported that at least 11 were known to have become ill, and 4 were hospitalized with serious cases of cholera. 4 The brand of water involved was not named. 5 According to an unpublished Waterborne Disease Outbreak report on this outbreak filed with CDC by local public-health officials, approximately one third of the island re sidents drink water from the company involved, and "thousands" of people may have been e xposed. 6 The total number of people who became ill is unknown.

The bottled water plants producing the water involv ed in this outbreak reportedly obtain their water from municipal water (some of the wells used tested positive for fecal coliform bacteria), but they supposedly then treat the water with state-of-the-art treatment using reverse osmosis. 7 While the bottles used were supposed to have been cleaned by machine or manually with hot water and a chlorine solution, the bottling plants had, according to CDC, "occasionally been cited for the cursory handl ing of returned bottles (e.g., for only rinsing them with treated water.") 8 The CDC reported that during the outbreak, bottled water tested positive for fecal coliform, but the a ctual source of the bacterial contamination in the bottled water was not determin ed.9

Another well-documented cholera outbreak, which occ urred in Portugal, was due to the use of bottled water from a contaminated source. 10 The outbreak occurred in the mid-1970s, but demonstrates the continuing potential fo r contaminated bottled water to spread waterborne disease. According to a study of the aff ected population, there were 2,467 bacteriologically confirmed hospitalized cases of c holera, of whom 48 died. 11 While apparently bottled water was not the only cause of the outbreak, at least 82 patients had a history of drinking bottled water from the contamin ated source. 12 In addition, 36 cholera victims had visited the spa that was fed with the s ame source as used for bottled water. 13 It was believed that the limestone aquifer was contami nated by broken sewers from a nearby village. 14

Historically, other cases of illness from bottled w ater have been documented in the scientific literature. For example, there are publi shed reports showing that bottled water was the causative agent not only in the outbreaks o f cholera just noted, but also illnesses from typhoid 15 and "traveler's disease." 16

Notes

1. See, e.g., International Bottled Water Associati on, "Frequently Asked Questions," (1997).

2. M.H. Kramer, et al., "Surveillance for Waterborn e-Disease Outbreaks -- United States, 1993-1994," Centers for Disease Control & Prevention Surveillance Summaries, Morbid ity and Mortality Weekly Report , vol. 45, no. SS-1, pp. 1-31 (April 12, 1996).

3. See, 21 U.S.C. § 321(a).

4. Ibid .

5. Ibid .

6. Waterborne Disease Outbreak Report Form, filed w ith CDC by Division of Public Health, Commonwealth of the Northern Marianas Islands, dated January 3, 1995.

7. M.H. Kramer, et al., "Surveillance for Waterborn e-Disease Outbreaks -- United States, 1993-1994," Centers for Disease Control & Prevention Surveillance Summaries, Morbid ity and Mortality Weekly Report , vol. 45, no. SS-1, pp. 1-31 (April 12, 1996).

8. Ibid .

9. Ibid .

10. P.A. Blake, et al., "Cholera in Portugal, 1974. II. Transmission by Bottled Water," American J. Epidemiology , vol. 105, pp. 344-48 (1977).

11. P.A. Blake, et al., "Cholera in Portugal, 1974. I. Modes of Transmission." American J. Epidemiology , vol. 105, pp. 337-43 (1977).

12. Ibid .

13. Ibid .

14. .Ibid .

15. D.W. Warburton, "A Review of the Microbiologica l Quality of Bottled Water Sold in Canada. Part 2. The Need for More Stringent Regulations," Canadian J. Microbiology , vol. 39, pp. 158-168 (1993), citing R. Buttiaux, "La Surveillance Bacteriologique Des Eaux Minerales en Bouteilles et en Boites," Ann. Instit. Pasteur Lille , vol. 11, pp. 23-28 (1960).

16. D.W. Warburton, "A Review of the Microbiologica l Quality of Bottled Water Sold in Canada. Part 2. The Need for More Stringent Regulations," Canadian J. Microbiology , vol. 39, pp. 158-168 (1993).

Appendix C

SUMMARY: STATE BOTTLED WATER PROGRAMSa

Survey Questions

State Staff or Budget Dedicated to Bottled Water Program?

Bottled Water Survey?

Regs. More/Less Strict vs. FDA?

State Regulates BW Not Reg’d by FDA?

Additional Labeling Require-ments? (FDA +)

Enforcement Actions Reported?

Violations Data Reported?

Illness Reported?

Testing & Source Certification Requirements?

State Permit Program?

Contaminant Posing Most Threat?

State Recommended Changes Needed?

Notes

Alabama

< 1 FTE

No = FDA

No No No. Two voluntary recalls

No No =FDA Yes No comment

No recommendations at this time.

Alaska

None No =EPA IBWA, & FDA Codes; Alaska does not require annual testing for chemicals & radioactive contaminants

Intrastate, carbonated, flavored waters regulated under same standards as bottled water

No No No No =Fed.; Must comply with Class A drinking water reqts per SDWA

Yes Microbiological

FDA needs definition of "glacier water"; Annual chemical & radiological contaminants testing should be eliminated: tests are expensive and not necessary.

Arizona

1/2 FTE

No =+IBWA Code;

Intrastate regula

No No No No =FDA; Require chemical,

State Certification

Known carcinogens,

Annual inspections;

= FDA

ted same as interstate

radiological and microbial testing; verified by twice-yearly inspections

bacteria

Need more regional approach to chemical & biological testing b/c not all contaminants found in all areas.

Arkansas

None Yes; Data more like lists of lab results

= FDA

Arkansas regulates all bottled water within state

No No No No =FDA; Bottlers must get approval on water source, filtration & chlorination (or other sanitation method)

Yes; Renewed yearly

Coliform bacteria, giardia, other bacteria

Biennial inspection (contact with FDA).

California

2 FTE; 9 investigators state-wide

Not in last 11/2 years

Stricter (THHM, disinfection rules)

No comment from state (but regulations appear to cover such waters)

Must list source, including municipal; Labeling must agree with source listed

State has separate investigative arm; Fines have been imposed; No shutdowns or recalls

No access to specific violations

Yes[

b] Stricter than FDA; Water analysis required to renew annual license; Licenses for plants and source are site-specific; Any changes must be submitted and approved by state

Yes; Renewed annually; Water analysis must be submitted each year

Parasites, cryptosporidium

No comment

IBWA Code Stricter standards & warning labels for many contaminants

Colorado

< 1 FTE

No = FDA, EPA drinking water; Bottlers must keep records of required lab analysis;

No No Yes; Regulatory action mostly for heavy metal or THMs; No "serious" enforcement actions

Small # of violations; Data not available

No Bottlers must meet state reqts, almost identical to EPA drinking water standards for source water (includes well and

Yes Nitrates

Many of our concerns were addressed w/passage of latest FDA labeling regs; Before that, misbranding on

Records must meet EPA drinking water requirements

taken; No shutdowns or recalls

spring construction)

labels was a concern

Connecticut

$50,000

No = FDA +IBWA Code; State code based on Fed. Standards (21 CFR 129, 103) and EPA

CT licenses & regs all manufacturers of nonalcoholic beverages sold in state

Separate state regs

Must request specific information and companies using freedom of information law

Same as above

No response

No response

No response

VOCs from underground fuel tanks

None

Delaware

None No No active regulatory oversight or permit program; No separate state code

Delaware does not have a state program for bottled water

No No No; Any violations would be recorded in home state

No No state requirements

No No comment

Pending the start up of in-state bottlers, the state would need to develop & implement a state BWP

No bottlers in DE

District of Columbia

None No =FDA No No No No No DC reqs bottlers to send copy of most recent inspections of water source in DC; Agency is new, but will eventually adopt FDA inspection policies

No Chemicals, bacteria, waste contaminants

Proper labeling so that labels are accurate, not misleading; Bottled water used for babies & other at-risk groups should be clearly labeled

Florida

2 FTE

Food Lab. collect

=FDA Intrastate sales

No No Listed in record

No =FDA; Inspections and

Yes; Renewable

No comment

None IBWA Code

s random samples from food shelves

s at Dept. of Agric.; No database

analytical results conducted in field

annually

Georgia

None dedicated specifically to BWP

Pesticide analysis on end-product on random basis

=+FDA; GA regs used to be much more stringent

GA regulates all bottled, flavored, carbonated water

No Yes; Some springs have exceeded radioactive limits: use denied or shutdown

GA working on database for sampling results; Summary of violations not feasible at this time

No answer

GA issues starter kits for bottlers

No answer

No problems w/chemical; Some bacteriological

None; "Bottled water as a food is probably one of the safest items on the market"

Hawaii

<1/5 FTE

Yes; Hawaii samples bottled water product on regular basis; Test for bacteria & chemicals

=FDA; Used to have stricter laws than FDA (IBWA Code)

No Yes (not specified)

Not in past 4 yrs; Recalls in past b/c of too much coliform bacteria & "filth"

Info available through FOI request

No Source must be approved, then license/ permit issued

Yes; Renewable every 2 yrs; Sample end-product

Microbiological contamination in source

No comment at this time

<10 bottlers in state

Idaho None No =but cover intrastate; Must comply with Idaho drinking water regulations

Idaho regulates intrastate bottlers only; FDA handles all interstate

Intrastate labeling law prohibits misbranding

No No; Only regulate intrastate bottled water sales; Non-critical violations not recorded; Sanitation violations not included

No Must apply w/ plan review, pre-operational inspections; Must qualify under HACCP prior to getting license; Must meet labeling requirements

Yes; License renewable annually

No comment

None

Illinois

None; No separate state BWP

Yes; 2 surveys on water bottlers in past 5 yrs; Report available through FOI request

=FDA, except 1 gal+ must add safety seal

Intrastate bottlers regulated

No Yes; Most enforcement actions in form of lettersc

Probably available, but would require great deal of resources to get info.

No answer

No state certification process; Source only inspected upon request

No state certification process; Inspections of bottlers conducted annually

Microbiological

State should adopt licensing process, providing more control & leverage

Indiana

None No =FDA; State does not have separate code

Intrastate sales of bottled water

No No Inspection reports made, but not gathered in database; Would require extensive time & labor to compile

Yes[

d] Testing =FDA; State does not certify source; Private source needs satisfactory bacteria/

radiological physical & chemical analysis of source by state lab before approval

No state permit, license or certification process

No comment

None

Iowa None No =FDA State does not directly regulate end-product from out of state

No Enforcement actions for food safety, labeling violations; No shut-downs or recalls

No summarized statistical data available; Info not stored in database

No Testing=FDA; Bottlers must sample end-product before license issued; Only private sources must sample

Yes; License renewable annually

Microbiological

Need more sampling for chemical residues on national level by FDA & it should do more actual testing

Kansas

<1 FTE

No Less stringent; No separate state regulations

Yes; Bottled water is "food" & subject to Kansas Food & Drug Act

=FDA; General labeling requirements of Kansas F & D Act

No Current computer system could not pull out this info

No answer

Kansas has

no statutory authorization to issue permits, licenses, or certificates for BW proces

No No comment

Would like to update state code to similar to industry model code or FDA’s regs

sors, plants, or distributors

Kentucky

None No =FDA Intrastate; Out-of-state bottlers submit most recent water analysis, permit & label for review prior to distribution in KY

=FDA

Yes; Warning letters issued

Only in inspection results

No answer

Intrastate source certified by Natural Resources & Environmental Protection Cabinet; No out-of-state source certification

Yes Chemical

Specific bottled water regulation

Louisiana

1/3 FTE

State samples end-product every 3 months, from both in- & out-of-state

=FDA Intrastate must get permit; Out-of-state must register with state, send water & plant approval, labels, lab analysis

=FDA

Violations listed from routine inspections; No shutdowns, recalls

No No Stricter than FDA; Out-of-state must register; In-state must apply for & obtain permit

Yes Microbiological, carcinogens

No comment

Maine <1/2 FTE

No =EPA Intrastate sales; In-state bottler inspections annually

Yes; If source or end-product exceed MCLs, must be listed on label; optional listin

None Listed in database; Take 1/2 hour to gather; Sorted by water systems

None

Must submit test results, site map, copies of labels, inspection reports prior to state certification

Yes; does not need to be renewed

Microbiological, nitrate/nitrite

Equalize drinking & bottled water regulations; Source listing on labels

g of analytical results; must list altered water quality

Maryland

None No, but bottlers required to conduct sampling through state-certified lab

=FDA Intrastate sales

Yes; Source of water must be listed on labels; Labels must meet Nutrition Labeling Act requirements

Yes[e] Database

None

Stricter than FDA; Bottlers required to do EPA primary drinking water analysis of source; Bottlers must pass sanitation inspection

Yes Bacteriological

Has requested funding & staff be increased to add 2 FTE; EPA should add cryptosporidium to drinking water checklist

THHM=10ppb, IBWA code, 100ppb chlorine; disinfection

Massachusetts

1/3 FTE

Yes, annually

= FDA +IBWA Code

Intrastate, carbonated, all nonalcoholic beverages

Yes. Source must be listed

Denials of applications

No No Must get Dept. Envtl Protection (DEP) approval

No response

VOCs None IBWA Code

Michigan

No response

State samples bottled water on routine basis, at least once/year

=FDA & SDWA

Intrastate sales, carbonated, unprocessed public drinking water, water dispensing machines

Declaration of identity, name & address of bottler, and declaration regarding carbon dioxide

"No legal actions" 4 years

No (will provide for $200/year)

No Essentially=

FDA; Annual inspection by independent 3rd party

Annual registration for each brand

No response

No response

Minnesota

None Yes; Currently sampling 459 sample

=FDA Separate state code

Yes; State rules & CFR requir

No No No response

State does not certify source; License firms

Yes; See above

Nitrites & pesticides (spring water)

State rules need updating (from 1993)

s of bottled water for metals; Samples taken from retail stores

ements

located in state; No longer issue permits to out-of-state firms

Mississippi

3 FTE for all state bottling facilities

Try to sample each bottled water product sold in state on monthly basis for E. coli & bacteria

=FDA Intrastate regulated same as interstate

No Bottled water products not meeting standards will be withdrawn (done in past)

No No answer

Must submit testing, geological survey, engineer certification & report, preliminary site inspections; If approved, state issues source certification

Yes; See above; re-cert every 3 years

No response

More FDA oversight needed; FDA program analysis of state’s bottled water program & assist it as necessary

Missouri

<1 FTE

Yes; Annual survey[f]

=FDA, except state requires pseudomonas testing

Intrastate; Seltzer water; All bottled waters regulated same as all other beverages

=FDA

No No; Currently working on database

No answer

Private source only;[g] Spring source must get private lab chemical & bacteriological analysis testing; Source must be protected from surface contaminants

Yes; See above

No response

None

Montana

1/20 FTE

Random monitoring program at plant for finished product every 2–3 years

More stringent; State monitors water quality more closely; Stricter definiton of & spring

All bottlers regulated under licensing programs as food processors

In-state labeling definitions more stringent; If labeled & organic& must be verified by 3rd

Yes; 3 recalls (2 microbial contaminations, 1 misbranding); No shutdowns

No No In-state bottlers apply to DEQ & meet EPA standards; Out-of-state bottlers must provide certification from source state public health

Out-of-state must register & obtain license (automatically renewed annually unless violations); In-

Nitrates (greatest risk to pregnant women); heavy metals & bacteriological in terms of protecti

FDA’s honesty in labeling should extend to artesian, spring, and other definitions of bottled waters

All in-state bottlers must become Public Water Systems (PWS) & meet EPA drinking water standa

water&

party & organic certification group&

agency state must apply to DEQ and become PWS; License issued upon approval as PWS (automatically renewed annually unless violation)

ng public

rds

Nebraska

None No (last bottled water survey done in 1991)

=FDA Intrastate bottlers must follow same guidelines as interstate

No No Yes, but data available would have more to do with sanitation violations rather than analytical results

None

Testing =FDA; Source does not have to be certified, but bottlers must supply satisfactory analytical results before processing begins

Yes, see above; Permit renewed annually; Bottlers do not need to submit analytical results to renew permit, but must have FDA test results on hand at plant; State conducts spot-checking on random basis

Testing & analytical process is effective at preventing contamination

Reduce testing for unlikely contaminants; FDA requirements should not be made any more stringent

Nevada

$5000 or 1/10 FTE

No =FDA Intrastate; All bottled waters produced in state are

Source, name & address of bottler must be on

Yes; Denial of permits for distribution into state withou

Violation data kept in paper files for local produ

None

Must submit detailed chemical & bacteriological analysis on source;

Testing = FDA, SDWA

Permit renewed annually; Bacteriological analysis must

Coliform; Bacteriologicals

Pretty happy with our regulations right now

covered by various portions of state code

label; If making any claims such as to low sodium or flouride content, must list levels found in product

t meeting chemical parameters; One local bottler had high bacteria levels found in sampling, resulting in voluntary recall of end-product

cers only; No data on out-of-state violations

be submitted every week if plant in "full" operation

New Hampshire

<1 FTE

No =FDA, +IBWA

Intrastate; License other waters, such as filtered waters

Accurate source listing (no misleading brand names)

Yes; Enforcement letters and permit actions; One recall and 2 shutdowns in last 4 years (no details available over phone)

No No Testing= FDA; Source certified through Dept. Environmental Services

Permitting program for source and bottling facility; Must submit analytical & hydrogeological reports; Plant permits renewed annually & analytical reports must be resubmitted with renewal application

No comment

More money/ staff in some states

Strong label requirements

New Jersey

1 FTE

Yes (annual). Spot checks of bottled water

=FDA; Some parameters stricter than federa

Intrastate; Carbonated water covered under

Source must be listed on label; Two-

Yes; 2 recalls in 1995–96;[h] No shutdowns

Annual summary of test results to legisl

No Testing = FDA & EPA drinking water standards; Must submit

License must be renewed annually and bottler

No particular contaminants have consistently

No comment

IBWA Code; Annual enforcement/ violation

sold and produced in state; State rules require periodic submission of samples for review by state health dept. lab

l standards (=EPA drinking water standards)

bottled water rules; Other types of waters may be classified as beverages & regulated as nonalcoholic beverage product

year expiration date (from time of bottling)

within last 4 years; Regulatory letters sent for various violations, primarily for unsanitary conditions; No fines or penalties assessed; No actions against in-state bottlers for violations of safe drinking water standards

ature mandated by state statute

analytical results of source testing showing compliance with state drinking water act standards; Spring sources must be protected from outside sources of contamination at discharge point

s subject to periodic inspections; Source and end-product subject to mandatory periodic testing at a DEP certified water testing lab

exceeded established standards

report mandated by state statute

New York

1–11/2 FTE

No (last survey in 1992)

Stricter (total SOCs)

Intrastate regulated same as interstate by state; Seltzer and carbonated waters not regulated under bottled water rules

Must list source, owner, certificate number & date water bottled; Nutritional claims must be consistent with FDA regs; Variances must be listed on label

Yes Violation data kept in paper files

No Testing= Stricter monitoring; Source must be certified & meet standards in building design & water quality (through certified lab)

State issues certification numbers; Renewed annually; All sampling & other requirements must be resubmitted upon renewal application

Microbiologicals

Uniform labels, FDA standards = EPA; NY’s goal is to become more consistent with national standards

Standards may be waived; IBWA Code

North Caroli

No com

No = FDA

Intrastate;

No Yes No No Testing = FDA; In-

No permit

No comme

None at this

Bacterial

na ment (adopted by reference into state code)

Seltzer water considered a beverage & regulated under different part of state code

state bottlers must get source approved (one-time approval); State occasionally does unannounced inspections and sampling

program

nt time contamination incidents reported

North Dakota

<1/4 FTE

No, but state is considering conducting survey of

water vending machines if time & resources allow

"much less stringent"

State has jurisdiction over all water bottlers not already under FDA’s jurisdiction

No No No No "Little if any testing;" Bottlers do not have to submit source analysis; Source must be "unadulterated"

Licensing program for facilities; Renewable annually

Probably nitrates

Should = EPA rules; State should adopt regulatory provisions when and if the demand arises; "Little need" for an additional state regulatory scheme

Ohio Approx. 1 FTE

Yes. Water quality survey on 5-gallon containers of bottled water, but not smaller (ice also surveyed)

=FDA Intrastate regulated same as interstate

Must list source if non-municipal; Any additives must be listed

Yes; Embargoed 5-gallon containers with high standard plate count; No recalls

No No Testing = FDA; Source must be inspected and declared acceptable by EPA

License is renewable yearly and all data/test results must be resubmitted

Bacteria

None IBWA Code

Oklahoma

1 FTE

No = FDA

Yes Yes No response

Yes; Inspection reports (not provided)

No = FDA; Bottler must send chemical, radiological, & bacteriological analysis & have contamin

Permit renewable annually; Renewal based upon compliance with

Bacteria

Truth in labeling

IBWA Code

ant levels within acceptable parameters

regulations

Oregon

1/10 FTE

No = FDA; State does more inspections than FDA

State regulates all water and beverage bottlers

No Yes. Action against bottler claiming source water was spring water when it was not

Yes (Summary report of violations for period 1/1/94–12/31/97)

"No listings available"

= FDA plus must meet state drinking water requirements for location, design, construction and water quality

Bottlers licensed as food processors; Reciprocity to bottlers to out-of-state bottlers; Licenses renewed annually

None; Water in compliance with standards does not pose any great risk to consumers & our program is adequate to assure compliance

Support FDA change

Pennsylvania

None Occasional bottled water quality surveys in 1992; Some VOC contamination found

Stricter

Intrastate; Waters with additives & bottled water under 1/2 gallon regulated by Dept. of Agriculture

Must list source; If source is taken from "finished water source," i.e., a public water system, must list name

Yes (5 permits revoked, 6 recalls); Mostly informal notices to bottlers of violations, w/set period time to correct violations; No recalls in 4 years

Yes No Essentially = FDA; Must submit source sampling that meets all Maximum Contaminant Levels; Once approved, source need not be monitored; Finished product must be tested weekly for coliforms

Yes Microbials, especially cryptosporidium & giardia

Reciprocity among states as to accepting analytical results & some sort of standardization among the different states’ labs

IBWA Code

Rhode Island

1/5 FTE

Occasionally RI takes random samples of end-product off retail shelve

= FDA; some sections of state code more stringent, e.g., RI requir

State regulates all bottled water, including carbonated; If natural

Source must be listed unless run through a deionizer (reverse

1 recall of baby water b/c of mold contamination; Informal actions

Must request from database and paper files

No = FDA & EPA; Out-of-state must send analytical report and approval letter from appropria

Yes; Bottler must submit end-product & source samples with annual renewal

Microbiologicals

More stringent than FDA labeling reqts, e.g., specific location & name of water source;

s & conducts microbiological analyses

es dedicated line for bottling water

juices added, regulated as soft drink under different part of state code

osmosis); Municipal waters without deionizaton process must list source

for other incidents, including chlorine contaminationi

te state agency; In-state must submit analytical report engineering drawing with location of spring source & everything within 1700’ radius

application

Shift focus away from health claims to more accurate labeling

South Carolina

<1 FTE

No More stringent b/c state follows EPA standards for drinking water

State regulates and permits construction of bottling & treatment facilities & monitor source & end-product

No comment

Yes; Enforcement actions taken over past 4 years mostly related to non-permitted construction activities & unapproved water bottling facilities

"No major violations;" All SC bottlers kept on water system inventory & assigned a water system number

No Bottler must submit plans & specifications for their design & construction for review under state code; Source must be tested for water quality

Yes; State issues permit to operate; Currently, permits need not be renewed; Regulatory changes will most likely impose a periodic renewal requirement in near future

Giardia & cryptosporidium (in terms of one-time exposure health risk)

Adopt model code; Need consistent standards for all states

FDA does monitoring & inspection

South Dakota

<1 FTE

State conducts yearly bottled water survey

Less stringent than FDA

Only one intrastate bottler, subject to state regulations only which are less stringent than FDA

No No Yes; Computerized data base of violations

No All sources in SD currently public water sources & are approved upon verification as municipal source after inspection(municipal sources must meet safe drinking water

No Since all sources are municipal & must meet safe drinking water requirements anyway, there is no great risk to bottled water consumers

Recommend that SD bring state regs up to FDA requirements

requirements); No natural spring sources in SD

Tennessee

No response

No = FDA

No response

No response

Not provided

Not provided

Not provided

Not provided

No response

No answer

No answer

Texas <1 FTE (300 hundred bottlers)

Yes; State inspects each firm individually & inspects at least annually; Private businesses send out their own quality control people to make sure finished product meets quality standards

More stringent; More frequent inspection program; Requires source labeling & certification of operators under Bottled Water Certification Program

All beverages manufactured, packaged and labeled in state are regulated as food; Water vending machines regulated

Source must be labeled; Chemicals or bacteria that exceed Maximum Contaminant Levels must be listed (must state on label "contains excessive bacteria")

Yes; Bottler fined approximately $1250 for operating without certification; Recall in Dallas 1–2 years ago b/c of gross misbranding

Yes (not provided); State keeps copies of warning letters, but no summary reports available

No Testing = FDA; Source must meet non-community public water system standards & state issues "Source Certification" letter (one-time)

State licenses bottled water plants & vending machines; Renewed annually; Water quality analysis must be resubmitted annually to EPA certified lab unless city source

Bacterial contamination

More FDA oversight where states have inadequate programs; Re-institute certification program

IBWA Code; Bottled Water Certification Program

Utah <1 FTE

No = FDA

Intrastate bottled waters regulated same as interstate

No Informal hearing held b/c company not permitted; Bottler now bottling water from another source; No recalls, shutdowns, or other legal action

No No Testing = FDA; Water quality analysis of source must be submitted; Bottling facility inspected before approval

No; State does not currently approve source, but environmental inspections required before company starts operations

Pesticides, fertilizers

Current regulations on both state & federal level adequate

Vermont

<1 FTE

Dept. has requested random sampling, but has not occurred

More stringent than FDA: State has stricter labeling requirements, chemical contaminant levels, & name of bottler

Intrastate sales of bottled water regulated same as interstate; No regulation of seltzer, carbonated, or flavored waters

Source, town & state of bottler, & finished product levels of chemical contaminants of arsenic, lead, sodium, & nitrates

Yes; Approx. 4 years ago, bottler was fined for using unapproved source

Yes; Computer data base of violations

No Bottler must apply for permit & submit hydrogeological info on source, schematic diagram of treatment facility & engineering facility; Copy of labels, chemical results for source & finished product, recall plan, list of foreign Country requirements.

Permit must be renewed every 5 years; Bottlers must resubmit water quality analysis & copy of most recent license & inspection program

Microbiological & VOCs

More frequent inspections of facilities, random testing of end product & active participation & support by FDA; FDA’s definition of "spring water" needs to be less ambiguous

Virginia

1–2 FTE

State samples regularly for bottled water quality, but no survey in past 5 years

= FDA

Intrastate; Seltzer & carbonated waters regulated same as other bottled waters

No State enforcement actions have included enforcement letters, a formal hearing, and court action which resulted temporary shutdown; Will provide for $235.80

Information kept in data base; Will provide for fee

Will provide for fee

State does not issue certification, but source needs to be tested & meet standards with respect to microbiological quality, physical turbidity, and chemical quality & radiological quality; plant inspections every 4 months

State does not have a permitting program: State is not empowered to permit of license

Microbiological contaminants

Adopt state licensing or permitting program which would enable state to address food safety issues in a more timely manner

Washington

1/3 FTE; $20,000

Not sure

We adopt federal regulations verbatim; State inspec

Yes No (same as 21 CFR 129)

Yes; Warning letters & notices of corrections issued

No No Bottler must go through source approval process with Dept. of Health, Division

Licensing renewed annually; Water quality analysis

(1) Bacteriological–due to post-process contamination; (2) Primar

No suggestions

ts bottled water operations on much more frequent basis than FDA

approximately to 6–10 bottlers; License suspension/civil penalty issued against one bottler; Civil penalty action issued against one bottler

of Drinking Water, including site inspection & chemical, bacterial, and physical analysis

required per CFR schedule, but not in order to renew license

y inorganics; (3) VOCs

West Virginia

1/2 FTE

No; State relies on bottlers to do required sampling in accordance with CFR reqts

= FDA; More stringent reporting requirements; Bottlers must test weekly for bacteriological contaminants & submit their reports to state agency by 10th of each month

Intrastate; Flavored & seltzer waters currently regulated under soft drink regulationss

No Yes; Mainly for technical permit violations, not for quality violations; Formal notices based upon consumer complaints of mold growth; No recalls

Yes; Information stored in hard files and would require substantial resources to compile

Yes[j

] WV does not have separate permitting program for source; Chemical tests followed by on-site physical inspection of plant; Source must be protected from outside contamination at point of discharge and draw area

Permitting program for facilities; Renewed annually; Bottlers must submit chemical analysis for both source & end-product and have satisfactory physical inspection to renew

WV has never really had a problem with either in-state or out-of-state contamination

State regulations need updating to meet standards of most recent CFR regulations; Currently, WV is following most recent CFR regs by interpretation only

Annual inspections

Wisconsin

<1 FTE

Yes; State statute requires publication of annual bottled water quality analysis report

= FDA; Exceeds in some areas, e.g., some state bottled water plant facility

Intrastate, seltzer, carbonated, all bottled water establishments regulated

No State has had some regulatory dealings which have been handled by working with

No (stored in paper files)

No answer

Bottles must contact DNR & have inspectors approve & verify source & construction; Source must be analyzed for

Permits renewed annually; Bottlers must maintain analysis criteria & testing

Lead Regulatory scheme of state is more than adequate to protect both consumers & bottling facilities

regulations much more stringent than FDA requirements

under ATCP (Agriculture, Trade & Consumer Protection)

bottlers without further legal actions; State reports few problems with bottled water facilities; 1 problem with pre-consumer lead contaminationk

contaminants

schedule to renew license

Wyoming

<1 FTE

No; State goes by what bottles must sample per CFR requirements

= FDA; State code is modeled after IBWA code; Separate state code adopted in Sept. 1986 & refers to CFR often

State regulates everything manufactured in-state; Out-of-state processors must apply for distribution permit; Contractual agreement with FDA to do federal inspections

Specific source must be listed; Municipal water must be labeled as "drinking water"

No; One incident of misbranding in which source labeled as "spring" when really tap; Bottlers response was to find a spring as source

Yes; Violation data stored on computer data base

No Bottler must submit proof of approved source from previous testing; State inspects in-state sources & processing plants upon initial application

State issues Food Handlers License; Renewed annually; Source sampling not required to renew license; Out-of-state processors must submit proof of approval by state authority, copy of labels, & last inspection results

Cryptosporidium & giardia (problems in municipal sources)

Rules should be put in layman’s language to increase voluntary compliance

IBWA Code

a Information based on NRDC Survey conducted late 1995 -- early 1996, updated with information publicly available from International Bottled Water Association, 1998, regarding states which have adopted IBWA’s model code, and, most recently updated with information gathered as a result of a state-by-state

telephone and fax survey conducted April–May, 1998

b While a 11/27/95 letter to NRDC from California Department of Health services indicated "no reports or listings [of illnesses or poisonings] are available at this time," the state attached a summary of numerous citizen complaints about adulterated or contaminated water, in which injuries to consumers were reported. Moreover, a 1985 California Assembly Office of Research found numerous complaints by bottled water consumers who alleged illnesses. Bottled Water & Vended Water: Are Consumers Getting Their Money’s Worth? (1985).

c One incident in which firm bottled water from municipal source without boiling during boiled water order; Resulted in voluntary recall of water product involved; No injuries reported from this incident.

d Indiana State Department of Health reported 3 illness incidents: (1) 1/25/95 "suspect pseudomonas," illness reported, from Anita Springs water; (2) Kroger Springdale water, 10/27/94 "off taste/not confirmed," illness reported; Hinkley & Schmidt, 12/2/93, "foreign material/not confirmed," illness reported. These statements were not independently verified by NRDC and should be viewed as unconfirmed.

e Generic descriptions of enforcement actions taken by the state of Maryland over the past four years include: Detention orders, in which the state retained water bottled under questionable conditions (2–3 times in last four years); Denial of applications due to lack of or incomplete information; Detained water for failure to renew annual license (approximately 10 occurrences in last four years); Maryland has not enforced any shutdowns, brought court action, or made any recalls in the past four years.

f Annual survey must include standard plate count, coliform, pseudomonas, yeast, mold, chemical, & radiological analysis.

g If source is municipal, no certification or testing is required because municipal water already subject to regulatory requirements.

h Recalls were based upon consumer complaints for alleged presence of mold and involved out-of-state companies. The two companies reportedly involved were Triton Water Company, Burlington, NC, and Aquapenn Spring Water Company, State College, PA. No injuries were reported as a result of either one of these incidents.

i Poland Springs conducted voluntary recall after unacceptable levels of chlorine contamination found in end-product. At that time, Poland Springs did their own recall. Rhode Island officials found out about the chlorine and contamination only after the fact from state of Massachusetts. Poland Springs did not notify Rhode Island. No further action was taken by Rhode Island.

j Illness of two individuals likely caused by "contamination after purchase through absorption through plastic."

k State detected lead in end-product bottled water while still at bottling facility (lead exceeded Preventive Action Limits (PAL), but not enforcement standards. The result was that the bottler voluntarily replaced defective equipment and corrected the problem. There were no injuries or illnesses reported.

Credits

Principal Author Erik D. Olson, J.D.

With the Assistance of Diane Poling, J.D. Gina Solomon, M.D., M.P.H.

Production Supervision Sharene Azimi

NRDC Director of Communications Alan Metrick

Copy Editing Michele Wolfe

Electronic Assembly Bonnie Greenfield

Cover Design and Photos Jeff Jenkins/Jenkins & Page

Acknowledgments

NRDC gratefully acknowledges the following donors f or their support of this project: Henry Philip Kraft Memorial Fund of the New York Co mmunity Trust, The Town Creek Foundation, Inc., Susan Kendall Newman, and Kathlee n Unger. As with all our work, publication of this report would not have been poss ible without the support of NRDC's 400,000 members.

The author is grateful to David Murphy, J.D., for h is valuable research during the early phase of this project, and to Patti Lease, M.S., fo r her careful fact-checking. The author appreciates the assistance of Alan Metrick, Sharene Azimi, Bonnie Greenfield, and Michele Wolf in making this a far better product than it wo uld have been without their help. The peer reviewers listed below were also extraordinari ly helpful. All mistakes are, however, the author's alone.

Special thanks to my family, Anne, Chris, and Luke, for putting up with this seemingly eternal project. Thanks also to all those colleague s at NRDC, Clean Water Fund, and Citizens for a Better Environment, and to many stat e and federal officials, who helped make this petition and study possible.

Reviewers Robert Bourque, Ph.D., J.D., Simpson Thacher & Bart lett; Thomas Cochran, Ph.D., Senior Scientist, NRDC; Linda Greer, Ph.D., Senior Scienti st, NRDC; Jeffrey Griffiths, M.D., M.P.H., Associate Director, Graduate Programs in Public Hea lth, Tufts University School of Medicine; Robert Morris, M.D., Ph.D., Associate Pro fessor, Tufts University School of

Medicine; Lawrie Mott, M.S., Senior Scientist, NRDC ; David Ozonoff, M.D., M.P.H., Professor and Chair of the Environmental Health Dep artment, Boston University School of Public Health; Fred Rosenberg, Ph.D., Professor of Microbiology, Northeastern University; Gina Solomon, M.D., M.P.H., Senior Project Scientis t, NRDC; and David Wallinga, M.D., M.P.A., Senior Project Scientist, NRDC. Data verifi cation was conducted by Environmental Data Quality, Inc.

The views presented in this report do not necessari ly reflect the opinions of those who helped to review it.

disodium hexafluorosilicon

CAS Number 39413-34-8

Chemical Formula F6Na2Si

http://www.neis.com/apps/chemicals?m=s&t=16893-85-9 Synonyms: 12656-12-1, 1310-02-7, 1344-04-3, 16893-85-9, 17084-08-1, 221174-64-7, 39413-34-8, AI3-01501, Caswell No. 771, Destruxol applex, Disodium hexafluorosilicate, Disodium hexafluorosilicate (2-), Disodium hexafluorosilicate (8CI)(9CI), Disodium silicofluoride, EINECS 240-934-8, Ens-zem weevil bait, ENT 1,501, EPA Pesticide Chemical Code 075306, Fluorosilicate de sodium [ISO-French], Fluosilicate de sodium, HSDB 770, Natriumhexafluorosilicat, Natriumsilicofluorid [German], Ortho earwig bait, Ortho weevil bait, Prodan, PSC Co-Op weevil bait, Safsan, Salufer, Silicate(2-), hexafluoro-, disodium, Silicon sodium fluoride, Sodium fluorosilicate, Sodium fluorosilicate [UN2674] [Poison], Sodium fluosilicate, Sodium hexafluorosilicate, Sodium hexafluorosilicate [ISO], Sodium hexafluosilicate, Sodium silica fluoride, SODIUM SILICOFLUORIDE, Sodium silicon fluoride, Super prodan, UN2674

|

JANUARY 11 2005 BECHTEL JACOBS COMPANY LLC New Remediation Contractors at Paducah and Portsmouth

The Department of Energy today named the new remediation contractors at Paducah and Portsmouth. A link to the DOE news releases is provided below.

North Wind Paducah Cleanup Company LLC has been named the Paducah remediation contractor. North Wind is a women-owned small business based in Idaho Falls. Additional information about North Wind, Inc., is available at http://www.nwindenv.com.

The Portsmouth remediation contractor is LATA-Parallax Portsmouth LLC. LATA-Parallax is owned by Los Alamos Technical Associates, Inc. http://www.lata.com/home.html, a New Mexico-based engineering, environmental and nuclear operations services company, and Parallax Inc., http://www.parallaxabq.com/, a Maryland-based engineering, environmental and nuclear operations services company. LATA is a service-disabled veteran owned small business and Parallax is a women-owned, minority owned small business.

DOE has not yet announced an award date for the infrastructure contracts.

We now enter a new phase of our work as we begin the transition that will lead to the turnover of all remediation responsibilities. Your efforts to prepare for this transition has put us in good stead for the weeks ahead. Our work is not finished, and we must maintain our professionalism and our commitment to safety as we assist the new team.

In the coming weeks, we will work closely together to lay the foundation for the workforce transition process. We expect to share additional information through e-mails and employee meetings in the very near future. This period of change is also a period of opportunity, and we intend to do everything we can to assist our employees during this transition. Please ensure that you await direction from our BJC Manager of Transition and the HR Department prior to initiating specific meetings on transition.

I know that you will respond to the challenge ahead with the determination and dedication you have shown since Bechtel Jacobs took on this work in April 1998.

Les Hurst Paducah and Portsmouth Transition

http://www.ohio.doe.gov/pppo_seb/remediation/index.html

HOME | Bechtel Jacobs Company LLC Subcontractor / Supplier Information Center Breaking News Security Statement / Privacy Policy Procurement Web

Source: Water Treatment Fundamentals, Water Quality Association, 1996.

DRINKING WATER CONTAMINANTS AND THEIR CONTROL WITH REVERSE OSMOSIS WATER TREATMENT

Nominal Rejection Performance for Thin Film Composite Reverse Osmosis Membranes at 60 psi Net Pressure and 77° F.1

Inorganic Contaminant Sodium 90 – 95% Calcium 93 – 98% Magnesium 93 – 98% Potassium 90 – 95% Iron2 93 – 98% Manganese2 93 – 98% Aluminum 93 – 98% Copper 93 – 98% Nickel 93 – 98% Zinc 93 – 98% Strontium 93 – 98% Cadmium 93 – 98% Silver 93 – 98% Mercury 93 – 98% Barium 93 – 98% Chromium 93 – 98% Lead 93 – 98% Chloride 90 – 95% Bicarbonate 90 – 95% Nitrate3 85 – 90% Fluoride 90 – 95% Phosphate 93 – 98% Chromate 90 – 95% Cyanide 90 – 95% Sulfate 93 – 98% Boron 55 – 60% Arsenic+3 70 – 80% Arsenic+5 93 – 98% Selenium 93 – 98% Radioactivity 93 – 98% Biological & Particulate Contaminants4 Bacteria > 99% Protozoa > 99% Amoebic Cysts > 99% Giardia > 99% Asbestos > 99% Sediment / Turbidity > 99% Organic Contaminants Organic Molecules with a Molecular Weight > 300 > 99% Organic Molecules with a Molecular Weight <300 5 0 – 99%

1. This table of nominal rejection performance

is for the thin film composite type of membrane used in drinking water systems operating at a net pressure (feed pressure less back pressure and osmotic pressure) of 60 psi and 77° F water temperature.

The actual performance of systems incorporating these membranes may be less due to changes in feed pressure, temperature, water chemistry, contaminant level, net pressure on membrane, and individual membrane efficiency.

2. While iron and manganese are effectively

removed by the membrane, they also can easily foul its surface with deposits even at low concentrations. Generally, iron and manganese should be removed by other treatment methods prior to RO treatment.

3. Nitrate removal depends on factors such as

pH, temperature, net pressure across membrane, and other contaminants present.

4. While reverse osmosis membranes

theoretically remove virtually all known microorganisms, including virus, they cannot offer foolproof protection when incorporated into a consumer drinking water system. Potential seal leaks and manufacturing imperfections may allow some microorganisms to pass into the treated water.

5. The degree of rejection of organic molecules

less than molecular weight (MW) 300 depends on the size and shape of the molecule. Activated carbon is always incorporated along with reverse osmosis to insure complete removal of these lower molecular weight organic contaminants.

Ministry of Transport,

Public Works and Water Management

Institute for Inland Water Management and Waste Water Treatment/RIZA

Dutch notes on BAT for the phosphoric acid industry

Author(s):

J.H.W. van der Loo (Tebodin, Consultants & Engineers)M. Weeda (Institute for Inland Water Management and Waste Water Treatment, RIZA)

Contact:

M. WeedaRIZAP.O. Box 178200 AA LelystadThe Netherlands

Final document - 3 January 2000

Dutch notes on BAT for the phosphoric acid industry 2


Preface

This document comprises the contribution of the Netherlands to the exchange of information in the European Unionon the use of Best Available Techniques (BAT) to control the environmental impact of industrial processes. Thisdocument concerns the production of phosphoric acid.

On September 24 th 1996, the European Commission passed the Council Directive 96/61/EC concerning IntegratedPollution Prevention and Control (IPPC Directive), which obliges the Member States to achieve integrated preventionand control of pollution in the licensing of environmentally relevant industrial installations. The purpose of the IPPCDirective is ‘to achieve a high level of protection of the environment as a whole’ (Article 1), which should result in theapplication of the ‘best available techniques’ (BAT). Here, BAT are those techniques which are ‘most effective inachieving a high level of protection of the environment as a whole’ (Article 2).

One of the essentials of the Dutch environmental policy is the application of the best available techniques, as statedin the Dutch Environmental Protection Act. In the situation of an open market with international competition, and withregard to the transboudary character of environmental pollution, this policy can only achieve goals if international co-ordination is a part of it. Therefore harmonisation of the ideas on BAT is very important to the Netherlands.

Article 16.2 of the IPPC-Directive, stating that ‘the Commission shall organise an exchange of information betweenMember States and the industries concerned on best available techniques, associated monitoring, and developmentsin them’, has opened up a useful route towards this harmonisation. It is within this framework that the presentdocument is drawn up. It is meant to support and feed the process on information exchange.

The document provides information on the production of phosphoric acid and the measures and technologies used tocontrol and reduce the environmental impact associated with the production processes. In this document theemphasis is on the so-called wet phosphoric acid production and the phosphogypsum problem, especially on thecurrent and future situation of the wet phosphoric acid industry in the Netherlands.

The document does not cover the production of phosphoric acid in full detail. This document is more a highlightdocument rather than a balanced BAT-document which is valid for the entire industrial phosphoric acid sector in theEuropean Union. Nevertheless, we hope that this document will prove to be a useful source of knowledge in theprocess of drawing up a European BAT-reference document.


Table of contents

SUMMARY 7

1 GENERAL INFORMATION 9

1.1 PRODUCTION ROUTES AND FIELDS OF APPLICATION 91.2 EUROPEAN PHOSPHORIC ACID PRODUCTION 101.2.1 MERCHANT-GRADE ACID 101.2.2 TECHNICAL-GRADE ACID 101.3 PREVIOUS WORK ON BAT 111.4 INTERNATIONAL DEVELOPMENTS 111.4.1 OSLO PARIS CONVENTION (OSPAR) 111.4.2 INTERNATIONAL COMMISSION FOR THE PROTECTION OF THE RHINE (ICPR) 121.4.3 HELSINKI CONVENTION 121.4.4 BARCELONA CONVENTION 121.5 SCOPE OF THE DOCUMENT 121.5.1 STARTING POINTS DUTCH POLICY 131.5.2 PRESENT SITUATION AND OUTLOOK 14

2. DESCRIPTION OF PROCESSES 15

2.1 RAW MATERIALS 152.1.1 PHOSPHATE ROCK 152.1.2 SULPHURIC ACID 162.2 PROCESS PRINCIPLES 172.3 WET PHOSPHORIC ACID PRODUCTION PROCESSES 172.3.1 DIHYDRATE PROCESS 172.3.2 HEMIHYDRATE PROCESS 182.3.3 RECRYSTALLIZATION PROCESSES 182.4 PHOSPHORIC ACID PURIFICATION PROCESSES 20

3. CONSUMPTION LEVELS AND ENVIRONMENTAL ASPECTS 21

3.1 CONSUMPTION LEVELS 213.2 EMISSIONS AND WASTE 213.2.1 FLUORIDE EMISSIONS TO AIR 213.2.2 DUST EMISSION TO AIR 223.2.3 EMISSIONS OF LIQUID EFFLUENTS TO WATER 223.2.4 WASTE GYPSUM 233.2.5 RADIOACTIVITY 253.3 DIFFUSE EMISSIONS RESULTING FROM PRODUCT ACID USE 27

4. EMISSION ABATEMENT MEASURES AND TECHNIQUES 28

4.1 GENERAL PREVENTIVE MEASURES 284.1.1 APPLICATION OF HIGH-GRADE PHOSPHATE ROCK 284.1.2 APPLICATION OF AN HIGH EFFICIENCY PHOSPHORIC ACID PROCESS 284.2 SPECIFIC TECHNIQUES AND MEASURES TO MINIMIZE EMISSIONS AND WASTE 294.2.1 MEASURES TO PREVENT FLUORIDE EMISSIONS TO AIR 294.2.2 MEASURES TO PREVENT DUST EMISSIONS TO AIR 294.2.3 MEASURES TO PREVENT EMISSIONS TO WATER 294.3 USEFUL APPLICATION OF PHOSPHOGYPSUM 304.3.1 PHOSPHATE ROCK 314.3.2 PHOSPHORIC ACID PRODUCTION PROCESS 314.3.3 REPULP UNIT 314.3.4 REDUCTION OF CADMIUM LEVELS IN WASTE GYPSUM BY CHLORIDE DOSING 324.3.5 UPGRADING OF PHOSPHOGYPSUM 324.4 THE NITROPHOSPHATE ROUTE: AN ALTERNATIVE PHOSPHORIC ACID PRODUCTION PROCESS 32

5. EMERGING TECHNIQUES 34

5.1 PHOSPHATE REMOVAL FROM WASTE WATER EFFLUENTS 345.2 IN-PROCESS PHOSPHORIC ACID PURIFICATION 34

6. PHOSPHORIC ACID PRODUCTION: THE DUTCH SITUATION 35

6.1 PROCESS DESCRIPTION 35


6.1.1 KEMIRA AGRO PERNIS (KAP) 356.1.2 HYDRO AGRI ROTTERDAM 366.2 CONSUMPTION LEVELS 376.3 EMISSIONS AND WASTE 386.4 THE FUTURE DUTCH SITUATION: USEFUL APPLICATION OF WASTE GYPSUM 396.4.1 DESCRIPTION OF GYPSUM UPGRADING INSTALLATION 396.4.2 CONSUMPTION LEVELS 396.4.3 ENVIRONMENTAL PERFORMANCE 40

7. EVALUATION OF WASTE DISPOSAL METHODS BY MEANS OF SCREENING LCA 41

7.1 STARTING POINTS FOR THE SCREENING LCA 417.1.1 GYPSUM DISPOSAL SCENARIOS AND FUNCTIONAL UNIT 417.1.2 SYSTEM BOUNDARIES AND DATA USED 427.2 RESULTS OF THE SCREENING LCA AND EVALUATION 427.2.1 IMPACT ASSESSMENT 427.2.2 NON-NORMALIZED ENVIRONMENTAL PROFILE 427.2.3 NORMALIZED ENVIRONMENTAL PROFILES 44

8. CONCLUDING REMARKS AND RECOMMENDATIONS 45

REFERENCES 49

ANNEX 1: THERMAL PHOSPHORIC ACID PROCESS

ANNEX 2: TYPICAL ANALYTICAL FIGURES PHOSPHATE ROCK

ANNEX 3: USE OF GYPSUM AS RAW MATERIAL OR AS PRODUCT

ANNEX 4: PROCESS DESCRIPTION OF THE HDH-1 PROCESS OF KEMIRA AGRO PERNIS (KAP)AND THE HDH-2 PROCESS OF HYDRO AGRI ROTTERDAM (HAR)

ANNEX 5: EMISSION MONITORING STANDARDS USED IN THE NETHERLANDS


Summary

This document comprises the contribution of the Netherlands to the exchange of information in the European Unionon the use of Best Available Techniques (BAT) for the production of phosphoric acid.It provides information on the production of phosphoric acid and the measures and technologies used to control andreduce the environmental impact associated with the phosphoric acid production processes. However, the documentdoes not cover the production of phosphoric acid in full detail. The emphasis in this document is on the so-calledwet phosphoric acid production and the phosphogypsum problem, with specific attention for the current and futuresituation of the wet phosphoric acid industry in the Netherlands. This document is more a highlight document ratherthan a balanced BAT-document which is valid for the entire industrial phosphoric acid sector in the EuropeanUnion.

In chapter 1 the subject “phosphoric acid production” is introduced. The two principal routes for the production ofphosphoric acid are decribed, and an overview of the production facilities in the European Union is given. Based onthis information the scope of the document is narrowed down to phosphoric acid production according to the so-called wet-process route. The chapter contains a summary of discussions in several international fora with respect toBAT for the production of wet phosphoric acid, and ends with an explanation of the specific Dutch approach withrespect to the main environmental problem of the wet phosphoric acid industry, i.e. the production and disposal of by-product phosphogypsum. In chapter 2, a general survey is given of the raw materials that are used for wetphosphoric acid production and the type of processes that are applied. In chapter 3 typical consumption levels of rawmaterials and utilities are presented together with an inventory of the environmental aspects of wet phosphoric acidproduction. In chapter 4 measures and techniques are decribed that are applied to prevent and minimize theproduction and need for disposal of phosphogypsum, and to prevent and minimize emissions to air and water.Emerging techniques that may further improve the environmental performance of wet phosphoric acid processes arediscussed in chapter 5. Subsequently, the production of wet phosphoric acid in the Netherlands is considered inmore detail in chapter 6, with special attention for the developments regarding useful application of the by-productgypsum. Last but not least, in chapter 7 the results are presented of an integral assessment of the best availablesolution for the phosphogypsum problem from an environmental point of view. Concluding remarks are made inchapter 8.

Wet phosphoric acid is produced by digestion of phosphate rock with sulphuric acid. In this process phosphogypsum(calcium sulphate) is formed as by-product. The disposal of phosphogypsum is the main environmental problem ofwet phosphoric acid production. Basically, three different options exist for handling phosphogypsum by-product, i.e.discharge into water, dumping on land and useful application of the gypsum. From an environmental point of view, itis commonly accepted that, the discharge of phosphogypsum into water should be avoided by any means. Theresults of a cross-media assessment, based on the principal steps of the so called Life Cycle Assessment (LCA),indicates that, of the two remaining alternatives, the overall environmental performance of useful application is betterthan dumping on land.

Useful application of phosphogypsum is only possible if the quality meets required specifications. In general, thismeans that the quality of the phosphogypsum should be comparable to that of other gypsum resources. To enableuseful application, it is important to use a process with a high P2O5-efficiency. With increasing P2O5-efficiency boththe amount of phosphogypsum per unit of P2O5 produced and the level of residual phosphoric acid (a major impurity)in the gypsum decreases. Efficiencies of more than 98% are possible in recrystallization processes with two filtrationstages. In addition to a high P2O5-efficiency, recrystallization processes also produce phosphogypsum withconsiderably lower levels of impurities than single stage reaction processes, like the dihydrate and the hemihydrateprocess.

Together with the use of a process with a high P2O5-efficiency, the use of phosphate rock with a low ratio ofimpurities to the P2O5-content is essential for enabling useful application of the by-product gypsum. The impurities inphosphogypsum mainly originate from phosphate rock. The lower the ratio, the lower will be the level of impurities inthe gypsum, and the better will be the chances for useful application.

Additional upgrading of phosphogypsum may be required to be able to meet quality specifications. Upgrading ofgypsum can be achieved by separation of fines (e.g. by means of hydrocyclones), as it appears that many of theimpurities present in phosphogypsum are enriched in the smallest gypsum particles. Another interesting option is in-process removal of specific impurities. This is not yet possible, but developments for in process removal of impurities


by means of extraction and precipitation techniques are underway. As in-process removal of impurities may yield acleaner gypsum as well as a cleaner phosphoric acid this development deserves further attention. Other environmental problems at the wet phosphoric acid production are the emission of fluorine and dust (fromphosphate rock grinding) to air, and the emission of fluorine and phosphate to water. The emission of dust can beeffectively prevented by using fabric filters. Fluoride can be removed by a number of different gas scrubbing systemswith a removal efficiency of more than 99%. The gas scrubbing systems yield an effluent containing fluorine andphosphate components. Before discharge, the effluent can be neutralized with lime or limestone to precipitate fluorineas solid calcium fluoride and phosphate as calcium phosphate.


1 General information

1.1 Production routes and fields of application

Phosphoric acid, H3PO4, is a colourless, crystalline compound, that is readily soluble in water. The main product isphosphoric acid with a commercial concentration of 52-54% P2O5. After sulfuric acid, phosphoric acid is the mostimportant mineral acid in terms of volume and value. The greatest consumption of phosphoric acid is in themanufacture of phosphate salts as opposed to direct use as acid. Markets are differentiated according to the purity ofthe acid.

Phosphoric acid is produced commercially by either the wet process or the thermal process. The wet digestion ofphosphate rock with sulphuric acid is the most important process in terms of volume [1, 2]. Wet-process acid ischaracterized by relatively high production volume, low cost, and low purity. The share of wet phosphoric acidamounts to 95% of the total phosphoric acid in Western Europe. It is used primarily in the production of fertilizers(approximately 80%) and animal feed supplements (8%). Part of the wet-process acid is purified for the manufactureof technical- and food-grade phosphate salts, usually employing a solvent extraction process.

The thermal process for the production of phosphoric acid starts with the production of elemental phosphorus fromphosphate rock, coke, and silica in an electrical resistance furnace. The elemental phosphorus is subsequentlyoxidized to P4O10 after which the acid is generated by hydration of the oxide. Thermal acid is considerably purer thanwet-process acid, but more expensive, and is produced in much smaller quantities than wet-process acid. About 80-90% of the thermal phosphoric acid produced is used for the production of industrial phosphates, especially thesodium, potassium, calcium and ammonium salts. Thermal acid is used in metal surface treatment and, in food-gradequality, for the acidulation of beverages. Table 1 shows comparative analysis of typical wet-process acid, purifiedwet-acid and thermal acid [1].

Table 1: Typical analysis of phosphoric acids (wt.%).

Wet-process acid Thermal acid

Component Merchant-grade(Tennessee Valley Authority)

Technical-grade 1)

(Extraction Acid)

(Société Chimique Prayon-Rupel)

Technical-grade(Monsanto Co.)

P2O5

CaOFAl2O3

Fe2O3

MgOK2ONa2OSiO2

SO4

As

53.10.060.81.71.230.580.010.120.072.2

<0.005

57

0.02

0.004

0.04

54.30.001

<0.00010.00030.00040.00020.00070.00250.0015<0.002

<0.00005

1) Depending on the origin and the application of purified, technical grade, wet acid major variations in the composition this acid may occur. Impuritylevels (also heavy metals) similar to that of thermal acid can be achieved by purifying wet acid. However, the low fluoride and sulphate levels inthermal acid cannot be reached by purifying wet acid.


1.2 European phosphoric acid production

1.2.1 Merchant-grade acid

In the late eighties and the early nineties fertilizer consumption strongly declined in Western Europe, caused primarilyby agricultural policy changes in the European Union where efforts to reduce surplus farm production resulted in anumber of reforms in the Common Agricultural Policy. These changes in policy, and the fact that the economics ofpresent-day production dictates increasingly that plants should be built where there is cheap access to raw materials(either at the phosphate mine or at the source of sulphur or sulphuric acid), has had a large impact on the structureof the European wet phosphoric acid industry. Because of unfavourable economics a large number of relatively smallphosphoric acid production plants in Europe closed down, and as a result the structure has increasingly movedtowards a small number of large production plants. Between 1980 and 1992 the number of plants in Western Europereduced from 60 to approximately 20 while the average plant size increased from 80,000 t/a to 180,000 t/a. Atpresent 10 production sites are left which will have been reduced to 9 by the end of 1999 as Hydro Agri Rotterdamhas announced to close down its phosphoric acid plant in Vlaardingen, The Netherlands. An overview of theEuropean phosphoric acid production plants is given in table 2 [3].

Table 2: Overview of European phosphoric acid plants in 1994.

Plants Phosphoric acid capacity[kton P2O5]

Belgium Rhone-Poulenc ChemieSociete Chimique Prayon-Rupel SA

130140

Finland Kemira Chemicals Oy 235

France Grand Quevilly 200

Greece Chemical Industries of Northern Greece SAPhosphoric fertilisers industry Ltd.

11065

Netherlands Hydro Agri RotterdamKemira Agro Pernis

160225

Spain Fertiberia S.LFMC Foret, SA

420130

1.2.2 Technical-grade acid

Economics have also had a very large impact on the production route used to produce technical grade acid. InWestern Europe, the production of phosphoric acid using the solvent extraction purifying route has taken over fromthe thermal route. The impact of energy cost has caused the proportion of thermal acid to be largely reduced. Atpresent only Thermphos in Vlissingen, the Netherlands produces phosphoric acid via the thermal route. Theproduction capacity of this plant amounts to 155,000 t/a (the production in 1995 was 67000 ton P2O5). A shortdescription of this plant, including the environmental performance is presented in Annex 1. Because of its minorrelevance the thermal route will not further be considered in this document.


1.3 Previous work on BAT

Through the years a vast amount of literature and documents have been published about the production ofphosphoric acid. Although not all documents intend to be a BAT-document a number of them give a comprehensiveoverview of new and existing wet phosphoric acid technology and environmental measures. Recommandeddocuments are:

• Reduction environmental burdening phosphoric acid process, Best Available Technology, 1994 [4];• Descriptive analysis of the technical and economical aspects of measures to reduce water pollution cased by

discharges from the fertilizer industry and other industries entailing nutrient discharges,1991 [5];• Production of Phosphoric Acid, 1995 [6].

Besides these specific reports there are several books that treat the subject of phosphoric acid production inconsiderable detail. A few of these titles are given below. Items adressed in these books are raw materials,production processes, environmental aspects and impact of the phosphoric acid industry, and pollution control in thephosphoric acid industry:

• Use and disposal of wastes from phosphoric acid and titanium dioxide production, 1988 [7];• Phosphates and Phosphoric Acid: Raw Materials, Technology and Economics of the Wet Process, Second

Edition, Revised and Expanded, 1989 [8];• Pollution control in fertilizer production, 1994 [9];• Fertilizer Manual, 1998 [10].

1.4 International developments

The phosphoric acid industry has received considerable attention in several international fora, because of theenvironmental impact of phosfogypsum disposal. The following presents an overview of historic and recent BAT-developments in some important European fora.

1.4.1 Oslo Paris Convention (OSPAR)

The Paris Commission (Parcom), which was established to administer the Paris Convention for the prevention ofmarine pollution from land-based sources has made a proposal for a recommendation for the reduction of marinepollution originating from the phosphate fertilizer industry (Oslo 22-26 March 1993). The proposal stated thatphosphogypsum should preferably be reused or otherwise be deposited on landfill sites, in conditions which are notharmful to the environment (geologically-stable site, protection of ground and surface water, etc.) Furthermore,manufacturing plants should recycle and reuse process water to the greatest extent practicable and must comply withthe following emission factors insofar as concerns their liquid wastes (process water):

Phosphorus (P): 2 kg/ton P2O5

Fluorine (soluble): 2 kg/ton P2O5

Cadmium: 1 g/ton P2O5

The proposal has never become a definitive recommandation. Parcom, nowadays OSPAR (Commission for theprotection of the marine environment of the North-East Atlantic), noted that a study on BAT was in progress in theICPR (International Commission for the Protection of the river Rhine) framework. It was agreed to remove thisindustrial sector from the working programme of OSPAR to avoid duplication of this work of the ICPR.

Recently, the subject of BAT in the phosphate fertilizer industry has been put on the agenda of the OSPAR workinggroup on radioactive substances (RAD). The aim is to esthablish BAT with respect to the radioactive aspects of thefertilizer industry.


1.4.2 International Commission for the Protection of the Rhine (ICPR)

Discussions on BAT in the fertilizer industry, in particular the phosphoric acid industry, are still going on within theICPR. These discussions were triggered because of the difference of view of the member states on the discharge ofphosphogypsum. In 1997 a first expert consultation was held on the production of phosphoric acid in order to get abetter understanding on a technical level between the member states. The effort is to minimize the discharge ofphosphogypsum. In June 1999 a second expert consultation was held. At this occasion the state of affairs withrespect to useful application of by-product gypsum was discussed.

1.4.3 Helsinki Convention

The Helsinki Commission (Helcom) which was established to administer the Helsinki Convention for protection of theBaltic marine environment, has adopted a recommendation entitled ‘Reduction of pollution from discharges into water,emissions into the atmosphere and phosphogypsum out of the production of fertilizers’ on 12 March 1996(recommendation 17/6). The recommendation should be implemented by 1 January 1998 for new plants and by 1January 2002 for existing plants. The Contracting Parties have to report the Commission every three years startingfrom 2003. The recommendation should be reconsidered in 2004, especially regarding limit values for the differentproduct lines and products. The recommandation states that for the production of phosphoric acid the following loadvalues should not be exceeded as annual mean values:

Waste water discharges:Phosphate-P: 0.02 kg/ton P2O5

Fluoride: 0.05 kg/ton P2O5

Cadmium: 0.1 g/ton P2O5

Mercury: 0.01 g/ton P2O5

Zinc: 1 g/ton P2O5

Emissions into the atmosphere:NOx: 500 mg/m3 related to NO2

dust: 50 mg/m3

Fluorine compounds: 5 mg/m3

Chlorine compounds: 30 mg/m3

Waste (phosphogypsum):Phosphogypsum from the sulphuric acid dissolution should be re-used to the extent possible. If this is not practicableit has to be disposed of in a disposal facility appropriately equipped. A discharge into waters does not comply withBAT.

1.4.4 Barcelona Convention

The Barcelona Convention is the convention for the protection of the Mediterranean sea. No information is receivedfrom the Co-ordinating Unit for the Mediterranean Action Plan.

1.5 Scope of the document

In this document information is given on the production of phosphoric acid and the measures and technologies usedto control and reduce the environmental impact associated with the production processes. The document does notcover the production of phosphoric acid in full detail. The emphasis is on the so-called wet phosphoric acidproduction, especially on the current and future situation of the wet phosphoric acid industry in the Netherlands. Thisdocument, therefore, is more a highlight document rather than a balanced BAT-document which is valid for the entireindustrial phosphoric acid sector in the European Union.


1.5.1 Starting points Dutch policy

In the Netherlands the discharge of so-called phosphogypsum from the wet phosphoric acid industry into the Rhineestuary has been a subject of discussion for years. Besides relatively harmless gypsum, phosphogypsum containsmany substances which, owing to their harmful properties, pose great risks to the environment and to human health.These substances include amongst others:• phosphorus;• fluorine• heavy metals such as cadmium, mercury and lead;• radionuclides, in particular radium-226, lead-210 and polonium-210.

The Dutch environmental policy regarding these pollutants is based on the precautionary principle and is aimed atreducing pollution using the best available techniques. In the case of black-listed, or list I substances, such ascadmium and mercury, the Dutch policy even requires efforts to reduce discharges to zero. This policy is clear. Thediscussion referred to above, therefore, did not concern the neccesity to minimize the discharge of pollutants fromthe wet phosphoric acid industry. The discussion concerned the best way to realize minimization of the discharge.

Main starting-point of the Dutch government has been to realize a sustainable solution. The following aspects ofDutch environmental policy and additional aspects have determined the Dutch approach with respect to the wetphosphoric acid industry:• Reducing pollution and industrial waste are basic principles in Dutch environmental policy. Priority is given to

eliminating pollution and waste at the source. This should be achieved preferably by measures that avoid theformation of pollution and waste rather than by measures that eliminate the problems once they are formed;

• If the production of waste is unavoidable priority is given to reuse or recycle of the material in the process fromwhich it originates, or useful application of the material elsewhere. Dumping of waste is seen only as the lastalternative if all other alternatives fail to solve the problem;

• Shifting of pollution between the various environmental media should be avoided. In case of the wet phosphoricacid industry this means that reducing the pollution from by-product gypsum should not lead to an increasedenvironmental burdening by end products based on the intermediate phosphoric acid;

• Because of a limited load bearing strength of the underground and high ground water tables (large area required;stringent precautionary measures to prevent serious soil and groundwater contamination), and a high populationdensity (lack of space, considerable transport distance) storage of gypsum in (a) depot(s) appeared not to be aviable option, neither permanent nor temporary.

Based on the abovementioned considerations, the Dutch government, in co-operation with the industry (convenantbetween the Dutch government and the industry in 1988), developed the following approach to deal with theenvironmental problems of the phosphoric acid industry:• Use of clean high grade phosphate ores (production of gypsum and phosphoric acid with relatively low levels of

impurities);• Implementation of high efficiency wet phosphoric acid processes (high P-efficiency means less gypsum per unit

of P2O5 produced, and a lower P-concentration in the gypsum);• Development of useful applications for the by-product gypsum;• Acid purification: The production of clean pure gypsum should not lead to an increased environmental burdening

by end products based on phosphoric acid. Additional acid purification may be required.


1.5.2 Present situation and outlook

Up till now the by-product gypsum from the wet phosphoric industry in the Netherlands is being discharged intowater. In the past decade, however, the discharge of all pollutants is reduced considerably. Compared to 1985 theemission of cadmium is even reduced by more than 95%. Moreover, further reductions can be expected in the nearfuture as due to the quality improvement of the gypsum it is now possible to use the gypsum as a feedstock, forexample in the cement industry and for the production of plaster, plaster board and gypsum building blocks.


2. Description of processes

In this section the raw materials (phosphate rock and sulphuric acid) and the phosphoric acid processes will bediscussed in general. The specific Dutch situation, i.e. the situation of the production sites of Kemira Agro Pernis andHydro Agri Rotterdam, will be highlighted in more detail in section 6.

2.1 Raw materials

2.1.1 Phosphate rock

There are two main types of phosphate rock deposits, sedimentary and igneous, which have widely differingmineralogical, textural and chemical characteristics (table 3). The phosphate minerals in both types of ore are of theapatite group, of which the most commonly encountered variants are “fluorapatite” [Ca10(PO4)6(F,OH)2] and“francolite” [Ca10(PO4)6-x(CO3)x (F,OH)2+x]. Fluorapatite predominates in igneous rocks and francolite in sedimentaryphosphate rocks. Phosphate ores can vary widely according to their origin. Each rock has its own color, viscosity andimpurities. The impurities are mainly responsible for the individual behaviour of the ore [11]. Specifications for anumber of phosphate rocks are listed in Annex 2.

Tabel 3: Rough composition of main components and trace elements in sedimentary and igneous rocks.

Sedimentary ores Igneous ores

Main constituents (%wt) (% wt)

Phosphate (P2O5) 30 - 37 35 - 40

Calcium (CaO) 46 - 52 48 - 54

Fluorine (F) 3 - 4 1 - 4

Trace elements (ppm) (ppm)

Arsenic (As) 10 - 20 1 - 10

Cadmium (Cd) 5 - 50 0 - 2

Mercury (Hg) < 0,2 < 0,1

Heavy Metals (Pb, Zn, Cu, Ni, Cr) 200 - 800 50 - 150

Rare earth elements (REE) 100 - 900 1400 - 6300

Radioactivity (Bq/kg, Ra-226) 700 - 1400 10 - 110

Generally, the sedimentary deposits are associated with matter derived from living creatures. The apatite is inadmixture with gangue materials such as clay and sand. But even if the gangue materials could be completelyseperated the mineral itself is usually far from pure apatite [12]. It may incorporate silicate, aluminate, sulphate andchloride in place of the phosphate while calcium may be replaced by other metals such as aluminium, iron,magnesium, strontium, barium, sodium, potassium, cadmium, and rare earth elements. Due to its origin sedimentaryores may contain organic material. This material can cause foaming problems during acid production. Compared toigneous phosphates, sedimentary phosphates contain more carbonates and fluorides, and often more aluminium andiron. Also they contain higher levels of heavy metals such as mercury, cadmium, arsenic, lead, zinc, copper, nickeland chromium, and radionucleids such as uranium, radium and polonium. Sedimentary phosphate rock is found in alarge number of countries, amongst others Morocco, Tunesia, United States, Jordan, Israel, Syria, Togo andSenegal.

Igneous phosphates are normally formed by the extrusion of magmatic material through solid rocks; the hot lavasolubilizes elements contained in the rock as it flows to the surface. Igneous phosphates are usually extremelyheterogeneous. The most common impurities are limestone and dolomite. However, the magmatic solution of otherelements is quite often considerable and the mine can have other mineral whealth besides that of phosphate.


Compared to sedimentary rocks, igneous rocks usually contain relatively high levels of rare earth metals such aslanthanide and cerium. Igneous phosphate rock is predominantly found in Russia (Kola), Finland, South Africa andBrazil.

About 85% of the global phosphate reserves is of sedimentary origin. Some 80% of the world phosphate production isderived from sedimentary phosphate deposits. The phosphate content in currently mined rocks can range from over40% to below 5%. The mined rock is further processed to remove the bulk of the gangue material and thus upgradethe rock. Consequently, the rock concentrate contains an increased apatite content of an improved quality. Thebeneficiation process usually allows a concentration of around 1.5x but higher ratios up to 9x are possible with somerocks. After beneficiation, phosphate rock concentrate generally ranges from 26% to about 34% P2O5 and up to asmuch as 42% [13]. Consequently phosphate rock usage ranges from approximately 2.5 to 3.5 ton per ton of P2O5.

2.1.2 Sulphuric acid

Sulphuric acid is used for the digestion of phosphate rock to form the product acid and calcium sulphate as by-product. Sulphuric rock usage is about 3 ton per ton P2O5. There are various types of sulphuric acid: • acid produced from elemental sulphur (sulphur-sulphuric acid);• acid produced from pyrite (pyrite-acid);• fatal acid: by-product acid from non-ferrous metal smelters processing sulfide ores;• spent acid: acid produced from elemental sulphur, pyrite acid or fatal acid which, after being used, is released as

moderately concentrated acid in large quantities from many processes; this acid is either used directly, or afterconcentration and purification;

• regenerated acid: reprocessed spent acid.

The types of sulphuric acid mainly used as raw material in the production of phosphoric acid are acid produced fromelemental sulphur, fatal acid and spent acid. The amounts of impurities introduced into the process by sulphuric acidare generally low or negligible compared to the amount introduced by the phosphate rock. Only in the case ofmercury and possibly lead, sulphuric acid may contribute significantly, especially when fatal acid is the main type ofsulphuric acid used [14]. Typical mercury contents of fatal acid and acid based on elemental sulphur are presented intable4. The table shows that the lowest levels of mercury are introduced, when sulphuric acid produced fromelemental sulphur is used. The mercury content of spent acid depends on the type of acid originally used. Themercury content of other sulphuric acids, in general, lies within the extremes presented in table 4.

Table 4: Typical mercury contents of sulphuric acid

Type of acid Mercury content [ppm]

sulphur-sulphuric acid < 0,01

fatal acid 0,1 – 1


2.2 Process principles

Phosphoric acid is produced from the reaction of phosphate rock with sulphuric acid. In the rock the phosphate ispresent in an insoluble form. When the rock is treated with strong sulphuric acid, the rock-lattice is destroyed and thecomponents pass into solution. In the wet phosphoric acid process phosphate rock may first need grinding to obtainfine rock particles. The rock is then dissolved in phosphoric acid and sulphuric acid. Besides dissolving the rock,sulphuric acid is added to precipitate the calcium present as calcium sulphate (reaction). During the reaction coolingis required as the overall reaction is exothermic. After conversion of the rock the calcium sulphate and phosphoricacid are separated by filtration. To produce merchant-grade phosphoric acid (52-54%), additional concentration ofthe product acid is usually required. The overall reaction can be represented by the following reaction equation:

Ca10(PO4)6F2CaCO3 + 11 H2SO4 →→ 6 H3PO4 + 11 CaSO4 + 2 HF + CO2 + H2O

Calcium sulphate exists in a number of different crystal forms depending particularly on the prevailing conditions oftemperature, P2O5 concentration in the reaction slurry and free sulphate level. The process operating conditions aregenerally selected so that the calcium sulphate will be precipitated in either the dihydrate (CaSO4.2H2O) orhemihydrate (CaSO4.½H2O) form; 26-32% P2O5 at 70-80°C for dihydrate precipitation and 40-52% at 90-110°C forhemihydrate precipitation.

For the production of wet phosphoric acid five principal process routes are available [2, 6, 8, 15, 16, 17, 18]. Inprinciple, each process type can process all types of phosphate rock. However, each phosphate rock is different andhas its own processing characteristics. A change of rock or rock type may therefore require significant processadjustments.

2.3 Wet phosphoric acid production processes

In the following paragraphs the five principal process routes are roughly outlined, and their main differences arediscussed. In table 5 the processes are summarised with respect to some important environmental aspects, i.e.P2O5-efficiency, some important energy aspects and the quality of the gypsum produced.

2.3.1 Dihydrate process

Most phosphoric acid plants in the world operate the dihydrate (DH) process. In this process most phosphate rocksneed particle size reduction, generally through the application of ball or rod mills. The phosphate rock is converted byreaction with concentrated sulphuric acid. The process produces phosphoric acid of 26-32% P2O5 at 70-80°C. Thereaction temperature is controlled by passing the reaction slurry through a flash cooler or by using an air circulatingcooler. After reaction the slurry is filtered. The most common filtration equipment is of three basic types: tilting pan,rotary table or travelling belt. In practice filtration is always vacuum assisted. Otherwise no reasonable rate ofseparation would be achieved. The initial separation must be followed by thorough washing of the filter cake to ensurea satisfactory recovery of soluble P2O5. Due to the low strength of the product acid significant concentration isneeded to produce a merchant-grade acid.

DH condi t ions w ater

T=80°C

phosphate rock reaction

w ater and filter DH-gypsum

sulphuric acid crystallisation

w eak acid phosphoric acid

26-32%

Figuur 1: Diagram of the dihydrate process


2.3.2 Hemihydrate process

In the hemihydrate (HH) process coarser rock can be used than in the DH process. So grinding may not benecessary. Apart from that, the process stages of the hemihydrate process are similar to those of the DH process.The process is operated at temperatures of 90-110°C and a phosphoric acid strength is 40-52% P2O5. The higheracid strength reduces the need for acid concentration and consequent energy requirements for this stage. Due to alower required excess in the reaction stage, in the HH process the sulphuric acid consumption per tonne of rock islower than in the DH process. However, the consumption per ton of P2O5 may not be different due to a lower P2O5-yield of the HH process.

HH condi t ions w ater

T=100°C

phosphate rock reaction

w ater and filter HH-gypsum

crystallisation

sulphuric acid


40-52%

Figuur 2: Diagram of the hemihydrate process

A clear disadvantage of the HH process is the low P2O5-efficiency; typically 90-94% compared to 94-96% for the DHprocess. This is caused mainly by less favourable filtration conditions; under HH conditions the calcium sulphatecrystals tend to be smaller and the viscosity of the acid is higher than under DH conditions. In addition, water balanceconsiderations restrict the amount of wash water that can be used. Due to processing at a high acid strength only alimited amount of filter cake wash water can be reused in the reaction stage.

The quality of the calcium sulphate produced by the hemihydrate process is lower than that produced by the DHprocess, not only because of a higher P2O5-content, but also because of a higher level of impurities such as fluorineand heavy metals. In general, the uptake of impurities in the calcium sulphate HH crystal lattice is higher than theuptake in the DH form. On the other hand, as less sulphuric acid is used (less free sulphate) and more impurities endup in the calcium sulphate, the acid produced by the HH process is generally purer than the acid produced by the DHprocess.

2.3.3 Recrystallization processes

In the DH- and HH proces 4-10% of the P2O5 is retained in the filter cake. If the calcium sulphate is made torecrystallise into its other hydrate, some of this loss will again pass into solution and can be recovered when therecrystallised calcium sulphate is finally separated. Besides P2O5, also part of the impurities will again pass intosolution. Recrystallization, therefore, not only raises the overall process efficiency, but also yields cleaner calciumsulphate.

2.3.3.1 Hemihydrate recrystallization process (single stage filtration)

In a hemihydrate recrystallization process (HRC-process), or hemi-dihydrate single stage filtration process (HDH-1process), the first reactor operates under HH conditions. The succeeding reactors operate under conditions favouringthe rehydration of HH to DH (gypsum). After rehydration, or recrystallization, the gypsum and product acid areseparated by filtration and the filter cake is washed. The product acid from the HRC process is no more concentratedthan that from the DH process, but the gypsum is considerably purer.


HH condi t ions DH condi t ions w ater

T=100°C T=80°C

phosphate rock reaction re-

w ater and crystallisation filter DH-gypsum

sulphuric acid crystallisation


30-32%

Figuur 3: Diagram of the hemihydrate ReCrystallization process (a HDH-1 process)

2.3.3.2 Hemi-dihydrate process (double stage filtration)

In a HDH-2 process it is possible to produce a concentrated acid directly (40-52% P2O5). In this process reactiontakes place under HH conditions. The HH and product acid are separated by filtration before recrystallization to DH.After recrystallization the DH is filtered and washed. The acidic filtrate from the second stage is reused as washingfluid in the first stage.

HH condi t ions DH condi t ions w ater

T=100°C T=80°C


sulphuric acid and filter crystallisation filter DH-gypsum

crystallisation

w eak acid

phosphoric acid

40-52%

Figuur 4: Diagram of a Hemi-diydrate process (HDH-2)

2.3.3.3 Di-hemihydrate process (double stage filtration)

The DHH process produces a relatively pure gypsum and a moderate strength phoshoric acid (32-35% P2O5). In thisprocess initial reaction takes place under DH conditions, after which DH and product acid are separated in the firstfiltration stage. Subsequently, the DH is recrystallised to HH. This conversion requires the input of heat (by steam).Finally, the HH is filtered and washed in a second filtration step.

DH condi t ions HH condi t ions w ater

T=80°C T=100°C


sulphuric acid and filter crystallisation filter HH-gypsum

crystallisation

w eak acid

phosphoric acid

32-38%

Figuur 5: Diagram of a Di-hemihydrate process (DHH)


Table 5: Some operating characteristics of phosphoric acid processes.

Process type Efficiency Energy aspects Gypsum quality

DH 94-96% P2O5 acid strength 26-32% P2O5, requiresevaporation 1)

may require rock grinding

Impure DH(0,75% P2O5)

HH 90-94% P2O5 acid strength 40-52% P2O5,

may use coarse rock

Impure HH(1,1% P2O5)

HDH - 1 stage 97% P2O5

lower H2SO4 consumption

acid strength 30-32% P2O5,

fine rock grind required

Relatively pure DH

HDH - 2 stage 98.5% P2O5

low H2SO4 consumption


may use coarse rock

Relatively pure DH(0,19% P2O5)

DHH 98% P2O5

lower H2SO4 consumption


requires rock grinding

requires steam for gypsum conversion, DHto HH

Relatively pure HH

1) The main product is phosphoric acid with a commercial concentration of 52-54% P2O5.

2.4 Phosphoric acid purification processes

Wet process phosphoric acid is purified by numerous methods and to a wide variety of standards depending on thefurther application of the acid [2, 8, 9, 10, 19]. The most basic method, and the one which all suppliers of merchant-grade acid carry out before shipment, is clarification, by settling or other mechanical means, to remove suspendedsolids. In case the acid is used for the production of fertilizers usually no further treatment is applied.

Chemical purification methods can be employed if the acid is to be used for specific purposes, not requiring a highquality. Active carbon treatment is the usual means of removing organic impurities. Fluorine is removed by addingreactive silica and distilling off silicon tetrafluoride. Phosphate rock or lime may be added to the impure acid toremove excess sulphate. Metals ions can be selectively precipitated by various chemicals. By adding a Na2S solutionto the acid arsenic can be precipitated as arsenic sulphate. Removal of other cationic impurities, especially Fe, Al, Mgand Ca can be achieved by neutralizing the acid with sodium hydroxide or caustic soda. However, since thephosphoric acid in this proces is converted to a phosphate salt solution, its uses are limited.

More elaborate techniques involving (organic) solvent treatment are used to obtain purer acid such as that requiredfor animal feed supplements (mainly cadmium removal) and especially the food industry. Liquid/liquid extractionprocesses are most commenly used. Processes are operated for the separation of single components (e.g. uraniumand cadmium) as well as of practically all impurities in wet phosphoric acid. The quality of such purified acid equalsthat of thermally produced acid. Besides liquid/liquid extraction processes also precipitation processes are beingemployed. An example of such a process is the separation of cadmium by means of a complexing agent (analkyldithiophosphoric acid alkyl ester) as operated by Tessenderloo Chemie in Belgium.

All extraction and precipitation processes are supplementary processes and therefore only affect the acid quality.Purification techniques integrated in the wet phosphoric acid process would give the possibility also to improve thegypsum quality. Thus far, no such processes exist, but developments are in progress (see section 5.1).


3. Consumption levels and environmental aspects

In this section reference levels of input requirements (raw materials and utilities), emissions to air and water, wastegypsum production and radio-nuclides releases are presented.

3.1 Consumption levels

Inputs for the phosphoric acid production consist of the raw materials phosphate rock and sulphuric acid, as well asutility requirements, such as process water and cooling water, electric power and steam. Typical input requirementsfor the production of phosphoric acid are presented in table 6 [6]. The specific consumptions depend mainly on thecomposition of the rock used and the process used (need for rock grinding; required reaction temperature and acidconcentration; process efficiency; need for acid concentration, heating as well as cooling).

Table 6: Typical input requirements for the product of merchant-grade wet phosphoric acid.

Inputs Consumption [per ton P2O5]

Phosphate rock 2,6 - 3,5 ton

Sulphuric acid 2 - 4 ton

Process water 1) 4 - 7 m3

Cooling water 2) 100 - 150 m3

Electric power 120 - 180 kWh

Steam 2) 0.5 - 2.2 ton

1) not including scrubber water 2) per ton of P2O5 produced as concentrated acid

3.2 Emissions and waste

The main environmental aspects of wet process phosphoric acid production are:• the emission of gaseous fluorides to the atmosphere• the emission of dust (secondary aspect)• the discharge of effluent from off-gas treatment containing phoshorus and fluorine• the disposal of the waste gypsum• radioactivity

3.2.1 Fluoride emissions to air

Origin

Fluoride is present in most phosphate rocks to the extent of 2 - 4%; 20 - 40 kg/ton rock or about 60 - 120 kg/tonP2O5. During the process fluorine is distributed between the product acid, the gypsum and the vapours generated inthe reactor and the acid concentration section. Initially, fluoride is released in the reaction as hydrogen fluoride (HF),but in the presence of silica this reacts readily to form fluosilicic acid (H2SiF6), and compounds such as MgSiF6 andH3AlF6. The fluosilicic acid may decompose under the influence of heat to give volatile silicon tetrafluoride andhydrogen fluoride. The reactions involved are: 4 HF + SiO2 →→ SiF4 + 2 H2O 3 SiF4 + 2 H2O →→ 2 H2SiF6 + SiO2

H2SiF6 →→ SiF4 + 2 HF

In a dihydrate process the temperature is usually to low to cause the decomposition of fluosilicic acid. The majority ofthe fluorine compounds will be evolved with the evaporator vapours during concentration of the weak phosphoric acid.In the hemihydrate process most of the fluoride is released during the reaction. Fluoride will leave the reactor with thevacuum cooler condenser water or with the cooling air, depending on the cooling system applied (flash cooler or air


circulating cooler). A typical fluoride distribution in the dihydrate and the hemihydrate processes is shown in table 7[6].

Table 7: Typical fluorine distribution in dihydrate and hemihydrate processes

Dihydrate process (%) Hemihydrate process (%)

Acid 15 12

Gypsum 43 50

Reactor off-gas 5 8

Flash cooler vapour 3 30

Concentrator vapour 35 -

Impact

Fluorine is emitted to the atmosphere either as silicon tetrafluoride or hydrogen fluoride. Due to their accumulation inplants, fluorine containing vapours may cause harm to the surroundings. A fluorine concentration of 0,02 mg/m3 inthe air may already be harmful for the vegetation, e.g. fruit trees [5].

3.2.2 Dust emission to air

Origin

The emission of dust originates from the unloading, handling and grinding of phosphate rock. Phosphate rock isgenerally supplied by ship. It is unloaded by cranes and further transported to storage and grinding section byconveyor belts or trucks. Impact

Size of the dust particles is generally divided into two principal groups: coarse particles larger than 2.5 µm and fineparticles smaller than 2.5 µm. Especially inhalation of small particles, which have air dispersion characteristics similarto gaseous compounds, may cause lung function problems. Inhalation of dust may also result in enhanced exposureto radiation since phosphate rock generally contains enhanced levels of radioactive substances like 226Ra, 210Pb and210Po. In addition dust may be a troublesome nuisance for the surrounding area of the plant location as it contributesto objects getting dusty through deposition, which may also lead to pollution of soil and water, either directly or viawashing away of deposited dust with rain.

3.2.3 Emissions of liquid effluents to water

Origin

Liquid emissions mainly consist of effluents originating from vacuum cooler condensors and gas scrubbing systemswhich are used for cleaning and condensation of the vapours that evolve in the various stages of the process. Thesevapours, and consequently the effluents, contain mainly fluoride and a small amount of phosphoric acid. Theeffluents, therefore, are acidic. Impact

The most serious effect of an acidulous discharge is the change in pH. This can affect most species of fish, aquaticlife and vegetation. Soluble fluorine may have toxic effects on aquatic life and humans (fluorosis). The phosphate maycontribute to the overfertilisation (eutrophication) of water systems which results in enhanced algae growth.


3.2.4 Waste gypsum

Gypsum is an unavoidable by-product in wet phosphoric acid production; for every ton of phosphoric acid (P2O5)around 4-5 ton of gypsum is produced. Phosphate rock contains a range of impurities (see table 3). In the processthe impurities are distributed between the product acid and the calcium sulphate. Table 8 shows a typical distributionof the impurities for a hemihydrate recrystallization process [20, 21]. In HDH-2 and DHH processes the amount ofimpurities that end up in the gypsum is slightly less, while in DH and HH processes the amount of impurities that endup in the gypsum is usually larger. In general, mercury, lead and the rare earth metals end up mainly in the gypsum.This also holds for the radioactive components radium-226 (226Ra), lead-210 (210Pb) and polonium-210 (210Po).Arsenic and the other heavy metals like cadmium, zinc, nickel and chromium end up mainly in the acid. Also uranium-238 (238U) almost completely ends up in the acid. Apart from these general characteristics, the exact distribution ofthe impurities is determined by type of process and the phosphate rock used. The possibilities to influence thedistribution are limited.

Table 8: Typical distribution of impurities between waste gypsum and product acid for a hemihydraterecrystallization process.

type of impurity % impurity in gypsum % impurity in acid

Cadmium 0 - 5 95 - 100

Mercury 100 0

Arsenic 0 - 5 95 - 100

Lead 100 0

Copper 30 - 60 2) 40 - 70

Zinc 0 - 5 95 - 100

Nickel 0 - 10 90 - 100

Chromium 0 - 5 95 - 100

rare earth elements 1) 90 - 100 0 - 10

uranium-238 0 100

radium-226, lead-210, polonium-210 100 0

1) The elements scandium, yttrium, lanthaan, cerium, praseodymium, neodymium, samarium, europium, gadolinium, terbium,dysprosium, holmium, erbium, thulium, ytterbium, lutetium; underlined are the elements that are the most abundant.

2) The distribution of copper, zinc, nickel and chromium usually lies in the same range. However, deviations may occur as a resultof the phosphate rock used.

Because of the size of the gypsum production and the type and level of impurities in the gypsum, this by-productconstitutes a serious environmental problem. Basically, three options exist to deal with the problem: • discharge into water;• storage on land;• useful application. Discharging into water and storage on land are the common methods of gypsum disposal. Local conditions determineusually the type of disposal. Important factors are the scale of the operation, geographical and geological factors, thelocal population density and the local perception of risk, and local usage of ground water [22]. Up till now only verylimited use is made of phosphogypsum as a resource because of quality restrictions, usually related to the relativelyhigh level of radioactive substances and residual phosphorus in the gypsum. At this moment, 20 - 25% of thephosphogypsum of the Prayon-Rupel plant in Engis (Belgium) is used for the production of plaster (Knauf). Inaddition, small amounts of the gypsum of the Kemira plant in Siilinjarvi (Finland) is used for various applications.Table 9 gives an overview of the European phosphoric acid plants and the method of gypsum disposal employed [5,7, 23].


Table 9: Overview of gypsum disposal methods in Western-Europe phosphoric acid plants

Plants Phosphate rock used Type of

process

Method of gypsum

disposal

Comments

NetherlandsHydro Agri Rotterdam

Kemira Pernis

Jordan (sedimentary)

Kovdor (igneous)/Jordan (sed.)

HDH-2 HDH-1

Discharge into sea Discharge into sea

Agreement with authorities to re-use gypsum withminimum 90%, or to reduce the gypsum contaminants,based on heavy metals and radio-nuclides, with 70-90%, within 10 years. For the re-use of gypsum a pilotrecovery plant is in use. Market study of commercialuse of gypsum (as building materials) indicatespositive results

SpainFertiberia S.L FMC Foret, SA

Mainly Moroccan rock,also Togo and Senegalrock (all sed.)

? ?

Stockpiled on land(discharge of run-offinto sea)

Local authorities have issued instructions, constraintsand deadlines to meet environmental regulations

BelgiumRhone-Poulenc Chemie

Societe Chimique Prayon-Rupel SA

Phalaborwa (ign.)

Phalaborwa (ign.)/Bucraa (Morocco sed.)and/or Kola(ign.)/Jordan (sed.)

?

DHH

Stockpiled on land

Stockpiled on land andpartial reuse

Reuse without further ipgrading of gypsum isinvestigated. Results were negative because ofcontamination of gypsum. Sells 20-25% of its gypsum for use in building products

FinlandKemira Chemicals Oy

Siilinjarvi (igneous)

HH

Stockpiled on land

Partial use of gypsum for the production of wood-chip-gypsum wall plates and paper coating applications(1991)

FranceGrand Quevilly

Moroccan rock (sed)

?

Stockpiled on land

Closed cycle pond system

GreeceChemical Industries ofNorthern Greece SA

Phosphoric fertilisersindustry Ltd.

? ?

? ?

Stockpiled on land Stockpiled on land

Removal of gypsum by truck. There is no doublefiltration process. The still acidic gypsum is brought tosuitable land, which is filled and covered withagricultural earth.

3.2.4.1 Impact of phosphogypsum discharge into water

Besides relatively harmless gypsum, phosphogypsum contains many substances which, owing to their harmfulproperties (acidity, eutrophication, toxicity, persistency, accumulation), pose great risks to the aquatic environment.The main substances and effects are: • residual acidity (Phosphoric acid): most species of fish, aquatic life and vegetation are sensitive to changes in

pH;.• phosphate: contributes to eutrophication resulting in enhanced algae growth.• fluoride: soluble fluoride compounds contribute to acidity, while fluoride itself has harmful effects (flourosis), (The

discharge of fluoride is mainly harmful in surface water. At the pH-value of sea water fluoride will precipitate ascalcium fluoride);

• heavy metals (Cd, As, Hg, Pb, Cu, Zn, Ni, Cr): toxic, persistent and are known to accumulate in organisms;• rare earth elements: toxic, persistent, and there are indications for accumulation in aquatic organisms (The

solubility of REE compounds in water is very low. In the Netherlands this has led to considerable debate on thesubject of the bio-availability of rare earth metals. In general the riks associated to REE are considered low.);

• radionuclides: radiological exposure (radio-toxicity).


3.2.4.2 Impact of phosphogypsum storage on land

For the design of land based phosphogypsum disposal sites, local geology, permeability of surface layers and theflow of the local ground water are important aspects. Two methods for landfill disposal are being used [5, 6, 24]:1. The gypsum is mixed with water from the acid process and pumped as a slurry to settling ponds. The acidic

overflow water, which also contains considerable levels of contaminants (fluoride, heavy metals), may berecycled to the plant, resulting in a reduction in the loss of phosphorus and a reduction in water consumption.The alternative is to discharge this water into a river or the sea.

2. The gypsum is transported in dry form from the plant to the disposal site (amongst others at Kemira in Finland).The advantage of this method is that the phosphoric acid plant water balance is independent of the gypsumtransport requirements, and does not lead to discharge of contaminated process water into a river or the sea.

To avoid soil pollution, and the pollution of ground water and surface water by acidic and contaminatedphosphogypsum leachate and run-off (process water and rain water), serious preventive measures are necessary,such as seepage collection ditches, intercept wells, natural barriers, lining systems and immobilisation of solubleP2O5 and trace elements by neutralisation [6, 24, 25]. Besides control during the built-up of a gypsum stack, the run-off from gypsum stacks will require treatment for many years after the acid plant has ceased production [26, 27]. Waste gypsum piles are a source of radon emission to the environment [26, 28]. Humans (and animal live) living inthe vicinity of a phosphogypsum stack may be exposed to enhanced levels of radiation. The gypsum containsenhanced levels of 226Ra. The major concern of materials which contain 226Ra is the production of radon-222 (222Rn),an inert noble gas that does not form any chemical bonds and can escape into the atmosphere. Radon with arelatively short half-life of 3,8 days, decays further into short lived radioactive solid products. These ionic productsattach rapidly to aerosols and dust particles in the air, and can thus be inhaled and deposited in the lungs, therebyincreasing the risk of lung cancer. A problem related to the emission of radon is the possible dust emission of agypsum stack as a result of erosion. The dust itself, containing radium, can be inhaled, but can also emit radon.

3.2.4.3 Useful application of phoshogypsum

In principle, phosphogypsum can be used for the same purposes as natural gypsum or gypsum originating from fluegas desulphurisation (FGD). However, apart from economic considerations, useful application of phosphogypsum isonly possible if its quality meets required specifications. In general, this will come down to the production ofphosphogypsum with a quality comparable to that of other gypsum resources. This can be done by adjusting theprocess so that high quality gypsum is produced directly, or by upgrading of gypsum that does not meet thespecifications (Further details on useful application of phosphogypsum are given in sections 4.3, 6.4 and Annex 3). Incase all phosphogypsum can be applied usefully there will be no gypsum disposal problems as above. If only a partcan be used, the remaining will still have to be discharged into water or dumped on land.

3.2.5 Radioactivity

Origin

All natural materials contain naturally occurring radioactive nuclides (radionuclides). The source of theseradionuclides are uranium-238 (238U), uranium-235 (235U) and thorium-232 (232Th) which have very long half-lives.238U, 235U and 232Th (the so-called mother radionuclides) decay via a chain of daughter radionuclides (which may haverelatively long half-lives) to stable nuclides. 238U is the most abundant one of the three mother radionuclides. Itamounts up to approximately 10 times the amounts of 232Th and 235U.


Consequently, the radioactivity of phosphate rock is mainly caused by radionuclides from the radioactive decay series238U. In the undisturbed crust of the earth a radioactive decay series is (expected to be) in equilibrium. This meansthat the activities of all members of the series are equal to that of the long-lived parent, i.e. 238U. 238U decays viaseven different chemical elements and ends with a stable lead isotope (206Pb). The radionuclides emit α- or β-radiation as they decay to other radionuclides. The radionuclides radium-226 (226Ra), radon-222 (222Rn), lead-210(210Pb) and polonium-210 (210Po) are part of the 238U decay series. The radionuclides content in phosphate rock strongly depends on the origin of the rock. Sedimentary rock containsmore 238U and its daughter radionuclides than igneous rock. During the phosphoric acid production process theradionuclides will be divided mainly between the product acid and the by-product gypsum, although other emissionsources may also contain limited amounts of radionuclides. For the by-product gypsum the radionuclides 226Ra, 210Pband 210Po are important. 238U, on the other hand, will almost completely end up in the product acid. 222Rn, as a decayproduct from 226Ra, is generated as a gas which is emitted to the air. The diagram below indicates the flows that maycause exposure of humans to radionuclides from a phosphoric acid plant.

dust emission (U-238) dust emission (U-238)

Ra-226

phosphate rock phosphate rock phosphoric acid phosphoric acid

(U-238) storage plant (U-238)

Ra-226 other w aste (Ra-226): scale (maintenance), piping

gypsum (226-Ra)

Figuur 6: Diagram showing the flows from a phosphoric acid plant that may cause exposure of humans toradionuclides

Impact

The presence of 238U and its daughters 226Ra, 222Rn, 210Pb and 210Po causes radiological exposure of humans. Theexposure of humans can be divided into exposure of workers and exposure of the public. Radiological exposure ofworkers can occur by phosphate rock storage, handling and grinding of phosphate rock and storage of the endproducts (the fertilizers), and to a much lower extent by transhipment of phosphate rock. Radiological exposure of thepublic can occur by exposure to the discharge of the by-product gypsum and to a lower extent by direct exposure tothe stored phosphate rock and emissions of dust originating from phosphate rock transhipment, storage and grinding. However, for waste gypsum discharge more potential pathways of radiological exposure may be considered. Whenphosphogypsum is discharged into water, 226Ra is partially dissolved in the water phase and partially bound tosuspended material. When 226Ra ends up in sediment, it remains a source of other nuclides lower down the uraniumseries. A potential pathway for exposure of humans is the use of contaminated mud originating from dredging theharbour for construction purposes (it is common practice in the Netherlands to use this material for terrain elevation).In this case, increased levels of 222Rn gas (226Ra decay product) in indoor air may occur. Another potential pathway for exposure is by 210Pb and 210Po (226Ra decay products). These radionuclides pose aradiological problem as they are strongly accumulated by several aquatic organisms (e.g. fish) which may beconsumed by humans.


When phosphogypsum is stored on land, there are four potential pathways for exposure of humans to radionuclides:• Direct exposure from the gypsum stack;• Exposure caused by accumulation of radionuclides by aquatic organisms from gypsum stack rainwater run-off;• Exposure by emissions of dust caused by wind;• Exposure by 222Rn gas inhalation emitted from the gypsum stack.

3.3 Diffuse emissions resulting from product acid use

In wet phosphoric acid processes the bulk of the heavy metals, among which cadmium, do not end up in the wasteby-product, but in the phosphoric acid itself. Eventually, these impurities end up diffusively in the environmentthrough the use of end products, mainly fertilizers, based on the intermediate phosphoric acid (see also table 8) [29,30]. This may lead to soil pollution and ground water pollution in area’s where fertilizer repeatedly and intensivelyused. Through uptake by crops, these impurities may be introduced into the foodchain and may be harmful tohumans. With regard to these aspects cadmium has received considerable attention [5, 31, 32]. It has led authoritiesin several countries to propose or implement Cd limits for P fertilizers. These limits are shown in table 10 [30].

Tabel 10: Proposed or implemented Cd limits for P fertilizers in several countries.

Country Cd limit mg/kg P Effective year Country Cd limit mg/kgP

Effective year

Australia

AustriaBelgiumDenmark

Finland

45035030012020015011050

in effect19952000

in effectvoluntary

19881995

in effect

GermanyJapanNorway

Sweden 1)

SwitzerlandThe Netherlands

200340100501005035

voluntaryin effectin effect

1995in effectin effect

1) In addition, Sweden has imposed an tax on fertilizers with Cd concentrations between 5 and 100 mg Cd/kg P.


4. Emission abatement measures and techniques

In this section measures and techniques are considered to prevent or reduce emissions to air and water, and tominimize waste. First, general preventive measures are discussed (before pollution arises). These measures concernthe choice of phosphate rock and the type of process to be used. These measures affect all environmental impacts ofphosphoric acid production. Next, a number of specific techniques and measures (end-of-pipe) are discussed whichare applied to deal with specific environmental aspects of phosphoric acid production such as fluorine and dustemissions to air. Useful application of phosphogypsum and the use of the nitrophosphoric acid process as anpossible alternative to the wet phosphoric acid process are discussed separately.

4.1 General preventive measures

4.1.1 Application of high-grade phosphate rock

From the phosphoric acid producer’s point of view, the best possible phosphate rock would consist entirely oftricalcium phosphate, Ca3(PO4)2. The impurities in phosphate rock are mostly undesirable for an assortment ofreasons - economic, technical and environmental. The most basic objection to anionic impurities is that, by taking the place of phosphate, they increase the CaO/P2O5

ratio of the phosphate rock. An increase in this ratio means an increase in the amount of acidulating agent requiredper ton of P2O5 processed, and thus impairs the economics of the process. Per ton of P2O5 it also means an increasein the mass of calcium sulphate produced requiring disposal. For producers in some areas, like in the Netherlands,calcium sulphate disposal is the most serious problem that they have to face. Apart from these problems, most of theindividual impurities cause problems arising out of their chemical properties. They can give rise to environmental andtoxic hazards as discussed in the previous chapter. Furthermore, they can interfere in the phosphoric acid reactionsystem (scaling, corrossion) or influence the filtration (crystal size and shape, slurry viscosity), affecting theefficiency of the phosphoric acid production process. Also, they may impair the quality of the product(s), particularlyfor use in downstream processes [11, 12]. If dealing with the gypsum disposal problem requires finding usefulapplication for the gypsum, this latter aspect does not only hold for the acid product but also for the gypsum by-product; clean, pure gypsum offers more and better opportunities for useful application than highly contaminatedgypsum. So, for an assortment of reasons it is preferable to use phosphate rocks with a high P2O5 content and a lowimpurity content.

4.1.2 Application of an high efficiency phosphoric acid process

The P2O5 recovery efficiency of a phosphoric acid plant is an important environmental parameter. With increasingefficiency, the consumption of a particular phosphate rock per ton of P2O5 produced will decrease, thus reducing theamount of impurities that will enter and will have to leave the process. An increase in efficiency means that per ton ofP2O5 less sulphuric acid is required and less gypsum is produced. Furthermore, a cleaner gypsum will be produced,especially with respect to P-content, thus enhancing the possibility to find a useful application for the gypsum. With respect to P2O5 recovery efficiency, the data shown in table 5 in section 2.3 clearly show that therecrystallization processes (HDH-1, HDH-2 and DHH) are to be preferred over the more straightforward dihydrateand hemihydrate processes. P2O5 which leaves the process with the gypsum consists both of small undissolved phosphate rock particles andphosphoric acid still adhering to the gypsum after filtration. With respect to the latter type of loss a furtheroptimisation can be obtained by an end-of-pipe repulp filter [6, 22]. By re-slurrying and washing the gypsum, followedby an extra filtration step, most of the free acid which is not removed in a previous filtration step, can be removed inthis filter, resulting in a higher P2O5 efficiency and a higher grade gypsum.


4.2 Specific techniques and measures to minimize emissions and waste

4.2.1 Measures to prevent fluoride emissions to air

Fluoride in the form of HF and SiF4, which evolves during the digestion of phosphate rock and during theconcentration of phosphoric acid to 54% P2O5, can be removed by a number of different scrubbing systems. Thefluorine scrubber is normally an unpacked spray tower made of rubber-lined steel, which is operated at atmosphericpressure. Other types such as packed bed, cross-flow venturi and cyclonic column scrubbers are also extensivelyused [6, 18, 33,]. Many companies recover the fluorine as fluosilicic acid (H2SiF6) which can be used for the production of aluminiumfluoride, and other fluorine compounds such as sodium and/or potassium fluosilicates. In this case a dilute solution offluosilicic acid is used as the scrubbing liquid. The reaction to fluosilicic acid results in the formation of free silica. Bycarefully controlling the strength of the fluosilicic acid the deposition of silsica is controlled. The silica is removed byfiltration. Usually, a product containing 20-25% fluosilicic acid is recovered in the fluoride recovery system. With twoor more absorbers a recovery efficiency of 99% or more can be achieved. According to EFMA [6] achievable fluorideemission levels for new plants are 5 mg/Nm3 (40 g/ton P2O5). In The Netherlands, emission levels in the order of 1-5mg/Nm3 are achieved in the existing plants [34, 35]. To minimize fluosilicic acid contamination with P2O5, or just to minimize contamination of the scrubber effluent,vapours from vacuum flash coolers and vacuum evaporators are usually first led through a separator for the removalof phosphoric acid droplets that are entrained with the vapours. If the fluorine is not recovered the scrubber effluentwill be discharged. Before discharge the effluent can be neutralized with lime or limestone to precipitate fluorine assolid calcium fluoride. As an alternative sea water can be used as scrubbing liquid. Also in sea water fluoride reactsto the harmless substance CaF2.

4.2.2 Measures to prevent dust emissions to air

The spread of phosphate rock dust from unloading of ships and transportation is commonly prevented by usingcovered conveyor belts and indoor storage [6]. Further dispersion of phosphate rock dust (by wind or rain) can beprevented by good housekeeping measures such as frequently cleaning/sweeping the plant grounds and the quay. Dust originating from phosphate rock grinding can be recovered by passing the dust containing air through fabricfilters. In general, dust emission levels of 10 mg/Nm3 can be achieved by fabric filters. However, rock particles arerather sticky and therefore easily stick to the filter cloth. This has a negative effect on the recovery efficiency of afabric filter. According to EFMA [6], the achievable dust emission level of fabric filters in new phosphoric acid plantsis: 50 mg/Nm3. By use of fabric filters, in The Netherlands, dust emission levels of less than 30 mg/Nm3 are achievedin the existing plants [34, 35].

4.2.3 Measures to prevent emissions to water

Emissions to water are mainly formed by the effluents from the fluorine scrubbers and the direct contact condensors.In phosphoric acid plants, in the systems operating under vacuum, direct contact condensors are normally used tocondense the vapours from the the flash cooler or the evaporator, so as to maintain a vacuum (vacuum pumps areused to remove the non-condensable gases). The vapours are led through the condensor either directly or aftertreatment in a fluorine scrubber.


4.2.3.1 Fluorine emissions

As described above many companies recover the fluorine as fluosilicic acid (H2SiF6). If the fluorine is not recovered,or cannot be recoverd for technical reasons (excessive silica formation resulting in plugging of the scrubber), thescrubber effluent will be discharged. Before discharge the effluent can be neutralized with lime or limestone toprecipitate fluorine as solid calcium fluoride. As an alternative sea water can be used as scrubbing liquid. Also in seawater fluoride reacts to the harmless substance CaF2. To prevent fluoride emissions with condensor water, the application of an indirect condensation system may beconsidered, instead of a direct contact condenser, thus avoiding that condensor water becomes contaminated withfluoride [6].

4.2.3.2 Phosphate emissions

To minimize contamination of the scrubber effluent with P2O5, vapours from vacuum flash coolers and vacuumevaporators are usually first led through a separator for the removal of phosphoric acid droplets that are entrainedwith the vapours [6, 33]. Despite the use of a separator, gas scrubber and condensor effluents may contain low levels of phosphoric acid.Phosphate removal can be achieved by magnesium ammonium phosphate (struvite) or by calcium phosphateprecipitation [36, 37]. Although several phosphorus recovery plants have been implemented, phosphate removal hasnot been practiced yet in phosphoric acid plants. These techniques are, therefore, outlined in section 5: Emergingtechniques.

4.3 Useful application of phosphogypsum

Depending on local conditions there are two basic disposal options for phosphogypsum; disposal to sea or disposalon land. The gypsum contains a wide range of impurities, some of which are considered a potential hazard to theenvironment and public health (see section 3.2.4). Because of this, there is a large pressure to end the practice ofgypsum diposal in the sea. In Europe, where most phosphoric acid plants discharged waste gypsum to the sea,much of the industry chose the option of closing down, because the alternative option of land disposal was in mostcases impracticable, mainly as a result of agricultural policy changes and bad economies of scale (see section 1.2.1). Locally, the disposal on land, however, also holds potential hazards for the environment and public health. Many ofthe important considerations in the design and construction of gypsum disposal areas are therefore based on thenecessity to keep both the gypsum and the acidic stack effluent within a closed system [24, 25]. To avoid pollution ofthe subsoil and ground water pollution by acidic and contaminated phosphogypsum leachate and run-off (processwater and rain water), severe preventive measures are necessary, such as seepage collection ditches, interceptwells, natural barriers and lining systems. Furthermore, to prevent or minimize pollution of the surrounding area andwatersystems, it is necessary to make provisions for effluent overflow. The effluent requires appropriate treatment,such as immobilisation of soluble P2O5 and trace elements by neutralisation, before it can be released from thesystem. Besides control during the built-up of a gypsum stack, the run-off from gypsum stacks will require treatmentfor many years after the acid plant has ceased production [26, 27].

A third and interesting way of dealing with the phosphogypsum disposal problem is to improve the quality of thegypsum, so that it can be used as a resource like natural gypsum and flue gas desulphurization gypsum. Manyexamples of phosphogypsum usage exist [7, 23, 27, 38, 39, 40]. Table 11 gives an overview of phosphogypsumapplications. It should be noted that different commercial applications require different types of gypsum. A shortdescription of the possible applications is outlined in Annex 3. In Europa, at this moment, only phosphogypsumproduced by Prayon Rupel (Belgium) is used on a commercial scale (20-25% of the total production). The gypsum isused as plaster. In Finland (Kemira), some phosphogypsum is applied in the paper industry (see table 9). In theNetherlands, the application of phosphogypsum (Kemira) in a variety of gypsum building products (plaster, buildingblocks, plasterboard) has been demonstrated on a pilot scale, with positive results. In the past, not all efforts to use the gypsum have been succesful, mainly because of quality considerations. In mostcases the radioactivity aspects of the gypsum formed a problem. Also the residual acidity or P2O5 content of the


gypsum is an important factor. Application of phosphogypsum requires the production of a clean pure gypsum.Measures that contribute to achieve this goal are outlined below.

Table 11: Overview of phophogypsum applications

Application Anhydrite, AH (CaSO4) Dihydrate, DH (CaSO4.2H2O) Hemihydrate, HH (CaSO4.½H2O)

Construction floor screedcement (as setting regulator)

Cement (as setting regulator) plaster (stucco)plasterboardceiling tilesgypsum blocksfloor screed

Agriculture soil conditioneras a source of calcium and sulphercarrier and filler in insecticidesas filler in the production of fertilizer

soil conditionercarrier and filler in insecticidesas filler in the production of fertilizer

as a source of calcium and sulphur

Industrialuses/Other

filler / pigment in variety of applications filler / pigment in variety of applicationsproduction of ammonium sulphate andsulphuric acid

filler / pigment in variety of applications

4.3.1 Phosphate rock

The production of clean gypsum requires the use of phosphate rock with low levels of impurities. Regarding size andeconomy, construction materials, in particular in-door building products, are an important area of application for theby-product gypsum. To enable this, it is important that the gypsum contains only low levels of radioactivecomponents, especially radium. The possibilities for useful application of phosphogypsum therefore will largely beenhanced if phosphate rock with low levels of radionuclides are used.

4.3.2 Phosphoric acid production process

In the DH- and HH proces 4-10% of the P2O5 is retained in the filter cake. If the calcium sulphate is made torecrystallise into its other hydrate, some of this loss will again pass into solution and can be recovered when therecrystallised calcium sulphate is finally separated. Besides P2O5, also part of the impurities will again pass intosolution. Recrystallization, therefore, not only raises the overall process efficiency, but also yields cleaner calciumsulphate.

In recrystallization processes with two-stage filtration phosphoric acid is separated from the gypsum beforerecrystallization. Thus a substantial part of the impurities is removed from the system before recrystallization takesplace. This is not the case in recrystallization processes with single-stage filtration. Because of this the levels ofimpurities in gypsum from two-stage filtration processes are generally lower than in gypsum from single-stagefiltration processes.

4.3.3 Repulp unit

With respect to P2O5 removal from the gypsum, a further optimisation of single-stage filtration processes can beobtained by extending the process with an extra filtration step, or repulp filter unit [6, 24]. In this unit the gypsum isre-slurried, washed and filtered thus removing most of the free acid which is not removed in the previous filtrationstep.


4.3.4 Reduction of cadmium levels in waste gypsum by chloride dosing

If the cadmium content of phosphogypsum is a problem, the addition of chloride in the acidulation stage may beconsidered [4, 16]. Chloride forms complexes with cadmium which are not incorporated in the gypsum crystals, butstay in the acid. Consequently the phosphogypsum produced contains less cadmium. The addition of chloride mayput a strain onthe choice of construction materials because of an increase of corrosion.

4.3.5 Upgrading of phosphogypsum

It appears that many of the impurities present in phosphogypsum are enriched in the smallest gypsum particles [41,42]. Among these impurities are mercury, the common heavy metals, the radionuclides and the lanthanides. Byseparating a particle size fraction with the smallest particles the quality of the remaining gypsum can, therefore, beimproved substantially. Separation can be achieved by passing the gypsum through a hydrocyclone, as has beendemonstrated on a pilot scale by Kemira and Hydro Agri in The Netherlands. In this case only 4% of the total amountof gypsum was separated as fines. Production on a commercial scale should be no problem as this does only requiremore hydrocyclones and not a larger one.

Additional advantages of separation of the smallest particles from the gypsum slurry can be an improvement of thewashing and filtering characteristics of the gypsum. Pilot plant test of Kemira and Hydro Agri in the Netherlandsshowed that upon washing and filtration of the remaining slurry after particle size separation by means of ahydrocyclone, still a substantial amount of P2O5 was removed from the gypsum despite the fact that Kemira employsa repulp filter in its regular process. Although not yet anticipated, it should be possible to return these P2O5-values tothe process thus increasing the P2O5 efficiency. After vacuum filtration a gypsum cake remains with a moisturecontent of less than 10%. Such a value is required by the gypsum industry for further processing of the gypsum toproducts.

The fines that are separated in the hydrocyclone are released as a dilute slurry (0.5-1 wt%). Because of the relativelyhigh impurity content of the fines it will not be easy to find a useful application for this fraction [43]. What remains arethe two basic options for disposal discussed above, namely discharge to sea or storage on land. In the latter case thefines will first have to be recovered from the slurry, for instance by means of filtration.

4.4 The nitrophosphate route: an alternative phosphoric acid production process

The sulphuric route has become established as the industry standard for the production of phosphoric acid,principally for economic reasons and because it provides a high flexibility in the range of (fertilizer) products that canbe made of the acid. The main alternative to the sulphuric route is the nitrophosphate route, in which nitric acid ratherthan sulphuric acid is used for the digestion of phosphate rock [44, 45, 46]. Around 10-15% of the world phosphatefertilizer production use the nitrophosphate route. The main advantage of the nitrophosphate route is that no gypsumis produced, thus avoiding waste gypsum disposal problems. A diagram with the principal process steps of a nitro-phosphoric acid process is shown in figure 7.

w ater and nitric acid

T=60-70°C T=0-20°C

phosphate rock filtration cooling/ Ca(NO3)2.5H2O

60% nitric acid reaction Ca(NO3)2- fi ltration slurry(insolubles) crystallization

nitro-phos. acid

return acid to NPK fertilizer

insoluble matter production

Figuur 7: Diagram of a Nitro-phosphoric acid process

Use of nitric acid gives calcium nitrate tetrahydrate as a by-product. This can be upgraded to calcium nitratefertilizers or converted to ammonium nitrate and calcium carbonate. When using nitric acid it is, however, noteconomically possible to remove the calcium, nitrate and certain dissolved impurities to the standard required for


making phosphoric acid as a commercial product. After removal of the calcium, therefore, nitro-phosphoric acid isalways turned into fertilizers on the spot. A disadvantage of the nitro-route is that the acid will always contain calcium and nitrate ions resulting in limitations inwater-soluble P2O5 (recombination with phosphate to water-insoluble dicalciumphosphate during fertilizermanufacture), and the N/P2O5 ratio of the products that can be made of the acid. Under reaction conditions calciumnitrate is soluble. To remove calcium nitrate, generally, the reaction liquor is cooled so that calcium nitrate partiallycrystallizes. About 60% of the calcium nitrate comes out of solution at 20 ºC. At -5 ºC this is about 85-90%. Furthermore, the nitro-phosphoric acid is more dilute so that more energy is required to remove the water. A specificenvironmental disadvantage is the release of NOx from the digestion unit. With respect to environmental impact it isfurther noticed that in the nitro-route all phosphate rock impurities end up in the acid, and will finally end up in theenvironment diffusively through the use of end product fertilizers.


5. Emerging techniques

5.1 Phosphate removal from waste water effluents

Waste water from phosphoric acid plant may contain considerable concentrations of phosphates, in particular theeffluents from gas scrubbers. Phosphates in solution can be precipitated by the addition of flocculating agents, suchas iron and aluminium salts. However, this method will generally preclude recycling of the phosphate as the resultingiron or aluminium compounds are not compatible with the technologies currently used in the phosphate industry. Abetter prospect for recycle of phosphates from waste water lies in processes that precipitate crystalline products ofreasonable purity, that could be used as a substitute raw material in standard phosphate fertilizer productiontechnology or directly as fertilizer material. Several processes of this nature have been developed [36, 37]. Mainproducts are usually either (insoluble) hydroxy-apatite or soluble magnesium ammonium phosphate (struvite). In mostof these processes phosphate recovery takes place in fluidised, agitated or fixed bed crystallization columns. Usually,sand or phosphate rock particles are used as seed material. Hydroxy, calcium and magnesium ions are usually addedto the process to facilitate precipitation. Several pilot and full scale processes already operate in different countries, recovering phosphates from waste waterstreams through calcium phosphate formation:• DHV Crystalactor process at the waste water plants of Westerbork (12,000 pe demonstration plant), Heemstede

(35,000 pe) and Geestmerambacht (230,000 pe) in the Netherlands;• pilot plant developed by DHV and Essex and Suffolk Water at Chelmsford sewage works, UK;• pilot plant developed by Karlsruhe University at Darmstad Süd sewage works in Germany;• demonstration plant (50,000 pe) developed by Sydney Water Board at Warriewood, Australia;• three plants constructed by Kurita, Japan• a fixed bed precipitation installation (160 m3/hr) is operational at the Mercedes motor car factory at Gagenau,

Germany. Full scale processes which recover phosphate as struvite are already operational or being built in Japan and in theNetherlands:• the DHV Crystalactor fluid bed process is used in a full scale struvite recovery installation at the AVEBE potato

processing plant in the Netherlands (150 m3/hr);• the Unitika Ltd (Osaka) struvite precipitation process (Phosnix process) is already in application at the Ube

Industries Sakai plant (industrial waste waters) and at the Shimane Prefecture sewage works in Japan; No examples are available for phosphate recovery from waste waters of phosphoric acid plants. Kemira Agro Pernis(Netherlands) has investigated the fluidised bed process of DHV (Crystalactor process) for phosphate removal fromthe effluents of the gas scrubber systems. In the process phosphate and also fluoride would precipitate andcrystallize on seed material (phosphate rock) under the controlled addition of lime (CaO). The process would producea slurry which can be recycled to the phosphoric acid process (solids roughly consist of 45% calciumphosphate, 45%calciumfluoride and 10% phosphate rock). The treated effluent could be recycled to the gas scrubber system, thuscreating a closed loop system. Unfortunately, the installation appeared not to be economically feasible at the time(1991).

5.2 In-process phosphoric acid purification

At the Technical University of Delft (the Netherlands) a process is being developed for removal of heavy metal ionsfrom process streams under conditions typically encountered in wet phosphoric acid processes, especially duringconversion of gypsum from hemihydrate to dihydrate in recrystallization processes. In-process removal of impuritieswill yield a cleaner phosphoric acid as well as a cleaner gypsum thus enhancing the chances for useful application ofgypsum, also when phosphate rocks with relatively high levels of impurities are used. The process is based on theliquid membrane or liquid-liquid extraction technique. An experimental transverse flow hollow fiber module has beendesigned and built. Lab-scale tests have shown positive recovery results for lead, mercury, copper, cadmium andcerium from actual plant acid (1% gypsum, 70 ºC) [40, 47]. Further research is aimed at optimization and scale-up ofthe test module, the finding of better extraction liquids and the specific removal of radium (other techniques, e.g.specific precipitation with of radium with barium salts), as this appears to be the most limitative element for usefulapplication of phosphogypsum.


6. Phosphoric acid production: the Dutch situation

In previous sections, general background information is presented concerning wet phosphoric acid production. In thissection the specific Dutch situation is described in brief, including the plans for a plant to upgrade waste-gypsum to apurity that is acceptable for the gypsum to be used as a raw material, for example for the production of buildingproducts. Since the mid-eighties the objectives of the policy pursued by the Dutch authorities with respect to the wetphosphoric acid production are: • substantial reduction of the amount of contaminants discharged with the phosphogypsum to the sea;• substantial reduction of the cadmium content of phosphoric acid following concern of build-up of cadmium in soils

as a result of phosphoric acid based fertilizer use (The target for fertilizers in the year 2000 was set at 15 mgCd/kg P2O5. The actual cadmium content at that time amounted to more than 60 mg Cd/kg P2O5.);

• useful application of at least 90% of the phosphogypsum produced. Since then many adjustments have been carried through with respect to use of raw materials, the phosphoric acidprocess and process management (good housekeeping, etc.), which have resulted in major reductions of emissions.In addition a specific research program has been executed with the aim to realize useful application of the gypsum.Pilot plant tests have demonstrated the technical feasibility of the production of a gypsum product that meets allspecifications required for application of the gypsum in (in-door) building products like plaster, plasterboard andgypsum building blocks. The gypsum can be produced for a price which is comparable to the price for naturalgypsum.

6.1 Process description

6.1.1 Kemira Agro Pernis (KAP)

Kemira Agro Pernis produces phosphoric acid at the Pernis location, situated in the Rotterdam harbour. Theproduction capacity of the plant is 225 kton per year. Kemira employs a hemi-dihydrate recrystallization process withsingle stage filtration. The main process consists of two reaction systems and a single filtration system. The processis extended with an extra gypsum washing and filtration step (repulp filter unit) for further removal of P2O5 which stilladheres to the gypsum after filtration and washing. A diagram of the process is presented below [48]. In the first reaction system phosphate rock, diluted sulphuric acid (75%) and return acid (20% phosphoric acidcoming from the filtration section) are mixed, and react at a temperature of 90°C to form hemihydraat gypsum andphosphoric acid. In the second reaction system the reaction slurry is cooled to 60°C by blowing air through themixture. During cooling the hemihydrate recrystallizes to dihydrate. After recrystallization the dihydrate andphosphoric acid are separated by means of filtration. The phosphoric acid (28%) subsequently is passed through adesulphatation section (lowering sulphate/sulphuric acid concentration of the acid), a settling tank (settling of smallgypsum particles), and finally an evaporation section where the acid is concentrated in four steps to 54% P2O5. Afterfiltration, the dihydrate gypsum cake is treated in a repulp filter unit before being reslurried and discharged into theNieuwe Waterweg, a Rhine estuary close to the sea. A somewhat more detailed description of the process is given inAnnex 4.


phosphate rock

grind mil l dust filter dust to air

water water fluorine to air

sulphuric acid

reactors scrubber f luor ine and phosphate to water

flash cooler

return acid water fluorine to air

recrystallisator scrubber f luor ine and phosphate to water

water

filter repulp fi l ter gypsum to water

desulfatation

phosp. acid

storage fluorine and

water water phosphate to

water

steam evaporator separator scrubber condenser

seal vac.pump

phosphoric acid product fluosilisic acid by-product

Figuur 8: Diagram of the HRC-repulping process of Kemira Agro Pernis

6.1.2 Hydro Agri Rotterdam

The phosphoric acid plant of Hydro Agri Rotterdam is located in Vlaardingen, opposite to that of Kemira at the otherside of the river. The production capacity of the plant is 160 kton per year. Hydro Agri employs a a hemi-dihydraterecrystallization process with double stage filtration. The main process consists of two reaction systems and twofiltration systems. A diagram of the process is presented below [35, 49]. In the first reaction system phosphate rock reacts with concentrated sulphuric acid (96%) and return acid (weakphosphoric acid coming from the filtration section) to form hemihydraat gypsum and phosphoric acid. The phosphoricacid is separated from the hemihydrate gypsum by means of filtration. Subsequently, in the second reaction systemsulphuric acid and a SiO2-containing slurry are added to stimulate the recrystallization of hemihydrate to dihydrate.The recrystallization liquid and the dihydrate are separated by means of filtration. The liquid phase is reused as washwater in the hemihydrate filtration step and finally ends-up as return acid in the first reaction system. After washingthe dihydrate is reslurried and discharged into the Nieuwe Waterweg. The process produces a 42% phosphoric acid.The acid is concentrated to 54% P2O5 by means of vacuum evaporators. During evaporation a SiO2 containingsolution is added to stimulate de-fluorisation of the phosphoric acid. A somewhat more detailed description of theprocess is given in Annex 4.


phosphate rock

water

water flash cooler fluorine to air

sulphuric acid

reactors scrubber scrubber effluent

(f luorine and phosphate)

return acid

water

scrubber effluent

filter scrubber (f luorine and phosphate)

recrystallisator vapour water

filter gypsum to water

phosp. acid

storage

water water

steam evaporator scrubber condenser

scrubber effluent


Figuur 9: Diagram of the Hemi-dihydrate process (HDH-2) of Hydro Agri Rotterdam

6.2 Consumption levels

In table 12 typical consumption figures, i.e. raw materials and utility requirements, are shown for the production ofconcentrated phosphoric acid by Kemira Agro Pernis and Hydro Agri Rotterdam [20, 34, 48, 49, 50].

Tabel 12: Typical consumption figures for the production of merchant grade phosphoric acid by Kemira Agro Pernisand Hydro Agri Rotterdam

Inputs Kemira (per ton P2O5) Hydro Agri (per ton P2O5)

Phosphate rock 2.8 ton 3.1 ton

Sulphuric acid 2.6 ton 2.6 ton

Process water 1) 51 m3 52 m3

Cooling water 2) 101 m3 40 - 50 m3

Electric power 173 kWh 167 kWh

Steam 2.2 ton 1.0 ton

1) including scrubber water 2) cooler and condensor water


6.3 Emissions and waste

Table 13 presents data which give an impression of the emission reductions (absolute emissions) that have beenachieved in the last decade by carrying through adjustments with respect to the phosphoric acid process and thetype of phosphate rock used, and by improving the management of the process. Furthermore table 13 contains datawith respect to the actual (1996/1997) specific emissions (per ton P2O5 produced) [20, 34, 49, 49]. Most of the datapresented is based on measured values. The emission values have been estabished according to standardizedmeasurement procedures. The procedures used are listed in Annex 5.

Tabel 13: Reduction of emissions (total emissions per year) achieved since 1985 and actual emissions factorsrealized during production of phosphoric acid by Kemira and Hydro Agri in 1996/1997

Emission reduction since 1985 specific emissions 1996/1997

Kemira Hydro Agri Kemira Hydro Agri

% % per ton P2O5 per ton P2O5

emissions to air

fluorine (F) 70 6.1 1) 2.8 g

dust 75 12 2) 19 g

liquid emissions to water

phosphate (P) 1.3 0.7 kg

fluorine (F) 15 31 kg

cadmium 0.03 3) 0 4) g

mercury 0 3) 0.01 g

arsenic 0.02 3) 1.9 g

heavy metals 1.9 3) 2.8 g

solid emissions to water

gypsum 4000 4700 kg

phosphate (P) 65 87 8.1 5.8 kg

fluorine (F) 53 39 33 45 kg

cadmium 96 98 0.5 1.4 g

mercury 61 74 0.2 0.5 g

arsenic 72 100 0.7 0 4) g

heavy metals 7) 33 88 53 27 g

rare earth metals 8) (17) 5) 6) 2200 360 g

radium-226 45 6) 1.4 2.3 MBq

polonium-210 40 6) 1.4 2.3 MBq

lead-210 50 6) 1.4 2.1 MBq

1) fluorine concentration <1 mg/Nm3

2) dust concentration 30 mg/Nm3

3) estimated values based on input-output calculations 4) all values measured are below detection limit 5) increase instead of decrease 6) decrease since 1992 (no data of 1985 available) 7) lead, copper, zinc, nickel and chromium 8) mainly lanthanum, cerium, praseodymium, neodymium


6.4 The future Dutch situation: Useful application of waste gypsum

The current situation of wet phosphoric acid production in the Netherlands is characterized by the use of highlyefficient processes with respect to P2O5-recovery, efficient prevention of fluorine and dust emissions to the air, andthe production of clean gypsum and low cadmium phosphoric acid through the use of clean phosphate rocks, i.e.phosphate rocks which are low in heavy metal content and concentrations of radionuclides. As in the Netherlandsland disposal of the by-product gypsum produced appears to be impracticable for a number of reasons, the currentsituation can be regarded as “best available”. However, the discharge of phosphogypsum to the sea is not acceptablefrom an environmental point of view, and therefore is not regarded as an alternative for disposal of the gypsum.Useful application of the gypsum is seen as the solution. Pilot plant tests have demonstrated the technical feasibilityof the production of a gypsum product that meets all specifications required for application of the gypsum in (in-door)building products like plaster, plasterboard and gypsum building blocks [51, 52, 53]. There are no technical limitationsfor full-scale production. Furthermore, the gypsum can be produced for a price which is comparable to the price fornatural gypsum [47]. In the Dutch situation, therefore, the useful application of by-product gypsum is regarded asbest available technique. Plans have been developed to start-up gypsum production in 2000, reaching full-scaleoperation in the year 2006 [48].

6.4.1 Description of gypsum upgrading installation

Instead of being discharged, the gypsum slurry from the wet phosphoric acid process is transported to the gypsumupgrading installation. Research has shown that many of the impurities present in the gypsum are enriched in thesmallest gypsum particles. In the gypsum upgrading process the gypsum is separated in a fine particle fraction(about 4% of the total gypsum) and a coarse particle fraction (about 96wt%) by means of a two-stage hydrocyclonesystem. Subsequently, the coarse particle fraction (roughly >15µm) is filtered, washed and dried by means ofvacuum filtration. In this way a large clean fraction is obtained that can be usefully applied. The fraction still containsthe bulk of the impurities, especially the radionuclide, but the levels of impurities in the gypsum are similar to thosefound in natural gypsum and other raw materials used for building products. At this moment no practicable solutionsfor useful application or land disposal of the fine particle fraction exist. The fines, which leaves the hydrocylones as avery dilute slurry (<1% dry weight), will be discharged to the sea. Although enriched relative to the unfractionatedgypsum, the total amount of impurities discharged is much less than in the present situation. A diagram of theupgrading unit is presented below.

w ater

slurry from phosacid process hydrcyclone vacuum filter

discharge gypsum fines effluent gypsum product

Figuur 10: Diagram of the phosphogypsum upgrading unit

6.4.2 Consumption levels

In table14 typical consumption figures, i.e. raw materials and utility requirements, are shown for the production ofconcentrated phosphoric acid and an a gypsum product called ProGips, which can be usefully applied [34, 54]. Dataare shown for Kemira Agro Pernis only. No data for Hydro Agri Rotterdam are shown as this plant will be closed atthe end of 1999.


Tabel 14: Typical consumption figures for the production of merchant grade phosphoric acid and gypsum (ProGips)by Kemira Agro Pernis.

Inputs Kemira (per ton P2O5)

Phosphate rock 2.8 ton

Sulphuric acid 2.6 ton

Process water 1) 55 m3

Cooling water 2) 118 m3

Electric power 207 kWh

Steam 2.8 ton

1) including scrubber water2) cooler and condensor water

6.4.3 Environmental performance

Table 15 shows the emissions per ton P2O5 due to discharge of the gypsum in the present situation and in the caseof full scale operation of gypsum upgrading is achieved. Other emission to air and water are not show as usefulapplication of the gypsum does not affect these issues [48].

Tabel 15: Emissions due to the discharge of gypsum, in the present situation and in the future situation with full scaleupgrading and useful application of the gypsum.

Kemira - 1996 1) Kemira - 2006 2)

per ton P2O5 per ton P2O5

solid emissions to water

gypsum 4000 470 kg

phosphate (P) 8.1 2.3 kg

fluorine (F) 33 4.4 kg

cadmium 0.5 0.04 g

mercury 0.2 0.2 g

arsenic 0.7 0.04 g

heavy metals 53 16 g

rare earth metals 2200 450 g

radium-226 1.4 0.4 MBq

polonium-210 1.4 0.7 MBq

lead-210 1.4 0.2 MBq

1) actual values based on emission data (measurements) and production figures 2) values based on estimates used in the application for a permit; actual values are generally lower


7. Evaluation of waste disposal methods by means of screening LCA

When identifying BAT according to the IPPC Directive, an integrated approach is required. In practice, this appearsto be a difficult task, as the integral assessment of BAT is hampered by the complexity of cross-media assessment.To solve this problem the Netherlands propose to use a transparent and structured assessment based on theprincipal steps of the so called Life Cycle Assessment (LCA). The LCA method is a standardized and internationallyaccepted method, and is known as a useful decision-supporting tool for product policy and environmental productdevelopment. There are no methodological restraints to apply the principles of LCA also for the environmentalassessment of processes. Because of the complexity of the life cycle of products (from cradle to grave) and theaccompanying need for data, LCA often gives the impression of being a complex and intensive way of analyzing theenvironmental burden. However, by well-considered adjustment of system boundaries to production processes (fromcradle to gate, or from gate to gate), a more simplified and less time-consuming method can be obtained.

The disposal of the phosphogypsum represents by far the most serious environmental aspect of wet-processphosphoric acid production. Recently, some detailed LCA studies have been carried out for the Dutch phosphoricacid industry [55, 56]. Based on data originating from these studies a screening LCA is performed to get insight in theenvironmental effects of different waste disposal scenario’s for this branch of industry [57]. The main results of thescreening LCA study are presented in this chapter. Thereby it is assumed that the principles of the LCA method areknown. For a more detailed description of the LCA method, the reader is kindly referred to existing literature on thissubject.

7.1 Starting points for the screening LCA

7.1.1 Gypsum disposal scenarios and functional unit

As mentioned before, there are three alternatives for disposal of phosphogypsum: discharge into water, storage onland and useful application. Based on these three options the following scenarios have been worked out. Thescenarios are graphically represented in figures 11, 12 and 13.

• Production in 1998, with discharge of all gypsum.• Production in 2006, with landfill of all gypsum.• Production in 2006, with useful application of most of the gypsum in the building industry.

The scenarios for disposal of phosphogypsum are compared on the basis of the production of 225 kton1 fertilizergrade phosphoric acid at Kemira Agro Pernis (KAP)2 and production of an amount of gypsum suitable for buildingproducts, equivalent to the amount of ProGips that KAP will produce in 2006 (functional unit).

1 The maximum annual quantity that KAP is allowed to produce.2 Since the recent decision by Hydro Agri Rotterdam to stop producing phosphoric acid at it’s Rotterdam facility, KAP is the only

remaining producer in the Netherlands.


7.1.2 System boundaries and data used

The system boundaries are chosen “from cradle to gate”. This means that the environmental impact (per functionalunit) includes the environmental burden from the process itself and from the use of raw materials and energy. Themost important starting points regarding the system boundaries are:

• The system boundary for the phophoric acid production lies just after the production of concentrated (merchantgrade) phosphoric acid.

• The production and use of fertilizers (resulting in diffuse emissions) are not included.• In the case of gypsum production (upgraded phosphoric gypsum or ProGips, flue gas desulphurization gypsum

and natural gypsum), the boundary is drawn just after drying dihydrate. Calcination to produce hemihydrate andthe production, use and waste treatment of building products are not included.

• In the case of landfill dewatering of the gypsum, transport of the gypsum to the landfill site and leaching ofcontaminating substances from the gypsum at the landfill site are included. It is assumed that 1% of allcontaminating substances eventually leaches to the environment (soil and groundwatersystem).

• The energy use and use of chemicals for groundwater control and emission control are not included. Also theemissions of radioactive substances to the air are not included.

Based on data from the Dutch phosphoric acid industry, the Dutch gypsum industry, (public) databases andliterature, environmental impact sheets were made for the different activities involved with the production of merchantgrade phosphoric acid and gypsum suitable for building products. The analysis is based on the actual productioncharacteristics of Kemira Agro Pernis (type and composition of phosphate rock used, sulphuric acid used, emissionsand specific consumption figures) which have been extrapolated to the maximum annual production capacity of theplant. A more detailed description of the starting points regarding system boundaries and data used are presentedelsewhere [57].

7.2 Results of the screening LCA and evaluation

7.2.1 Impact assessment

With the aid of the environmental impact sheets, the potential environmental effects were calculated based on socalled “equivalence factors”. These factors translate the emissions, waste and energy demand in potentialenvironmental effects on several environmental themes, such as greenhouse effect, ozone depletion, acidification,eutrophication, nutrification, aquatic ecotoxicity and (non-)toxic solid waste. The result of this characterization is a listof scores on environmental themes for the three alternative disposal scenarios. The list of scores is called theenvironmental profile.

The results of the characterization may be presented as non-normalized and as normalized. By normalization, theimportance of the various environmental themes for the scenarios studied are calculated by relating the scores to thetotal environmental burden of that theme for a certain area in a certain period of time. In this study the results of thescreening LCA have been related (normalized) to the total environmental burden caused by:• all anual economic activities on the Dutch territory in 1993• all annual economic activities on the Westen European territory in 1990 to 1994 (no complete set of data for one

particular year is available)

7.2.2 Non-normalized environmental profile

The non-normalized characterization scores are presented in figure 14. For presentation purposes the highest scoreper theme is put at 100%. The results show that the performance of the different disposal scenarios is very similarfor most environmental themes. The reason for this is that the scores on these themes are mainly caused by energyconversion and transport processes, which do not differ much for the different disposal scenarios.


0

10

20

30

40

50

60

70

80

90

100

reso

urce

s de

plet

ion

glob

al w

arm

ing

ozon

e la

yer

depl

etio

n

hum

an to

xici

ty

aqua

tic e

coto

xici

ty

sum

mer

sm

og

acid

ifica

tion

nutr

ifica

tion

land

use

ener

gy d

eman

d

non-

toxi

c w

aste

toxi

c w

aste

discharge

landfill

reuse

Figuur 14: Characterization scores of the three phosphogypsum disposal scenarios

The differences in effects between the three disposal scenarios mainly occur for the environmental themes aquaticecotoxicity, nutrification potential, land use and non-toxic solid waste. In this case the latter two themes are stronglycorrelated as the main sources of land use are mining of raw materials and landfill of both mining waste andphosphogypsum. To avoid counting impacts twice, only waste will be considered further. The reason for choosingwaste, and not land use, is that in Annex 4 of the IPPC Directive waste is explicitely mentioned as one of the items tobe taken into account when determining best available techniques.

Figure 15 shows that the reuse scenario has a better performance on aquatic ecotoxicity, nutrification and waste thanthe discharge scenario. Especially the environmental impact on aquatic ecotoxicity (80% less) and nutrification (60%less) are much lower. The performance of the landfill scenario on aquatic ecotoxicity and nutrification is even betterthan that of the reuse scenario. The landfill scenario, however, scores worse on waste, both compared to the reusescenario and the discharge scenario. As non of the three scenarios scores best on all the environmental themes it isnot possible on the basis of the characterization scores to decide which of the scenarios is most favourable from anenvironmental point of view.


7.2.3 Normalized environmental profiles

Normalized environmental profiles are shown in figure 15. These profiles clearly shows that the slightly larger scoreon nutrification and aquatic ecotoxicity of the reuse scenario in comparison with the landfill scenario is completelyoutweighed by the scores on waste. The difference between the scores on waste is more than 1 order of magnitudelarger than the difference on the other themes. This is especially the case in the Dutch situation, where, because of astrict waste policy, the total amount of waste is relatively small, and therefore the contribution of the studiedscenarios is relatively large. In the Western European situation, the differences between the various environmentalthemes are smaller, but still significant. Because of the dominance of waste, it is concluded from this screening LCAanalysis that the overall environmental performance of the reuse scenario is better than the landfill scenario, both inthe Dutch and in the Western European situation3.

Dutch situation

0

0,05

0,1

0,15

0,2

0,25

0,3

0,35

aquaticecotoxicity

nutrification non-toxicwaste

(eq

/yr)

discharge

landfill

reuse

European situation

0

0,001

0,002

0,003

0,004

0,005

0,006

aquaticecotoxicity

nutrification non-toxicwaste

(eq

/yr)

discharge

landfill

reuse

Figuur 11: Normalized environmental profiles of the three phosphogypsum disposal scenarios for the maindistinguishing environmental themes. The characterization scores are normalized by relating them to the total annualenvironmental burden on the Dutch and Western European territory.

3 In addition to the normalization, it is possible to weigh the different environmental themes, and achieve an overall performance for each

process. Weighing means that if an environmental theme is considered more important than another, this theme is assigned a higherweighing factor. Although no weighing step is carried out in this study, it is assumed that, because of the dominance of waste by morethan 1 order of magnitude, the reuse scenario overall has the best environmental performance. Applying a difference of more than 1order of magnitude in the interpretation of the normalized results means that it is assumed that the ratio between the most and leastimportant environmental theme is smaller than 10. In the Dutch approach of integral assessment of BAT by the screening LCA methodit is advised to use the ‘ratio 10’as a first approximation as long as no clear results can be derived from the normalized environmentalprofile and no societal preferences are available.


8. Concluding remarks and recommendations

Wet phosphoric acid is produced by digestion of phosphate rock with sulphuric acid. In this process phosphogypsum(calcium sulphate) is formed as by-product. The production of 1 ton of merchant grade phosphoric acid (54%P2O5)roughly requires 1.5 ton of phosphate rock and 1.5 ton of sulphuric acid, and yields approximately 2.5 ton ofphosphogypsum. The disposal of phosphogypsum is the main environmental problem of wet phosphoric acidproduction. It is, however, not the gypsum that is the problem, but the impurities present in the gypsum such asresidual acid, fluoride, mercury, cadmium and other heavy metals, rare earth metals and radionuclides such as 226Ra,210Po and 210Pb. The impurities originate mainly from phosphate rock or from the production process (residual acidity). The amount ofimpurities introduced into the process by sulphuric acid are generally low or negligible compared to the amountintroduced by the phosphate rock. Only in the case of mercury, and possibly lead, sulphuric acid may contributesignificantly, especially when fatal acid is the main type of sulphuric acid used Basically, three different options exist for handling phosphogypsum by-product, i.e. discharge into water, dumping onland and useful application of the gypsum. From an environmental point of view, it is commonly accepted that, thedischarge of phosphogypsum into water should be avoided by any means. The results of a cross-media assessment,based on the principal steps of the so called Life Cycle Assessment (LCA), indicates that, of the two remainingalternatives, the overall environmental performance of useful application is better than dumping on land. The mostpracticable option, however, will depend on the local conditions, among which the phosphoric acid technology appliedand the type of phosphate rock used. In the assessment of BAT for the production of phosphoric acid, the P2O5-efficiency should be a dominant factor.With increasing efficiency, less phosphate rock and less sulphuric acid is required per unit of acid produced. At thesame time the amount of phosphogypsum decreases per unit of acid produced. Efficiencies of 98% and more arepossible in recrystallization processes with two filtration stages. In addition to a high P2O5-efficiency, these processesalso produce phosphogypsum with considerably lower levels of impurities than the conventional processes.Consequently, the potential environmental hazards associated with the disposal of phosphogypsum are lower, and thepossibilities for useful application of the gypsum are better. With respect to recrystallization processes, the following should be noticed. Impurities introduced into the processare divided between the phosphoric acid product and the phosphogypsum by-product. If a smaller part of theimpurities ends-up in the phosphosgypsum, a larger part will end-up in the phosphoric acid. Eventually, theseimpurities will end-up in the environment through the use of fertilizers based on the intermediate phosphoric acid.This can be avoided by purification of the acid before further processing. As impurities in phosphogypsum mainly originate from phosphate rock, the ratio of impurities to the P2O5-content ofthe phosphate rock is an important parameter. The lower the ratio, the lower will be the content of impurities in thephosphogypsum. Together with the use of a process with a high P2O5-efficiency, the use of clean phosphate rock,therefore, is the most important preventive measure to reduce the potential environmental hazards associated withthe disposal of phosphogypsum, and to enhance the chances for useful application of the gypsum. Useful application of phosphogypsum is only possible if the quality meets required specifications. In general, thismeans that the quality of the phosphogypsum should be comparable to that of other gypsum resources. Besidesapplying clean phosphate rock in a recrystallization process, this may require upgrading of gypsum that does notmeet the specifications, and/or in-process removal of specific impurities that particularly hinder the application ofphosphogypsum. Upgrading of gypsum can be achieved by separation of fines (e.g. by means of hydrocyclones), asit appears that many of the impurities present in phosphogypsum are enriched in the smallest gypsum particles.


Developments for in-process removal of impurities by means of extraction and precipitation techniques are underway.As in-process removal of impurities may yield a cleaner gypsum as well as a cleaner phosphoric acid thisdevelopment deserves further attention. Other environmental problems at the wet phosphoric acid production are the emission of fluorine and dust (fromphosphate rock grinding) to air, and the emission of fluorine and phosphate to water. The emission of dust can beeffectively prevented by using fabric filters. Fluoride can be removed by a number of different gas scrubbing systemswith a removal efficiency of more than 99%. The gas scrubbing systems yield an effluent containing fluorine andphosphate components. Before discharge, the effluent can be neutralized with lime or limestone to precipitate fluorineas solid calcium fluoride and phosphate as calcium phosphate.


References

[1] Phosphoric acids and Phosphates, in Kirk-Othmer Encyclopedia of Chemical Technology, vol.18, 1992, John Wiley &

Sons Inc., United States, pp. 669-718.

[2] Phosphoric acid and Phosphates, in Ullmann’s Encyclopedia of Industrial Chemistry, 5th completely revised edition,

Vol. A 19, 1991, VCH Verlagsgesellschaft mbH, Weinheim, Germany, pp. 465-503

[3] On course for recovery?, Phosphorus & Potassium No. 192, June-August, 1994, 15-18.

[4] Reduction environmental burdening phosphoric acid process, Best Available Technology (Vermindering milieubelasting

fosforzuurproces, Best Uitvoerbare Techiek), Ministry of Housing, Spatial Planning and the Environment - Directorat-

General for Environmental Protection, Publication series Environmental Technology no. 1994/3 (in Dutch)

[5] Descriptive analysis of the technical and economical aspects of measures to reduce water pollution cased by

discharges from the fertilizer industry and other industries entailing nutrient discharges (BKH Consulting Engineers),

Commission of European Communities - Directorate-General Environment, Nuclear Safety and Civil Protection,

October 1991

[6] Best Available Techniques for Pollution Prevention and Control in the European Fertilizer Industry,

Booklet No. 4 of 8: Production of phosphoric acid, European Fertilizer Manufacturers’ Association (EFMA), 1995.

[7] Use and disposal of wastes from phosphoric acid and titanium dioxide production, Economic Commission for Europe

(ECE), United Nations Punblications, 1988

[8] Phosphates and Phosphoric Acid: Raw Materials, Technology and Economics of the Wet Process, Second Edition,

Revised and Expanded, Pierre Becker, Marcel Dekker Inc., New York and Basel, 1989

[9] Phosphate Fertilizer industry (Part III), in Pollution control in fertilizer production, C.A. Hodge and N.N. Popovici

(Eds.), Marcel Dekker Inc., New York, 1994, pp. 145-336.

[10] Sulfuric and Phosphoric Acids (Chapter 11), and Environmental Protection and Pollution Prevention (Chapter 19), in

Fertilizer Manual, United Nations Industrial Development Organization (UNIDO) and International Fertilizer

Development Center (IFDC) (Eds.), Kluwer Academic Publishers, Dordrecht, The Netherlands, 1998.

[11] Phosphate rock grade and quality, Phosphorus & Potassium No. 178, March-April 1992, 28-36.

[12] Winning phosphate from low-grade rock and mining waste, Phosphorus & Potassium No. 169, Sept.-Oct. 1990, 28-36.

[13] Steen, I., Phosphorus availability in the 21st century, Management of a non-renewable resource, Phosphorus &

Potassium No. 217, Sept.-Oct. 1998, 25-31.

[14] Mercury in Sulphuric Acid (Kwik in zwavelzuur), M. Weeda, Ministry of Transport, Public Works and

Water Management, Directorate-General for Public Works and Water Management Institute for Inland Water

Management and Waste Water Treatment (RIZA), report no. 98.113x, 1998 (in Dutch).

[15] Prayon displays its phosphate technology and operations, Phosphorus & Potassium No. 174, July-Aug. 1991, 38-43.

[16] The cadmium issue, Phosphorus & Potassium, Jan.-Feb. 1995, 27-33

[17] Leyshon, D., Phosphoric acid technology, Phosphorus & Potassium No. 212, Nov.- Dec. 1997, 25-31.

[18] Agarwal, S.S. and Murugaperumal, S., HDH process technology for phosphoric acid production, Phosphorus &

Potassium No. 214, March-April 1998, 38-42.

[19] Wet process acid cleaning comes of age, Phosphorous & Potassium No. 170, Nov.-Dec. 1990, 20-22.


[20] Overview emissions 1997 (Lozingsbeeld 1997) Hydro Agri Rotterdam and Kemira Agro Pernis, internal report, Ministry

of Transport, Public Works and Water Management, Directorate-General for Public Works and Water Management,

Directorate Zuid-Holland, 1997 (in Dutch).

[21] Combined license application Kemira Agro Pernis BV, part 4: Nuclear Energy Act (Gecombineerde

vergunningaanvraag Kemira Agro Pernis BV, deel 4: Kernenergiewet), January 1999, pp. 181-221 (in Dutch).

[22] Gypsum disposal and the environment, Phosphorus & Potassium No. 215, May-June 1998, 35-38.

[23] Market & Technical Analysis and Business Planning - Useful Applications of By-product Gypsum: Hydro Agri

Rotterdam and Kemira Agro Pernis, Booz-Allen & Hamilton Inc., July 1997.

[24] Where does all the process water go?, Phosphorus and Potassium No. 207, Jan.-Feb. 1997, 26-31.

[25] Stack management is an integral part of phosphoric acid plant operation; Containing phosphogypsum for safe disposal

on land, Phosphorus & Potassium No. 153, Jan.-Feb. 1988, 25-28.

[26] Van der Heijde, H.B. et al., Environmental aspects of phosphate fertilizer production in the Netherlands, with particular

reference to the disposal of phosphogypsum, The science of the Total Environment, 90, 1990, 203-225.

[27] Leyshon, D., The gypsum dilemma, Phosphorus & Potassium No. 202, March-April 1996, 34-40.

[28] Guimond, R.J. and Hardin, J.M., Radioactivity released from phosphate-containing fertilizers and from gypsum,

Radiat. Phys. Chem., Vol. 34, No. 2, 1989, 309-315.

[29] Heavy metals and by-product disposal: Suitable cases for treatment, Fertilizer International No. 368, Jan./Feb., 1999,

51-53.

[30] Mortvedt, J.J., Heavy metal contaminants in inorganic and organic fertilizers, Fertilizer Research, 43, 1996, 55-61

[31] Cadmium in Phosphates: one part of a wider environmental problem, Phosphorus & Potassium No. 162, July-Aug.

1989, 23-30.

[32] Phosphate Perspectives, Phosphorus & Potassium , July-Aug. 1995, 32-40.

[33] Phosphoric acid equipment - II, Phosphorus & Potassium No. 176, Nov.-Dec. 1991, 26-40.

[34] Company environmental plan - 2, 1998 - 2001 (Bedrijfsmilieuplan - 2, 1998 - 2001), Kemira Agro Pernis B.V.,

September 1998 (in Dutch).

[35] Company environmental plan (Bedrijfsmilieuplan), Hydro Agri Rotterdam, January 1995 (in Dutch).

[36] Phosphate removal & recovery from wastewaters, Phosphorus & Potassium No.213, Jan.-Feb. 1998,

30-39.

[37] Phosphate recovery for recycling from sewage and animal wastes, Phophorus & Potassium No.216,

July-August 1998, 17-21.

[38] Weterings, K., Processing of waste gypsum from phosphoric acid production (Verwerking van afvalgips uit de

fosforzuurbereiding), Polytechnisch tijdschrift - Procestechniek, 35 (2), 1980, 79-86 (in Dutch)

[39] Phosphoric Acid by Wet Process: Phosphogypsum, Transport, Storage and Utilization, in Pollution

control in fertilizer production, C.A. Hodge and N.N. Popovici (Eds.), Marcel Dekker Inc., New York, 1994, pp. 209-

223.


[40] Environmentally friendly phosphoric acid production: “Clean ways for gypsum” (Milieuvriendelijke

fosforzuurfabricage: “Schone wegen voor gips”, Kemira Agro Pernis & Hydro Agri Rotterdam, October 1996 (in Dutch).

[41] The removal of radio-active nuclides (De verwijdering van radio-actieve nucleiden), Intron report no. 96072, Sittard, the

Netherlands, April 1996 (in Dutch)

[42] Rutherford, P.M. et al., Heterogeneous distribution of radionuclides, barium and strontium in phosphogypsum by-

product, The Science of the Total Environment, 180, 1996, 201-209.

[43] Scope Study “Possibilities for processing of hydrocyclone fines at the ProGips® production” (Scope studie

“Verwerkingsmogelijkheden hydrocyclone fines bij ProGips® productie”), Feenstra et al., TNO-MEP report no. 98/156,

Apeldoorn, the Netherlands, April 1998 (in Dutch).

[44] Fertilizers by the nitrophosphate route, Phosphorus and Potassium No. 155, May-June 1988, 28-33.

[45] Nitrophosphate Fertilizers (Chapter 13), in Fertilizer Manual, United Nations Industrial Development

Organization (UNIDO) and International Fertilizer Development Center (IFDC) (Eds.), Kluwer Academic Publishers,

Dordrecht, The Netherlands, 1998, pp. 384-399.

[46] Best Available Techniques for Pollution Prevention and Control in the European Fertilizer Industry, Booklet No. 7 of 8:

Production of NPK Fertilizers by the Nitrophosphate Route, European Fertilizer Manufacturers’ Association (EFMA),

1995.

[47] Proceedings ProGips Symposium, 8 June 1999, Rotterdam, the Netherlands, Kemira Agro Pernis B.V., 1999.

[48] Combined license application within the framework of Environmental Protection act, Pollution of

Surface Water Act, Water Management Act, Nuclear Energy Act (Gecombineerde vergunningaanvraag in het kader

van Wet milieubeheer, Wet verontreiniging oppervlaktewater, Wet op de waterhuishouding, Kernenergiewet), Kemira

Agro Pernis BV, January 1999 (in Dutch).

[49] (Draft) License application for Pollution on Surface Water Act and Nuclear Energy Act

(Vergunningaanvraag Wvo en Kew, concept), Hydro Agri Rotterdam, January 1999 (in Dutch).

[50] van Ede, Hydro Agri Rotterdam, personal communication, 1999.

[51] Building on Gypsum II, Penders, L.M., Roelsma, W. and van Selst, R., Hydro Agri Rotterdam B.V. and Kemira Agro

Pernis B.V., September 1998.

[52] Einbrodt, H.J. et al., Bericht und Gutachterliche Stellungnahme: Unterscuchungen zur gesundheitlichen Beurteilung

von ProGips im Hinblick auf die Verwendung zur Herstellung von Baustoffen, Intron/Hydro Agri Rotterdam B.V./Kemira

Agro Pernis B.V., 1999 (in German).

[53] Radiation Performance of Progips Products, Bosmans and Leppers, Intron B.V. report no. 980556, Sittard, the

Netherlands, 1999.

[54] Environmental impact statement ProGips® production Kemira Agro Pernis B.V. and Hydro Agri Rotterdam (Milieu-

effect rapport productie ProGips® Kemira Agro Pernis B.V. en Hydro Agri Rotterdam B.V.), van Veen and de Graaf-

Bremmer, Tauw report no. 3613097, Deventer, the Netherlands, 1999 (in Dutch).

[55] LCA ProGips backing study for the benefit of environmental impact statement ProGips (LCA ProGips ondersteunende

studie t.b.v. MER ProGips), R. Seijdel, publication PRC Bouwcentrum, Bodegraven, the Netherlands, November 1998

(in Dutch).

[56] LCA phosphoric acid production system, R. Seijdel, PRC Bouwcentrum publication, Bodegraven, the Netherlands, May

1999.


[57] Cross-media assessment of gypsum disposal scenario’s for the phosphoric acid industry, R. Seijdel (PRC

Bouwcentrum BV), Institute for Inland Water Management and Waste Water Treatment RIZA, report no. 99.138x,

Lelystad, the Netherlands,1999.

Dutch notes on BAT for the phosphoric acid production

Annex 1: Thermal phosphoric acid process

In this section, the production of thermal phosphoric acid by Thermphos International (Vlissingen, the Netherlands) isoutlined. The process description and the environmental performance is considered.

Process description

The production of thermal phosphoric acid is carried out in two stages. First elemental phosphorus is produced fromphosphate rock. Then the elemental phosphorus is oxidized with air to P2O5, which is subsequently hydrated toproduce phosphoric acid. A schematic overview of the process is shown in the accompanying block diagram [1, 2].Typical data on consumption of raw materials and utilities, and formation of by-products in the process are presentedin table 1 [2, 3]. Typical data on emissions and waste of the process are shown in table 2 [3].

Production of elemental phosphorus

Elemental phosphorus is obtained from phosphate rock. Thermphos uses a mixture of sedimentary rock and igneousrock. The process starts with grinding of the phosphate rock. The ground phosphate rock is mixed with a slurryconsisting of water, clay and various phosphorus containing waste streams, to produce pellets in a granulator. Thepellets are sintered in a furnace at a temperature of about 800°C.

Phosphorus is released from the sintered pellets by heating the pellets to about 1500°C in an electric resistancefurnace together with cokes (to provide a reducing environment) and gravel (slag formation). The overall reaction canbe summarized as follows:

2 Ca3(PO4)2 + 6 SiO2 + 10 C →→ P4 + 10 CO + 6 CaSiO3

The process mainly produces gaseous phosphorus, carbon monoxide and a liquid slag. The gas phase is first passedthrough an electrofilter to remove dust (Cottrell dust). Subsequently gaseous phosphorus is recovered completelythrough condensation. The remaining gas phase mainly consists of carbon monoxide. This gas is used as fuel gas onthe site (e.g. in the sinter furnaces) and is sold to the nearby power plant. The left-over gas, if any, is flared. Theliquid slag is tapped from the furnace in batches, and yields a phosphorus slag (the major part) and a ferro-phosphorus slag (a minor amount) by-product. After further processing the former is used as foundation material inlarge construction works, while the latter is used as steel additive in the iron and steel industry. The P-recoveryefficiency of the phosphorus process is about 94%. The remaining phosphorus will mainly end up in the furnace slag(as unreacted phosphate). Minor amounts end up in ferrophosphorus (as alloy) and the Cottrell dust.

The production of phosphoric acid

At present only about 20% of the phosphorus produced is converted into phosphoric acid. In the past a considerableamount of thermal phosphoric acid was used for the production of sodium phosphate salts. More and more however,thermal phosphoric acid is being replaced (on the basis of economics) by purified wet phosphoric acid. Thermalphosphoric acid is almost exclusively produced for specific applications which require a very pure acid such as metalsurface treatment in the micro-electronics industry and the acidulation of beverages. To produce phosphoric acid from elemental phosphorus, first the phosphorus is brought into a reaction vesseltogether with air, after which the phosphorus oxidizes to P2O5. The heat evolving from this reaction is used for thegeneration of high pressure steam. Subsequently, the P2O5 is contacted with diluted phosphoric acid, and reacts withthe water present in the acid to form phosphoric acid. Two configurations for this process are used. In one case theabsorption of P2O5 by diluted phosphoric acid is carried out in the same reaction unit as where oxidation of thephosphorus takes place. In the other, preferential, case, the reaction of P2O5 to phosphoric acid is carried out in aseparate absorption tower, allowing energy recovery as high-pressure steam. The production of phosphoric acid fromelemental phosphorus is represented by the following reactions: P4 + 5 O2 →→ 2 P2O5

P2O5 + 3 H2O →→ 2 H3PO4


Main environmental aspects

The environmental performance of the thermal acid plant is presented in table 2 [2, 3]. Main sources of emissionsand waste in the production of phosphorus and phosphoric acid from elemental phosphorus are: • Sintering of the phosphate rock pellets and drying of cokes in the sinter furnace. The off-gas from the sinter

furnace contains a wide range of pollutants such as dust, fluoride, phosphate, heavy metals, radionuclides andSO2 and NOx. The off-gas from the ovens is cleaned in two-stage scrubber systems with closed water circuits,before being emitted to the air. To prevent accumulation, pollutants are removed from the recirculating washwater stream through neutralisation followed by flocculation and separation of the solids. The solids obtained arereturned to the process either via the slurry station or via the phosphate rock (after drying).

• Calcination of Cottrell dust, flaring of fuel gas and drainage of liquid slag from the phosphorus furnace:

– The gas phase produced in the phosphorus furnace contains a considerable amount of dust (so-calledCottrell dust) which is removed through an electrofilter. As a result of closed loops (reuse of waste streams)in the process, the dust is enriched in heavy metals (mainly zinc) and radionuclides (such as 210Po and210Pb). The dust is mixed with water and recycled to the slurry station. However, due to the high zinccontent in the dust, part of it is removed to prevent excessive accumulation. The dust is calcined (emissionof dust, F and P2O5 to the air) and stored. In the near future storage will be replaced to a special storagefacility for all kinds of radioactive waste.

– After recovery of phosphorus from the gas, the remaining gas mainly consists of carbon monoxide. This gasis used as fuel gas on the site (e.g. in the sinter furnaces) and is sold to the nearby power plant.The left-over gas, if any, is flared, which contributes to SO2 and NOx emissions to the air.

– Vapours released at drainage of the liquid slags from the phosphorus furnace, are being removed, andwashed with water in a venturi scrubber before being emitted to the air;

– Process effluents that have been in contact with phosphorus are sent to the waste water station. Aftertreatment (sedimentation followed by neutralisation, flocculation and separation of the solids formed), 70 to90% of the water is recycled to the process. The remaining water is treated with lime for further P2O5-removal and is subsequently treated in an biological wastewater treatment plant before being discharged tothe sea. All solids are recycled to the process.

• Oxidation of phosphorus in the acid plant and removal of arsenic from the acid:– The off-gas from the acid towers is contaminated with traces of P2O5 and phosphoric acid. To minimize

emissions the off-gas is cooled and washed with recirculating acid and water, and subsequently treated in aventuri scrubber (diluted acid) and a demister. The bleed of the recovery system is reused either in the wetphosphoric acid purification plant or the slurry station. The emissions of the acid plant are small comparedto the emissions of the sinter plant and the phosphorus plant.

– Due to the specific fields of application (e.g. additive to foodstuff and beverages) traces of arsenic presentin the phosphoric acid have to be removed. To this end sodium hydrogen sulphide (NaHS) is added to theacid, upon which arsenic is precipitated as arsenic sulphide (As2S3). After separation and furtherprocessing, the latter is obtained in concentrated form and stored as hazardous chemical waste.


References [1] License application for Pollution on Surface Water Act (Vergunningaanvraag Wvo), Thermphos International B.V.

Vlissingen, The Netherlands, June 1997 (in Dutch)

[2] SPIN-document Hoechst, K. Huizinga and A. Hoogenkamp, RIVM report no. 773006155, RIZA report no. 92.003/55,

September 1993 (in Dutch).

[3] Environmental & Safety Annual Report 1998, Thermphos International B.V. Vlissingen, March 1999 (in

Dutch).

phosphate rock

grind mill

clay

emissions to air granulator slurry station wet acid process

filter cakes

gas scrubber sinter oven

sinter

phosphate

filter calcinate (solid waste)

Cottrell slurry

air emissions fuel gas

coke gas- waste water

silica furnace gases electrofilter condensation scrubber station

emission to air effluents

slag tapping

scrubber

furnace slag

drainage emission to water

emission to air cakes to furnace filtration

cooling

furnace slag and ferro-phosphorus by-product

phosphorus

air

water

to air

combust ion

chamber *

steamoff-gas

recoverywater

absorption

tower *sulfide

acid to process

cooling precipitation phosphoric acid

product

arsenic values (solid waste)

* process w ith separate combustion, including steam generation, and absorption

Figuur 12: Diagram of the phosphorus and thermal phosphoric acid production at Thermphos


Tabel 1: Typical data on raw material and utility consumption, and formation of by-products for the production ofthermal phosphoric acid.

ThermPhos - 1998 1)

Per ton P2O5

Inputs

Phosphate rock 3.0 - 3.4 ton

Clay 0.2 - 0.3 ton

Gravel 1.2 - 1.3 ton

Cokes 0.5 - 0.6 ton

Process water 40 m3

Cooling water 120 m3

Electric power 5700 - 6000 kWh

Natural gas n.a. Nm3

Steam n.a. ton

Outputs: by-products

Fuel gas 1500 - 1600 1) Nm3

Phosphorus furnace slag 3.2 ton

1) In 1998 about 20% of this gas was flared

Tabel 2: Emissions factors realized during production of elemental phosphorus and phosphoric acid by Thermphosin 1998.

ThermPhos - 1998 1)

Per ton P2O5

Emissions to air

Phosphate (P) 0.6 kg

Fluorine (F) 0.1 kg

Dust 0.4 kg

Cadmium 1.0 g

Lead 6.0 g

Zinc 5.9 g

Polonium-210 3.5 MBq

Lead-210 0.3 MBq

Emissions to water

Phosphate (P) 0.7 kg

Fluorine (F) 0.7 kg

Cadmium 0.2 g

Mercury <0.01 g

Arsenic <0.07 g

Heavy metals 14 g

Polonium-210 0.05 MBq

Lead-210 0.06 MBq

Waste

Cottrell dust 3.2 kg

Arsenic sulphide filter cake 0.1 kg

1) The figures presented in the table are based on the total emissions of the sinter plant, the phosphorus plant and the acid plant, and the amountof phosphate rock processed in 1998 assuming a P2O5 content of 33% and an overall P-recovery efficiency of 94%. In 1998 only about 20% of thephosphorus produced was converted into phosphoric acid on site. The remaining was sold as phosphorus.


Annex 2: Typical composition of various phosphate rocks

The specifications in the table are an indication of the composition of the various phosphate rocks. Differentspecifications my be found for the same type of phosphate rock. Both the quality of the rock and the level ofimpurities may vary. This is caused mainly by the variation in composition which is present by nature, but may alsobe caused by different results of analyses.

Sedimentary phosphate rock Igneous phosphate rock

Morocco Morocco Jordan Israel Florida Senegal Togo Russia Russia S.Africa

K11 Bucraa Eshydia Zin Taiba Kola Kovdor Phalaborwa

main constituents (wt%)

P2O5 31,1 36,4 33,0 32,4 32,9 37,5 36,1 38,1 37,0 40,2

CaO 50,2 50,9 49,5 52,0 48,9 51,0 50,8 51,8 52,5 54,1

F 3,9 4,0 3,8 3,6 3,8 3,8 3,5 3,6 0,8 2,6

Org. C 0,3 0,2 0,2 0,2 0,3 0,6 0,2 0,09 0,2 0,03

SiO2 1,1 3,7 4,0 1,3 1,5 2,7 3,0 1,4 2,0 0,4

Fe2O3 0,2 0,2 0,3 0,1 1,0 1,1 1,4 0,3 0,2 0,2

Al2O3 0,6 0,4 0,2 0,1 1,2 1,1 1,1 0,7 0,1 0,1

MgO 0,4 0,1 0,2 0,3 0,3 0,02 0,1 0,05 2,1 0,4

trace elements (ppm)

Cd 9 35 5 22 6 62 52 <1 <1 0,2

Hg 0,05 0,04 0,02 0,01 0,1 0,2 0,05 0,001 0,01 0,01

As 10 13 5 7 7 18 15 2 2 11

Pb 4 4 3 5 17 5 9 4 3 20

Zn 180 75 120 400 81 320 20 5 6

Cu 40 11 9 25 13 45 37 30 90

Ni 32 8 10 70 21 28 39 2 2 18

Cr 360 87 65 75 47 6 8 1 3 1

Co 2 12 20 2 1 7 2 2

V 205 32 60 200 63 72 30 10

Ti 245 33 30 230 900 170 29

Mn 15 151 170 12 110 170 250 74

REE 1) 900 415 110 135 610 6300 1400 4800

radioactivity (Bq/kg)

238U 1415 750 740 1325 1500 35 30 110232Th 18 16 16 92 37 90 30 360226Ra 1370 750 720 1325 1300 35 12 110210Po 1425 750 630 1325 1300 35 13 110210Pb 1230 750 645 1325 1300 35 8 110

1) Rare earth elements: scandium, yttrium, lanthaan, cerium, praseodymium, neodymium, samarium, europium, gadolinium, terbium, dysprosium,holmium, erbium, thulium, ytterbium, lutetium; underlined are the elements that are the most abundant.


Annex 3: Use of gypsum as raw material or as product Potential uses for gypsum fall into the three broad categories:• Uses for agricultural purposes;• Uses in construction and building materials;• Industrial uses.

Uses for agricultural purposes

Direct use

Gypsum is useful as a fertilizer for calcium- and sulphur-deficient soils, such as those found in Brazil and othercountries. It is also effective as a soil conditioner for acid soils rich in active aluminium (Al3+), which tend to haveadverse effects on plant roots. Acid soils may predominate in nearly 30% of the total farmland in the world. Gypsumcan supply calcium to plants and can also reduce the adverse effect of aluminium by forming AlSO4

+. In India, Coromandel Fertilizers and EID Parry dispose of all their gypsum for agricultural purposes. This was also thecase in the United States. In 1992, The Environmental Protection Agency (EPA) banned the use of gypsumcontaining more than 360 Bq/kg of radium equivalency for soil applications.

Conversion to ammonium sulphate or potassium sulphate

Conversion of gypsum to ammonium sulphate can be done for the fertilizer industry. In this process ammonia, carbondioxide and gypsum form ammonium sulphate and calcium carbonate. Calcium carbonate can be used in cement oras fertilizer as well. Potential environmental hazards can be expected with the use of calcium carbonate, because ofthe radioactivity levels. Full scale plants, with natural gypsum as raw material, are operational in Austria, Italy, Indiaand Indonesia. For potassium based fertilizers, usually potassium sulphate is produced (Sulphate of Potash). In this processpotassium chloride and gypsum form potassium sulphate and calcium chloride. Calcium chloride precipitates and hasto be disposed of. With the use of phosphogypsum the gypsum disposal will be substituted with an impure calciumchloride disposal, with comparable environmental problems.

Uses in construction and as building materials

There are three main possible uses for by-product gypsum as construction and building material:• Uses as a road based material;• Production of plaster and related products;• Cement additive.

Uses as a road based material

Phosphogypsum can be used in road construction as a road base material. Phosphogypsum stabilised with cementor flyash can replace and upgrade secondary roads constructed of clay and sand. A possible environmental hazardfrom phosphogypsum is leaching together with other possible impurities from cement or fly ash. Pollution to the soilor groundwater may occur. Immobilisation techniques, such as washing or thermal treatment may be necessarybefore usage. An experimental road was constructed in Florida (United States) and has been open for traffic since1986.

Production of plaster and related products

The processes used for converting phosphogypsum into plaster and related products are essentially the same aswhen using natural gypsum. The majority of plasters are based upon the hemihydrate form of calcium sulphate, sincethis rehydrates more quickly than the anhydrate form and is therefore quicker setting. One of the major uses ofplasters is in the manufacture of prefabricated plaster products. Plasterboards, for example, are manufactured byreslurrying dry plaster which is than encased in durable paper liners. To manufacture blocks, the slurry is poured intomoulds to set and then cut into the required size. For these products a rapidly setting plaster is desirable(hemihydrate gypsum).


Gypsum can be dehydrated (from dihydrate to hemihydrate) either by dry calcination (under pressure in an autoclave)or in aquous suspension. Calcination at a temperature of about 150°C converts most of the gypsum into calciumsulphate hemihydrate. The product contains about 5-6% water. Phosphogypsum contains a number of impurities which can affect the properties of the plaster: Residual acidreduces the setting rate and increases the corrosiveness towards building structures, sodium and potassium saltcause crystalline bloom on the plaster surface. Organic substances discolor the gypsum, etc. The limiting factor inthe use of phosphogypsum is the level of radioactivity (radium content). Because the levels are higher than in naturalgypsum, application of phosphogypsum as plaster product in indoor houses is not acceptable in the Netherlandswithout gypsum purification. With regard to regulation on radioactivity levels in Europe, there are two approaches:• Regulation on radioactivity levels in building materials. The Netherlands is focussing on radioactivity levels of

building materials normally used (approx. 150 Bq/kg). In Sweden and Germany there is a standard of 200 Bq/kgfor all product categories.

• Regulation on radioactivity in the air in houses/buildings. There are large differences between countries, rangingfrom 150 up to 750 Bq/m3 for new houses.

Cement additive

Gypsum is used as an additive in cement to retard the rate at which the cement sets, keeping it in a workable statefor a longer period. Its use also increases the strength of the final material. Suitable purification of phosphogypsummay be necessary, since phophate and fluoride impurities adversely affect the properties of the cement by delayingthe set and decreasing the initial hardness. The degree of purification required will naturally depend on thephosphoric acid process and the phosphate rock used.

Industrial use

Gypsum can be used as a filler in the paper industry. The sulphate content in the gypsum can also be reprocessedfor the production of sulphuric acid and cement.

Paper industry

The paper industry uses mineral-based pigments, both as filler and for paper coating.Filler pigment is mixed with the pulp. The most widely used fillers are kaolin, chalk and talc. The qualitycharacteristics of filler pigments are very important. The filler affects, amongst other things, the absorption capacity,porosity and smoothness and the whiteness of the paper. The primary function of the coating pigment is to improvethe printability of the paper. Coating paste is applied on the paper surface. Koalin and calcium carbonate are used ascoating pigment.

The limiting factor in the use of phosphogypsum as filler or for paper coating is its whiteness. Gypsum pigment isproduced from phosphogypsum on industrial scale by Kemira Oy (Finland), based on a high quality phosphogypsumproduced from igneous phosphate rocks and recrystallization of phosphoric acid processes (HDH and DHH). Herethe gypsum is washed more thoroughly in order to reduce the amount of residual acid. The filter-dry gypsum isdispersed with water by means of dispersion chemicals. The gypsum slurry is milled to a low particle size andstabilising chemicals are added to the slurry.

If phosphogypsum contains impurities with a colouring effect, bleaching of the gypsum is necessary.


Recycling to sulphuric acid and cement

Gypsum is useful in producing sulphuric acid and cement by calcination with clay and coal around 1450°C. Gypsumis decomposed to form lime (CaO) and sulphur dioxide (SO2). CaO reacts with clay to produce cement, while SO2 inthe gas is used to produce sulphuric acid by the conventional catalytic process. Major problems with phosphogypsumare the high moisture content, which increases energy consumption. Also the impurities may have adverse effects,such as poisoning the catalyst delaying the setting in the cement (caused by phosphorus). This process has beenused in England, Germany and Austria. The most recent plant, in Phalaborwa (South Africa), was shut down in 1989as a result of low sulphur prices.


Annex 4: Detailed process description of the HDH-1 process of Kemira Agro Pernis (KAP)and the HDH-2 process of Hydro Agri Rotterdam (HAR)

Kemira Agro Pernis (KAP)

The HDH-1 process of KAP comprises phosphate rock grinding, reaction and re-crystallization, gypsum repulpingand product acid desulfatation and evaporation. The diagram of the process is presented below.

phosphate rock

grind mil l dust filter dust to air

water water fluorine to air

sulphuric acid

reactors scrubber f luor ine and phosphate to water

flash cooler

return acid water fluorine to air

recrystallisator scrubber f luor ine and phosphate to water

water

filter repulp fi l ter gypsum to water

desulfatation

phosp. acid

storage fluorine and

water water phosphate to

water

steam evaporator separator scrubber condenser

seal vac.pump


Figuur 13: Diagram of the HRC-repulping process of Kemira Agro Pernis

Grinding

The phosphate rock is grinded in a ball mill followed by a particle size separator and cyclones, from which theparticles are pneumatically transported to storage. The finest fraction is adsorbed in a dust filter and the largestparticles are recycled to the mill.


Reaction- and recrystallization system

This section includes two premixers, three reactors and four crystallisators. Sulphuric acid is firstly diluted to 75%;cooling water is used to control the temperature. In the premixers sulphuric acid and weak phosphoric acid from thefiltration (return acid) are added to the phosphate rock to form calcium phosphate at a temperature of 90°C. In thereactors this transformation is completed. In the crystallisators the slurry is cooled down to 60°C by direct contactwith cooling air. During cooling down the hemihydrate transforms into dihydrate while the slurry is recirculated.

Scrubbing system

The reaction gases and the extraction air from the crystallisators are washed with water in separate two-stagescrubber systems. Gas scrubber effluents are discharged into surface water (seawater).

Filtration

In a rotary table vacuum filter the hemihydrate crystals are separated from the phosphoric acid slurry and washedcountercurrently. The process involves a number of stages and filtrate offtakes. The first offtake is the product acid.The acid collected from the second stage is a return acid, which is pumped back to the hemihydrate reaction system.The third stage generates acidic washing water. Final cake washing is done using acid from the repulping filter,before the cake is discharged to the repulping filter. Four vacuum water ring pumps in series, which effluent isdischarged into surface water, maintain the vacuum in the system.

Gypsum repulping section

The final P2O5 losses are removed from the gypsum cake in the repulping vacuum belt filter. The cake undergoescountercurrent washings. The filtrate is used for washing the rotary table filter. The final wash is used for washing therotary table filter cloth. Finally, the gypsum is slurries with river water and discharged into surface water.

Phosphoric acid desulfatation

In the desulfatation unit the remaining sulphuric acid is removed from the product acid. A calculated amount ofphosphate rock is fed to a stirred reactor and reacts with the sulphuric acid to form gypsum. The gypsum slurry isseparated from the acid and pumped to the crystallisators.

Phosphoric acid concentration

The phosphoric acid produced contains approx. 28% P2O5. Concentration of the product acid to 54% P2O5 isnecessary. Concentration is done in four stages by forced vacuum evaporation. Each stage consists of a heatexchanger, a flash chamber, condenser, vacuum pump and circulation pump. Steam is required for the evaporationheat. Fluoride gases from the evaporator flash chamber are fed through an entrainment separator to remove P2O5

droplets, followed by absorption in a water scrubber, where fluosilicic acid is produced. The gases are further washedwith water in a direct contact condenser followed by absorption in a vacuum water ring pump. Liquid effluents aredischarged into surface water (seawater).

Prevention and reduction of emissions

The following overview gives a summary of measures which are taken to prevent or minimize emission to air andwater:• Use of hemihydrate-dihydrate recrystallization process with single stage filtration (Nissan HRC-process),

extended with a repulp filter. The P2O5-recovery efficiency of the process is more than 98%.• Use of a relatively large excess of sulphuric acid for complete dissolution and good recrystallization of the

hemihydrate gypsum to dihydrate gypsum with a low P2O5-content. (After separation of the product acid from thedihydrate gypsum, phosphate rock is added to lower the sulphate content in the acid. The gypsum produced inthis operation is returned to the recrystallization section as a slurry. The remaining product acid (28%) isconcentrated in four stages to merchant grade acid (54%) by means of vacuum evaporators, and subsequentlytransferred to storage tanks. The sludge from settling and storage tanks is also returned to the recrystallizationsection as a slurry.)

• Use of cleanest igneous phosphate rock (Russian Kovdor rock, 65 - 80%) and sedimentary phosphate rock(Jordan rock, 20 - 35%) presently available.

• Separation and recycle of coarse material to ball mill grinding system to ensure an optimal particle sizedistribution for digestion of the phosphate rock particles in the reactors.


• Dust separation at grinding by means of cyclones and fabric filter.• Fourfold countercurrent washing of gypsum (twofold washing in dihydrate and repulp filtration section each) with

warm wash water to remove as much as possible P2O5 values from the gypsum. The washing cycle produces aweak acid which is returned to the reactor.

• Two-stage gas scrubbing (pre-washing in exhaust pipe followed by treatment in an unpacked spray tower) ofreaction gases and process air from the reactors and recrystallization tanks. The wash water form the spraytowers, containing mainly fluoride and some phosphate, is discharged to the sea without further treatment.

• Use of droplet separators to remove phosphoric acid droplets form the evaporator off gases, and single stagewashing of the off gases in the evaporator exhaust pipes, with recovery of the fluoride as H2SiF6 in the first threestages. By subsequently using the wash water in the first, second and third stage, a 28% H2SiF6 by-product isobtained. The condensable gases which are left after washing (mainly water vapour and some fluoride containingcompounds) are removed by direct contact condensors. Condensor water and the wash water of the fourth stageare discharged to the sea without further treatment.

• Extraction and washing (in one of the unpacked spray towers) of air from the building where filtration takes placeto avoid diffuse fluoride emissions.

• Continuous monitoring of gas phase fluoride concentration and automatic alarm system to be able to react rapidlyand avoid prolonged air pollution in case limit values are exceeded.

• Reuse of heat arising from sulphuric acid dissolution (96% to 75%) by using heated cooling water as gypsumwash water.

• Recovery of steam condensate from the evaporator section for use elsewhere (fertilizer plants)• Frequent cleaning of evaporator section with hot 5% H2SiF6 to remove scale (affects heat transfer), and reuse of

the rinsing liquid as washing liquid for the gypsum filters.• Leakages and rinsing losses during cleaning and rinsing operations are collected in a closed containment system

and recycled to the process

Hydro Agri Rotterdam (HAR)

The HDH-2 (hemi-dihydrate) process of HAR comprises two reaction systems and two filtration steps. A diagram ofthe process is presented below.

Phosphate rock handling

Phosphate rock from storage is sieved and transported by a covered conveyor belt to a weighing unit, where an amount ofrock is dosed to the reaction system.

Grinding

(no grinding)

Hemihydrate reaction system

There are two parallel reaction systems on the HAR site. One reaction system comprises three reactors in series which areall fitted with agitators. Phosphate rock and recirculated slurry from the flash cooler are fed to the first reactor where part ofthe calcium precipitates. In the second reactor sulphuric acid and phosphoric acid from the hemihydrate filter (return acid)are added with the slurry and the remaining calcium in the slurry precipitates. A flash cooling system, which pumps the slurryfrom the second reactor to the first reactor, maintains the system temperature. The third reactor is the filter feed tank. The second reaction system consists of four reactors and temperature is controlled by air-cooling.


Hemihydrate filtration

In a vacuum belt filter the hemihydrate crystals are separated from phosphoric acid slurry and washed countercurrently. Theprocess involves a number of stages and filtrate offtakes. The first offtake is the product acid, the second is pumped back tothe hemihydrate reaction system as return acid. Final cake washing is done using acid from the dihydrate filter. Finally, thecake is discharged to the dihydrate reaction system. Off-gases are washed with water in a direct contact condenser, followedby absorption in a vacuum water ring pump. Liquid effluents are discharged into surface water, remaining vapours are fed toa gas scrubber.

phosphate rock

water

water flash cooler fluorine to air

sulphuric acid

reactors scrubber scrubber effluent

(f luorine and phosphate)

return acid

water

scrubber effluent

filter scrubber (f luorine and phosphate)

recrystallisator vapour water

filter gypsum to water

phosp. acid

storage

water water

steam evaporator scrubber condenser

scrubber effluent


Figuur 14: Diagram of the Hemi-dihydrate process (HDH-2) of Hydro Agri Rotterdam

Dihydrate reaction system

In this process the hemihydrate cake is redissolved and recrystallised as dihydrate gypsum. During this operation, any P2O5

bound in the crystal lattice is released and passes into solution. The P2O5 slurry is fed back into the process. The dihydratereaction system comprises two reactors in series, with agitators. In the first reactor sulphuric acid and silica (SiO2) is fed withthe slurry to support the hemihydrate transformation. The second reactor is the filter feed tank.

Dihydrate filtration

The dihydrate slurry from the reactor is pumped to the dihydrate vacuum belt filter. The filter separates the dilute phosphoricacid solution from the dihydrate crystals. The gypsum cake undergoes countercurrent washings. The filtrate is used as afinal wash for the hemihydrate cake and the hemihydrate fabric filter. Finally, the gypsum and the dihydrate fabric filterwashing water is discharged into the surface water (seawater). The vacuum system of this filter is similar to the hemihydratefilter.

Scrubbing system

The high temperature of the hemihydrate process results in fluoride formation, mainly as SiF4, to the gas outlet. There arefour gas scrubbing systems to absorb the fluoride compounds. Scrubber effluents are discharged into surface water(seawater):• A two-stage scrubber for the first hemihydrate reaction system. Reaction gases from the first two reactors are extracted

by the gas scrubber fan and washed with water in the first gas scrubber stage. Fluoride from the third reactor and theflash cooler gas stream are scrubbed in the final stage scrubber.

• A single-stage scrubber for gases from the second hemihydrate reaction system.• A two-stage scrubber for gases from the hemihydrate filter and the dihydrate reactors.• A two-stage scrubber for gases from the dihydrate filter.


Phosphoric acid concentration

The phosphoric acid produced contains 42% P2O5. Concentration of the product acid to 54% P2O5 is necessary.Concentration is accomplished by the forced vacuum evaporator system, comprising a heat exchanger, a flash chamber,condenser, vacuum pump and circulation pump. Steam is required for the evaporation heat.

Apart from water vapour, a mixture of SiF4 and HF is generated during the concentration of phosphoric acid. Most of thefluoride is absorbed as dilute fluosilicic acid in a scrubber containing a weak fluosilicic acid solution. The requiredconcentration is maintained by removing an amount of fluosilicic acid product. The gases are further washed with water in thedirect contact condenser. The washing water is recycled to the scrubber systems.

Prevention and reduction of emissions

The following overview gives a brief summary of measures which are taken to prevent or minimize emission to air and water:• Use of hemihydrate-dihydrate recrystallization process with double stage filtration (HDH-2 process). The P2O5-recovery

efficiency of the process is about 99%.• Use of cleanest sedimentary phosphate rock (Jordan rock, 100%) presently available.• Addition of a sodium chloride solution in the hemihydrate reaction system to influence/reduce the uptake of cadmium in

the gypsum crystal lattice.• Multiple washing of gypsum in countercurrent (dihydrate filtrate is used for washing of the hemihydrate gypsum). The

washing cycle produces a weak acid which is returned to the hemihydrate reactor.• Hemihydrate reaction system: Washing of vacuum cooler off-gas by means of a direct contact condensor (condensable

gases) followed by washing of the gas in an unpacked spray tower (non-condensable gases). Furthermore two-stage andsingle-stage washing of reactor off-gases and cooling air in unpacked spray towers. Condensor water and spray towerwash water is discharged to sea without further treatment.

• Dihydrate reaction-/recrystallization system: Washing of reactor off-gas in an unpacked spray tower. The wash water isdischarged to sea without further treatment.

• Hemihydrate and dihydrate filtration system: Use of liquid separators to remove entrained phosphoric acid dropletspresent in the vacuum filtration off-gases, and subsequent washing of the gases in a “packed bed direct contactcondensor” and an unpacked spray tower. Gases arising from the warm filter surfaces are extracted by an exhaust hoodand also washed in a spray tower. Condensor water and spray tower wash water are discharged to the sea withoutfurther treatment.

• Evaporation system: Washing of evaporator off-gases with a recirculating 25% H2SiF6 solution in a fluoride gasscrubber, with recovery of the fluoride as H2SiF6. The condensable gases that remain after washing (mainly water vapourand some fluoride containing compounds) are removed by means of direct contact condensors. The condensor water isre-used as wash water in the gas scrubber systems of the reaction, recrystallization and filtration sections before beingdischarged to the sea.

• Frequent cleaning of the evaporator section to remove scale (affects heat transfer). The rinsing liquid is reused in thephosphoric acid production process.


Annex 5: Emission monitoring standards used in The Netherlands

Component Monitoring standard Frequency

Emissions to water

COD (Chemical Oxygen Demand)Nitrate (NO3)N-Kjeldahl (Nkj)Gypsum (as CaSO4.2H2O)Calcium (Ca)Phosphate (P)Fluorides (F)Cadmium (Cd)Mercury (Hg)Lead (Pb)Zinc (Zn)Copper (Cu)Nickel (Ni)Chrome (Cr)Arsenic (As)Vanadium (V)Cobalt (Co)Rare earth elements (Sc, Y, La, Ce, Pr, Nd,...)

NEN 6633NEN-EN-ISO 13395NEN 6472calculation from Ca-content in gypsum slurryNEN 6446 after disclosure according to NEN 6465 *

NEN 6663NEN 6483NEN 6426 after disclosure according to NEN 6465NEN-EN 1483 after disclosure according to NEN 6465NEN 6453 after disclosure according to NEN 6465NEN 6443 after disclosure according to NEN 6465NEN 6426 after disclosure according to NEN 6465NEN 6426 after disclosure according to NEN 6465NEN 6458 after disclosure according to NEN 6465NEN 6426 after disclosure according to NEN 6465NEN 6426 after disclosure according to NEN 6465RIZA W4.135 after disclosure according to NEN 6465NEN 6426 after disclosure according to NEN 6465

Frequency of emissionmeasurement is situationspecific.

Emissions to air The Netherlands Emission Regulations (NeR) are concernedwith process emisions to air and apply as guidelines for theissuing of licences or for the adjustment of license conditions.The NeR follows the same basic concept as the German TA-Luft, except that the classification of some substances hasbeen adjusted in the light of recent toxicological findings. Inaddition, the emission standards for some classes ofsubstances have been adjusted in line with current knowledgewith regard to best available techniques. In the NeR,concentration standards for different substances are given,which constitute upper limits for distinct point sources,depending on mass flow. The “special regulations” comprisemeasuers to limit emissions from incidental discharges ordiffuse sources. Furthermore, in the “special regulations”rules departing form the “general emission standards” forcertain industries or specific installations are given.

* Beforehand the sample should be diluted such that visually no solids are present after disclosure.

The Florida Institute of Phosphate Research was created in 1978 by the Florida Legislature(Chapter 378.101, Florida Statutes) and empowered to conduct research supportive to theresponsible development of the state’s phosphate resources. The Institute has targeted areas ofresearch responsibility. These are: reclamation alternatives in mining and processing, includingwetlands reclamation, phosphogypsum storage areas and phosphatic clay containment areas;methods for more efficient, economical and environmentally balanced phosphate recovery andprocessing; disposal and utilization of phosphatic clay; and environmental effects involving thehealth and welfare of the people, including those effects related to radiation and waterconsumption.

FIPR is located in Polk County, in the heart of the central Florida phosphate district. TheInstitute seeks to serve as an information center on phosphate-related topics and welcomesinformation requests made in person, by mail, or by telephone.

Research Staff

Executive DirectorRichard F. McFarlin

Research Directors

G. Michael Lloyd Jr. -Chemical ProcessingJinrong P. Zhang -Mining & BeneficiationSteven G. Richardson -RecIamationGordon D. Nifong -Environmental Services

Florida Institute of Phosphate Research1855 West Main StreetBartow, Florida 33830

(863) 534-7160Fax:(863) 534-7165

THE ECONOMIC BENEFIT OF PHOSPHOGYPSUM USE IN AGRICULTUREIN THE SOUTHEASTERN U.S.

Greg Traxler, Associate Professor

Auburn UniversityDepartment of Agricultural Economics and Rural Sociology

304 Comer HallAuburn University, AL 36849-5412

Prepared for

FLORIDA INSTITUTE OF PHOSPHATE RESEARCH1855 West Main Street

Bartow, Florida 33830

February 29, 1996

DISCLAIMER

The contents of this report are reproduced herein as receivedfrom the contractor.

The opinions, findings and conclusions expressed herein are notnecessarily those of the Florida Institute of Phosphate Research,nor does mention of company names or products constituteendorsement by the Florida Institute of Phosphate Research.

PERSPECTIVE

Phosphogypsum, like gypsum from any source, is an almost ideal agricultural source ofboth calcium and sulphur. In areas where phosphogypsum is available it has the advantage ofbeing the most economical of all types of gypsum for agricultural use.

Since it is slowly soluble, phosphogypsum remains available to the plant over longperiods. Unlike lime which makes the soil more alkaline, phosphogypsum is neutral in its soilreactions. As a calcium source, gypsum is the material of choice for peanut farmers and whileit is a small market, gypsum used to supply calcium to ferns raised for the floral market allowsthe soil to remain acidic for optimum growth. In other words gypsum is a hard to beat sourceof calcium in agriculture.

Agricultural literature is reporting ever increasing instances of soil sulfur deficiencies thatadversely affect crop yields. With increased emphasis on removing sulphur gases from the airand the use of high analysis fertilizers that contain little or no sulphur, the previous mostcommon methods of replenishing soil sulphur no longer exist.

In Florida one type of agriculture that could benefit dramatically from sulfur fertilizationis cattle ranching. In other parts of the world sulfur fertilization of pastures has resulted in asmuch as a 20% increase in weight gain for livestock. Phosphogypsum is about the onlyagricultural sulfur source that could be economical for pasture fertilization in Florida.

While the USEPA has banned the use of phosphogypsum in agriculture because it isslightly radioactive, all of the research in this area that we are aware of contradicts the USEPAassessment. We will continue to work towards having the USEPA revise their ruling bypresenting scientific facts that will allow Florida agriculture to achieve the significant economicbenefits that phosphogypsum can provide.

THE ECONOMIC BENEFIT OF PHOSPHOGYPSUM USE IN AGRICULTURE

IN THE SOUTHEASTERN U.S.

INTRODUCTION

Phosphogypsum is a solid waste byproduct of the wet phosphoric acid method of

processing phosphate rock. It is composed principally of calcium sulfate, but also

contains small amounts of quartz, phosphates, fluoride, radioactive minerals and

heavy minerals. Calcium and sulfur content usually exceed 23 and 18 percent,

respectively (Sumner, 1990).

The National Emission Standards for Hazardous Air Pollutants: National

Emissions Standards for Radon Emissions from Phosphogypsum Stacks of 1990

required that all phosphogypsum be disposed in stacks or mines because of its radium

content and the emission of radioactive radon gas. In 1992 the EPA issued a final

rule on National Emissions Standards for Radon Emissions from Phosphogypsum

Stacks which amended the standard to allow the distribution of phosphogypsum for

use in agriculture provided that the certified average concentration of radium-226 in

the phosphogypsum does not exceed 10 pCig-1. The ruling on the maximum

allowable radium content was based on an assumed 95th percentile application rate of

2,700 pounds per acre biennially for 100 years. The final rule also permits the

distribution of phosphogypsum for use in research and development in amounts not

exceeding 700 pounds per research activity.

1

Agriculture accounts for about 5 percent of the nearly 30 million tons of gypsum

used in the United States each year (Table 1). This report estimates the economic

benefit of removing restrictions on phosphogypsum use in agriculture in the

Southeast.

SIZE AND ORGANIZATION OF THE U.S. PHOSPHATE INDUSTRY

The United States is a major producer of phosphate rock, responsible for

approximately 30 percent of world production. Some 25 million short tons of

phosphate rock were traded on world markets in 1993. U.S. exports averaged nearly

5 million short tons from 1990-93 and are expected to increase as a result of NAFTA

and GATT trade agreements.

A total of 14 companies produced phosphate in the United States in 1993. About

85 % of the U.S. production, or 35 million tons, is accounted for by the six

companies located in central Florida and one in North Carolina. The U.S. also

imported approximately 850,000 tons annually during this period. The U.S. has no

duties or tariffs on fertilizer imports.

GYPSUM PRODUCTION

The U.S. is the world’s leading producer of gypsum. Oklahoma, Iowa, Texas,

Michigan, Nevada, California and Indiana are the largest producers of crude, or

2

mined, gypsum. Plaster, wallboard construction and cement production are the main

uses of gypsum in the United States. There are no operating gypsum mines in the

Southeast. Gypsum used in the Southeast is either byproduct gypsum or imported

mined gypsum. Byproduct gypsum accounts for about three percent of the gypsum

used in the U.S. Of the two major sources of byproduct gypsum, the desulfurization

of stack gas in thermal powerplants provides the largest share of byproduct gypsum.

The National Emissions Standards for hazardous air pollutants of the Clean Air

Act Amendments of 1990 restricts the use of phosphogypsum because of its radium

content and the emission of radioactive radon gas. The Act requires that

phosphogypsum be disposed of in stacks or in mined-out areas. In 1993 it was

estimated that the Florida phosphate industry had about 600 million tons of

phosphogypsum in existing stacks and that about 30 million tons of phosphogypsum

per year (an amount equal to total U.S. gypsum consumption) were being generated

(Llewellyn, 1993). Stacks must be lined with thick plastic sheet to prevent

groundwater contamination. In Florida the cost to build a 400 acre lined stack site in

1993 was estimated at more than $80 million (Llewellyn, p. 2). While

technologically possible to remove the harmful impurities from phosphogypsum, it is

not considered to be economically feasible (Llewellyn, p. 3).

Despite an overall rise in byproduct gypsum sales, phosphogypsum usage has

fallen by 50% since the 1990 EPA ruling limiting its use. An average of 207,000

tons of phosphogypsum were used in 1988-90, while the 1990-93 average is just

3

103,000 tons (Llewellyn). Over the same period, the share of phosphogypsum in

total byproduct sales fell from approximately 30 percent to 10 percent.

GYPSUM USE IN AGRICULTURE

A total of nearly 1.5 million tons of gypsum, including mined gypsum and

byproduct gypsum, were used in agriculture in 1994 (Table 1). Agricultural use

accounts for about 5 percent of the total of nearly 30 million tons of gypsum used in

the United States; construction uses account for 90 percent of total use. To be used

in agriculture, crude gypsum must be pulverized and screened to 100 mesh or finer

after mining. For wallboard production, the screened gypsum must then be further

treated by a calcining process. Agronomists have been unable to detect differences

between the agronomic effects of phosphogypsum and mined gypsum (Mullins and

Mitchell, Sumner).

The uses of gypsum in agriculture fall into three main categories (Sumner): 1) as

a source of calcium for peanut production 2) as a source of sulfur for vegetable crops

and forages 3) as an ameliorant for soil sodicity, crusting and subsoil acidity

problems. Sumner summarizes experimental evidence which examine the potential

for sulfur to increase the yield of several southeastern crops. At present little sulfur,

only 8,000 tons in 1994, is used in agriculture in the region (TVA). The use of

gypsum to reclaim sodic soils occurs primarily in irrigated agriculture, especially in

California, but occurs very rarely in the Southeast. By far the most commercially

important use of gypsum in the Southeast at present is as a source of calcium for

peanut production.

An average of 1.29 million acres of peanuts are planted in the six southern states

of Alabama, Florida, Georgia, North Carolina, South Carolina, and Virginia. The

Southeast’s “peanut belt” is centered about 150-200 miles from Florida’s main

phosphorus mining areas. About 80 percent of U.S. peanut production takes place

within a 100 mile arc around the juncture of the Georgia, Florida and Alabama

borders (Table 2). Georgia accounts for more than half of the U.S. peanut area.

The value of gypsum as a source of Ca for peanut production has been

recognized since the 1940’s (Sumner). Among Southeastern states, recommended

application rates range from 250 lb ac-1 to 860 lb ac-1 for banded application and from

688 lb ac-1 to 1720 lb ac-1 for broadcast application (Sumner).

An average of 198,626 short tons of gypsum are used in agriculture in Georgia,

Florida and Alabama each year (Table 3). Virtually all of this gypsum use is for

peanut production.

An important assumption of the EPA final rule on National Emissions Standards

for Radon Emissions from Phosphogypsum Stacks was the estimate of 1350 lb/ac as

the 95th percentile annual average application rate for phosphogypsum. Evidence that

the application rate used by Georgia peanut farmers is significantly less that this is

provided by survey information collected by the USDA national peanut research

laboratory in Dawson, Georgia. Data on input use levels were collected from a

random sample of 84 peanut farmers in 1991, 1992 and 1993 (Lamb). The sample

5

was selected to be statistically representative of all peanut farmers in Georgia. Forty-

six percent of surveyed farmers applied gypsum. The average application rate over

the entire sample was 402 lb/ac. Of farmers using gypsum, the average application

rate was 879 lb/ac. The 95th percentile application rate was 1,000 lb/ac (Figure 1).

The average gypsum expenditure was $17.44 per season, and the average farm price

was $40.00/ton.

The majority of farmers rotate peanuts with another crop to which they do not

apply gypsum in either a two or three year rotation. This suggests that most fields

receive gypsum on either one out of two or one out of three years, so that the long

run average application gypsum use rate on any given field is one half to one third of

those shown in Figure 1. This would place the survey long run average application

rate at 500 lbs/ac, which is less than 40% of the EPA assumed 95th percentile

application rate. Even the 99th percentile implied average application rate of 750

lb/ac is barely 50% of the EPA assumed 95th percentile.

A similar survey of input use among 30 peanut farmers in Alabama was

conducted by agricultural economists at Auburn University during the 1995 growing

season. Gypsum use among Alabama producers was much lower than among Georgia

producers (Figure 2). Only two producers, 7% of the sample, applied gypsum. The

highest application rate was 1,000 lb/ac, or an implied 500 lb/ac based on a two year

peanut rotation.

6

BENEFIT CALCULATIONS

Welfare analysis will be used in this section to estimate the total benefit from

removing restrictions on the use of phosphogypsum in agriculture. This section

provides a brief background on the economic surplus concepts that are used by

economists for applied welfare analysis. The parameters of the economic surplus

model and the benefit estimates are then presented.

The net economic benefit from allowing unrestricted use of phosphogypsum in

agriculture in Georgia, Florida and Alabama was calculated within the framework of

economic welfare analysis. Welfare analysis, which is a form of benefit/cost

analysis, is the most common method used by economists to quantify the costs and

benefits of changes in government policies. Just, Hueth and Schmitz and Alston,

Norton and Pardey summarize the economic welfare literature which has been

developed since welfare analysis was first used by Ricardo in the early nineteenth

century. Welfare analysis is a tool that is relatively easy to understand and apply as

well as being theoretically justified.

Welfare changes can be decomposed into changes in consumer and producer

surplus. Consumer surplus is the difference between the price a consumer pays for a

product and the price that he or she would be willing to pay. Consumer surplus can

be graphically represented as the area above the price line and below the demand

curve (triangle A in figure 3). The demand curve is called a derived demand curve

when the good being considered is an input such as gypsum which is an input into the

7

production of another commodity, This derived demand curve maps the marginal

value product of the input. The size of consumer surplus depends on the elasticity, or

slope, of the demand curve.

Producer surplus is the area below the price line and above the supply curve

(triangle B in figure 3). When product markets are competitive the supply curve for

the individual firm is the marginal cost curve. If inputs are available in perfectly

elastic supply, the industry supply curve is the sum of the marginal cost curves of

individual firms. Under the common economic conditions of competitive markets and

mobility of factors of production, the marginal cost curve reflects the opportunity cost

of resources. Producers’ surplus is affected by the elasticity of supply. In the special

case of perfectly elastic supply, which characterizes gypsum, no producers’ surplus is

generated.

Agricultural use has a negligible effect on the price of gypsum because the

amount of gypsum used in agriculture is very small both in relation to total gypsum

use (one percent or less), and in relation to the production of phosphogypsum. Each

year the Florida phosphate industry adds some 30 million tons of phosphogypsum to

the existing 600 million ton inventory (Llewellyn). The annual increment to

phosphogypsum stockpiles is 150 times the current total agricultural gypsum use in

the Southeast.

Removing the restriction on phosphogypsum sales would have the effect of

inducing a downward shift of the gypsum supply curve facing producers in the

Southeast (Figure 4). Geometrically, the welfare effect of the shift in supply is seen

8

as the sum of rectangle B and triangle C. These areas have straightforward intuitive

interpretations. Area B is simply the quantity of gypsum used multiplied by the

difference in price between mined gypsum and phosphogypsum. Area C represents

additional surplus due to the fact that more gypsum will be demanded as the price

falls. The size of the increase in the quantity demanded depends on the magnitude of

the demand elasticity. This “surplus triangle” is generally quite small. Note that, as

modeled, this surplus accrues entirely to gypsum consumers, i.e., agricultural

producers. Because supply is perfectly elastic, there is no producer surplus.

The formula for calculating the welfare change, or net benefit, is:

(1) Change in welfare = QJP + OSAPAQ

where Q, is current level of gypsum use, AP is the change in price of gypsum with

phosphogypsum restrictions removed, and TQ is the change in gypsum consumption

as the price falls. The ?Q is based on an assumed elasticity of demand for gypsum

of -0.2. The first term in (1) is simply the price change times the current quantity of

gypsum used and is equal to area B in figure 5. The second term accounts for the

small increase in gypsum use which will occur as the price falls (area C in figure 5).

Equation (1) is the annual benefit of the fall in the price of gypsum. Since this is

expected to be a permanent price reduction, the total financial benefit is the net

present value (NPV), which is the discounted sum of the annual benefit amounts for

all future years.

9

The Tennessee Valley Authority (TVA) reports average annual gypsum use

quantities for 1985-94 of 155,200 short tons in Georgia, 43,284 in Florida and 158

tons in Alabama. No published studies have estimated the elasticity of demand for

gypsum, but several reported elasticity estimates for phosphorus and nitrogen are

reported (Larson and Vroomen, Roberts). A value of q =-0.2 was used in this study.

Some uncertainty exists about the equilibrium gypsum price when

phosphogypsum restrictions are removed. Conservative estimates of the new gypsum

price were used in the benefit calculations. Phosphogypsum can currently be

purchased F.O.B. White Springs, Florida for $10.00/ton. White Springs is

approximately 100 miles from the center of Georgia peanut production, and about the

same distance from central Florida phosphate production. It is assumed that with the

entry of new phosphogypsum suppliers in central Florida, northern Florida suppliers

will be forced to reduce their price to meet this competition. Because of the cost of

adding to existing phosphogypsum stockpiles, it is assumed that central Florida

suppliers will be willing to supply phosphogypsum at a zero price F.O.B. central

Florida. The delivered farm price will then be determined by the transportation price

of $7.00/ton/l00 miles. Because White Springs is approximately 100 miles nearer

than other suppliers to the peanut growing areas, it, will not be forced to supply

phosphogypsum at a zero price, but rather will need to meet the effective north

Florida price of other phosphogypsum suppliers of $7.00 (i.e. the cost of

transportation from central Florida to White Springs). The result is that the delivered

10

gypsum price to Georgia, Alabama and north Florida peanut growing areas can be

expected to fall by a minimum of $3.00/ton.

There is a second economic benefit to society of the use of phosphogypsum in

agriculture. This is the cost saving that results from not adding any phosphogypsum

used in agriculture to existing stockpiles. This economic benefit accrues to

phosphorus producers. The estimated average cost per ton of constructing a

50,000,000 ton stack with a 10 year life is estimated at $49,000,000 (Rubin). This

cost includes neither capitalized interest expense, nor annual direct costs of handling

phosphogypsum. Kendron estimates per ton costs of stacking phosphogypsum at

$1.50 to $2.00. The $1.50 per ton cost will be used in this study.

The annual net benefit accruing to agricultural producers is estimated to be nearly

$$609,284 if prices fall by $3/ton. The reduced storage cost for the industry would

be $297,938, for a total economic benefit of nearly $900,000. The net present value

of this annual benefit flow is $17,606,768 using a 3% real discount rate. Because of

the uncertainty involved with predicting this future gypsum price, benefit calculations

were done using price assumptions ranging from a price reduction of $1.00/ton up to

a $10/ton reduction (Table 4).

SUMMARY

Economic welfare analysis was used in this study to estimate the benefit of

unrestricted use of phosphogypsum in agriculture in the states of Georgia, Florida and

11

Alabama. An average of nearly 200,000 tons of gypsum are used in agriculture in

these three states each year, primarily as a source of calcium for peanut production.

The most important information presented is the survey data on gypsum

application rates in Southeastern agriculture. Forty-six percent of peanut producers

in Georgia apply gypsum. Of farmers using gypsum, the average application rate is

879 lb/ac. Assuming a two year peanut rotation, the implied 99th percentile

application rate in Georgia is 750 lb/ac. Only seven percent of Alabama farmers

surveyed applied gypsum, with the highest observed application rate being 500 lb/ac,

assuming two-year peanut rotation.

Using an assumed $3.00 per ton fall in the price of gypsum if central Florida

phosphogypsum were to enter the market, the total annual net benefit from removing

the restriction on gypsum use in agriculture is estimated to be nearly $900,000. Of

the total annual net benefit approximately $600,000 would be passed on to agricultural

producers through lower prices, while reduced storage cost for the industry would be

nearly $300,000. The net present value of this annual benefit flow is $17,606,768.

12

REFERENCES

Alston, J.M., G.W. Norton, and P.G. Pardey. 1995. Science under Scarcity:

Principles and practices for agricultural research evaluation and priority setting.

Cornell University Press, Ithaca, NY.

Davis, L.L. 1993. Gypsum. in Minerals yearbook. U.S. Bureau of Mines, Dept. of

the Interior.

Just, R.E., D.L. Hueth, and A. Schmitz. 1982. Applied welfare economics and public

policy. Prentice Hall, Englewood Cliffs, NJ.

Kendron, T.J. Sulfur Recovery from Phosphogypsum. Paper presented at the Florida

Institute of Phosphate Research Forum, Tallahassee, Florida, December 7,1995.

Lamb, M. 1995. Economic Analysis of Planning, Management and Marketing Peanuts

in the Southeast U.S. Unpublished Ph.D. dissertation, Auburn University.

Larson, B.A. and H. Vroomen. 1991. Nitrogen, phosphorus, and land demands at the

U.S. regional level: A primal approach. Journal of Agricultural Economics.

42:354-64.

Llewellyn, T.O. 1993. Phosphate rock. Minerals Yearbook. U.S. Bureau of Mines,

Dept. of the Interior.

Mullins, G.L. and C.C. Mitchell. 1990. Use of phosphogypsum to increase yield and

quality of annual forages. Publication No. 01-048-084 of Florida Institute of

Phosphate Research, Bartow Florida.

Roberts, R.K. 1986. Plant nutrient demand functions for Tennessee with prices of

jointly applied nutrients. Southern J. Agric. Econ. 18: 107-112.

13

Rubin,G.J. Phosphogypsum Handling. Paper presented at the Florida Institute of

Phosphate Research phosphogypsum Fact-Finding Forum, Tallahassee, Florida,

December 7, 1995.

Sumner, M.E. 1995. Use of calcium and sulfur as nutrients for crops in florida:

Reconciliation of literature review with EPA’s final rule on phosphogypsum.

Draft report prepared for Florida Institute of Phosphate Research.

Sumner, M.E. 1990. Gypsum as an ameliorant for the subsoil acidity syndrome.

Publication No. 01-024-090 of Florida Institute of Phosphate Research, Bartow

Florida.

Tennessee Valley Authority. Various years. Commercial fertilizers. TVA, Muscle

Shoals, AL.

14

Table 1. Gypsum use: Total, byproduct, and phosphogypsum, U.S. and Southeast

(Georgia, Florida and Alabama), 1989-93

Tot. use, U.S.*

Tot. use ag., U.S.’

Ag. share tot. U.S.

S.E. ag. use*

S.E. ag. share tot.,U.S.

Byproduct sales, U.S.*

Phosphogypsum sales, U.S.*

Byproduct share tot. gypsum

Phosphogypsum share tot.

gYPsum

1989 1990 1991 1992 1993

27,068

1,172

4.3%

204

0.8%

725

174

2.7%

25,691

1,381

5.4%

248

1.0%

667

207

2.6%

21,859

1,560

7.1%

220

1.0%

618

136

2.8%

27,113

1,193

4.4%

159

0.6%

694

69

2.6%

0.6% 0.8% 0.6% 0.3% 0.3%

29,460

1,350

4.6%

215

0.7%

933

103

3.2%

* Thousands of short tons

Sources: Llewellyn; Tennessee Valley Authority

15

Table 2. Peanut area planted in Georgia, Florida, and Alabama, 1985-94

YiZU Georgia Florida Alabama Total

1985 595 80 201 876

1986 670 93 220 983

1987 630 91 221 942

1988 690 98 237 1,025

1989 690 95 240 1,025

1990 782 102 258 1,142

1991 900 126 278 1,304

1992 675 237 Loo(--)

1993 240 1,032

1994

Avg 1985-94

700

640

697

88

92

75

94

220

235

935

1,026

1,000 acres

Source: USDA

16

Table 3. Gypsum use in agriculture in Georgia, Florida, and Alabama, 1985-94

YCXU Georgia Florida Alabama Total S.E.

1985

1986

1987

1988

1989

1990

1991

1992

1993

1994

Avg 1985-94

185,604

125,924

154,079

187,837

176,007

206,135

184,610

105,879

141,140

84,784

155,200

Short tons

31,378

53,932

31,793

31,342

27,101

42,111

35,627

53,311

74,175

52,068

43,284

0

0

19

15

477

nr

146

299

134

329

142

216,982

179,856

185,891

219,194

203,585

248,246

220,383

159,489

215,449

137,181

198,626

nr = not reported

Source: Tennessee Valley Authority

17

Table 4. Annual economic benefit and present value of benefit under wrious

assumed changes in price agricultural gypsum

Change in

price

Annual Annual

agricultural stacking

benefit cost saved

Total

present

value

$1.00 $199,122 $297,938 $9,742,606

$2.00 399,237 297,938 13,664,954

$3.00 600,346 297,938 17,606,768

$4.00 802,447 297,938 21,568,048

$5.00 1,005,542 297,938 25,548,793

$6.00 1,209,630 297,938 29,549,004

$7.00 1,414,711 297,938 33,568,681

$8.00 1,620,785 297,938 37,607,823

$9.00 1,827,852 297,938 41,666,432

$10.00 2,035,912 297,938 45,744,506

18

Figure 1. Distribution of gypsum application rates among Georgia peanut farmers

60%

50%

2 40% s

3 ; 30%

2 s ii! 20%

10%

500 550 600 650 700 800 827

Gypsum Application Rate (lb/ad

Price

P

Figure 3. Consumer and producer surplus

SUPPlY

Demand

Q Quantity

21

Figure 4. Change in economic surplus from a shift in supply

Price

P

P’

Supply before policy change

\ Demand

I

I

I

I

Q

1

I

I

I

Q’ Quantity

22

Figure 5. Shift in supply of gypsum

Price

P’

P I

I

I I

I .

I .

I I

:

. I

:

I

I

I I

I I

: :

I .

. I :

I I

I I

.

. :

I I :

I .

I m

I .

I I

I I

I I

I I

:

Present Supply of Gypsum

Supply of Phosphogypsum

Agricultural Demand for Gypsum

\

Q’ Q Quantity

23

Fluorine Recovery http://www.waterwatchofutah.com/reservoirs.htm

Phosphorous & Potassium, September/October 1979 No. 103, pp. 33-39 Fluorine recovery in the fertilizer industry - a review.

by H.F.J. Denzinger, H.J. Konig and G.E.W. Kruger

The fluorine compounds liberated during the acidula tion of phosphate rock in the manufacture of phosphoric acid and fertilizers are now rightly reg arded as a menace, and the industry is now obliged to suppress emissions of fluorine-containin g vapours to within very low limits in most parts of the world.

As with any pollution control operation, it is high ly desirable for the operator of the fluorine scrubbing operation to find a use or market for the recovered fluorine to help defray at least partial ly the cost of the operation.

This article reviews the chemical and technical pri nciples of gaseous fluorine compound removal, the principal types of practical fluorine recovery processes that have been developed and their limitations, and possible methods of utilizing the fluosilicic acid solution which these processes generate.

Most phosphate rocks mined today contain an average of 3-4% fluorine. When they are processed to phosphoric acid (the basic material from which a va riety of fertilizers are manufactured) fluorine compounds appear at various process stages. For the purposes of this review the volatile fluorine compounds HF and SiF4 are of prime interest, as the y can be separated relatively easily from the reaction vapours during the acidulation or concentr ation by scrubbing with water or dilute fluosilicic acid. Many authors have dealt with the processes fo r and problems of fluorine recovery from wet-phosphoric acid in the last decade. Besides a few r eview articles, (67-75) the publications refer to separation techniques for fluorine compounds, e.g. precipitation, (1-16) solvent extraction, (27-35) ion exchange (35-40) and volatilization. (41-66).

In the past, little attention was paid to the emiss ion of gaseous fluorine compounds in the fertilizer industry. But today fluorine recovery is increasing ly necessary because of stringent environmental restrictions which demand drastic reductions in the quantities of volatile and toxic fluorine compounds emitted into the waste gases. These compo unds now have to be recovered and converted into harmless by-products for disposal or , more desirably, into marketable products. At the same time, the expected depletion of natural fl uorspar reserves, the main source of fluorine compounds, within the next 2-3 decades increases th e importance of fluorine recovery from phosphate rock. As phosphate rock reserves are guar anteed until the end of the next century (78) silicon tetrafluoride or fluosilicic acid might wel l become the most important source of fluorine for the chemical industry.

Only part of the fluorine contained in phosphate ro ck is economically recoverable with today's technology. In the course of wet-process phosphoric acid production by sulphuric acid attack (dihydrate and hemihydrate processes) 45-60% of the fluorine is released in gaseous, recoverable compounds, 30-45% of the fluorine precipitates in t he gypsum in solid compounds while 5-10% remains as an impurity in the acid. During single o r triple superphosphate production, the portion of volatile compounds diminishes to about 10-25%.

Fluosilicic acid recovered by scrubbing these volat ile compounds could in future become the primary raw material for chemicals such as aluminum fluoride and cryolite - auxiliaries indispensable in Hall-process aluminum smelting - o r hydrofluoric acid and others which, until now, are normally produced from natural fluorspar. Even synthetic fluorspar can be obtained for use as flux in steel making.

Fluorine recovery

During the production of phosphoric acid from fluor apatite (3Ca3(PO4)2CaF2) and a strong mineral acid, the calcium fluoride present in the rock is c onverted, by reaction with the silica also present, into fluosilicic acid according to the following eq uations:

CaF2 + 2H+ (H2SO4, HNO3, H2PO4, HCl) > (1) 2HF + Ca++ (2) 4HF + SiO2 > SiF4 + 2H20 (3) 3SiF4 + 2H2O > 2H2SiF6 + SiO2

The hydrogen fluoride and silicon tetrafluoride are partly evolved directly as vapours and partly form fluosilicic acid which, under the influence of heat , decomposes again into volatile SiF4 and HF, leaving the reaction vessel together with the water vapour.

As the heat of the reaction evolved in the attack s tage is much less than that required for evaporation, the major portion of the volatile fluo rine compounds is obtained during subsequent concentration of the phosphoric acid.

In the production of single and triple superphospha te or weak (28-32%) phosphoric acid, silicon tetrafluoride is preferentially volatilized because under the conditions prevailing its vapour pressur e is higher than that of hydrogen fluoride. As the ph osphoric acid is concentrated up to 54% P2O5, more and more hydrogen fluoride escapes. The molar ratio HF:SiF4 in the vapours increases sharply with the concentration of the phosphoric acid and s urpasses 2 when the acid concentration is 50% P2O5 or more. At molar ratios below 2, reaction (3) will take place when the vapours are scrubbed, and surplus silica will be precipitated in the scru bber liquor, an effect that has to be considered when designing equipment for fluorine recovery.

There are two distinct basic types of process in us e:

- fluorine recovery under atmospheric pressure (as used in single and triple superphosphate and weak phosphoric acid production)

- fluorine recovery under vacuum (used in the conce ntration of phosphoric acid from 30%-50% P2O5 and in evaporative cooling of reaction slurry durin g phosphoric acid production)

Typical descriptions of the two process types are g iven below. The second is of greater importance, as it represents the larger recoverable fluorine so urce.

Fluorine recovery at atmospheric pressure

The gases (mainly silicon tetrafluoride) extracted from the reaction vessel are fed to a venturi scrubber in which the silicon tetrafluoride is abso rbed, forming fluosilicic acid and silica (Fig. 1). The scrubbing liquid is dilute, circulating fluosilicic acid. To increase scrubbing efficiency (up to 99%) two or more units are placed in line. Dust can be e liminated first, if necessary, in a special scrubbe r. Precipitated silica must be removed from the produc t, for example by filtration. The concentration of the formed fluosilicic acid depends on the use to w hich it is to be put; normally it is maintained at between 18 and 25%. The higher the concentration of the acid, the lower the washing efficiency.

Fluorine recovery under vacuum

The superheated vapours from the flash vessel of th e phosphoric acid concentration plant first pass through a high-efficiency entrainment separator. Th is is essential to reduce the P2O5 contamination of the vapours, and thus the product, to a minimum; this is particularly important if the product fluosilicic acid is to meet the purity specificatio ns demanded for certain of its uses. The collected mixture of dilute phosphoric and fluosilicic acid i s sent back to the concentration unit and thus does not represent a loss of either fluorine or P2O5. Th e cleaned vapours are then fed to a fluorine scrubber, where the silicon tetrafluoride and hydro gen fluoride they contain are absorbed using circulating fluosilicic acid as the scrubbing liquo r. Fluosilicic acid (18%-25%) is withdrawn continuously under density control and the correspo nding amount of water is introduced into the

system. (Fig 2) For economic reasons, it is desirab le to achieve the required fluorine recovery with one scrubber stage only. However, this depends on v arious factors which need to be carefully investigated before the final decision is made.

Whereas the attainable fluorine recovery largely de pends on the fluorine content of the incoming vapour as well as the concentration and the tempera ture of the fluosilicic acid produced, the P2O5 content of the fluosilicic acid is mainly dependent on the P2O5:F ratio in the vapours from the flash vessel and on the efficiency of the P2O5 separator. Figure 3 shows the fluorine recovery efficiency versus the fluorine content of the vapours for a si ngle-stage scrubbing unit for different concentrations of circulated fluosilicic acid. From this it is quite clear that a high fluorine recove ry cannot be achieved with a single-stage unit when a high fluosilicic acid concentration is required and at the same time the fluorine content of the va pours is low. In that case, a second scrubbed stage would be necessary.

Figure 4 shows the P2O5 contamination of the fluosi licic acid in relation to the P2O5 content of the vapour, expressed as the P2O5:F ratio for different fluosilicic acid concentrations, based on a constant fluorine level in the vapours and a given efficiency of the P2O5 separator of 98%. The P2O5 impurities of a 25% fluosilicic acid in this case a re almost twice as high as for an 18% fluosilicic acid.

Figure 5 is similar to Fig 4 but it indicates the i nfluence of the fluorine content of the vapours for a given H2SiF6 concentration.

From this it follows that, for an existing installa tion, neither the efficiency of the fluorine absorp tion unit nor the P2O5 content of the fluosilicic acid i s constant. They depend rather on the type of phosphate rock processed as well as on the actual o perating conditions of the phosphoric acid and concentration plant.

Direct uses of fluosilicic acid

Fluosilicic acid has only limited applications for direct use but it can be used advantageously as a raw material for the production of, for example, al uminum fluoride and cryolite; this will be describe d later. Its direct use is restricted because of its low concentration and the relatively high amount of impurities, as shown below for a typical acid compo sition:

H2SiF6 18-25% P2O5 100 ppm Fe2O3 70 ppm SO4 1,000 ppm Cl 1,000 ppm

The main characteristics of fluosilicic acid are it s bactericidal and fungicidal effects, because of which there is some direct use as a sterilizing and impregnating agent in breweries and for wood protection. Today, some attempts have been made, ma inly in the United States, to fluoridate drinking water with up to 1 ppm F using fluosilicic acid or its salts. (80)

Pure silicon tetrafluoride is not isolated on an in dustrial scale because of the great expense of doin g so. Only one process is described in the literature (the Ochrate process) for direct uses of SiF4 in which dry concrete is treated with SiF4 gas to impr ove stability and abrasion strength. (81)

Disposal as a waste

The strong and poisonous fluosilicic acid has to be converted into inert and harmless waste products if no suitable application exists. Small p lants, especially, are often confronted with the problem on economic grounds. They prefer to neutral ize the acid, for example with limestone or milk of lime, to precipitate the acid as a mixture of ca lcium fluoride and silica.

The precipitated solids are filtered off and remove d as a waste product, sometimes together with gypsum from the phosphoric acid plant. The neutrali zation has to be closely controlled to avoid problems in settling and filtration. However, it is difficult to achieve complete neutralization, and therefore small amounts of poisonous fluorine compo unds are still found in the effluent.

Use in the production of fluorine compounds

There are various ways of using fluosilicic acid as a raw material to produce essential fluorine-containing materials on an industrial scale.

Aluminum fluoride

Aluminum fluoride and cryolite are used to reduce t he melting point of alumina (forming an eutectic mixture) in electrolysis plants producing aluminum metal. Normally about 20-30 kg aluminum fluoride and about the same amount of cryolite are consumed per tonne of aluminum, depending on the specific process conditions. The P2O5 content o f these flux materials should be as low as possible in order to minimize losses of electrical energy.(125)

The classical route for producing this indispensabl e auxiliary of the aluminum industry is from hydrogen fluoride and aluminum hydroxide; the moder n processes using fluosilicic acid (82-117) are divided into the acid and the ammonia process. The acid process, especially the one developed by Chemie Linz, (118-121) is of greater significance, having been in industrial use since 1962. According to this process the required quantities o f aqueous fluosilicic acid and aluminum hydroxide are mixed in a reaction vessel. At the bo iling point and by careful control of distinct process conditions, the following reaction takes pl ace:

H2SiF6 + 2Al(OH)3 + 2H2O > 2(AlF3 3H2O) + SiO2

The trihydrate crystallizes very slowly and therefo re the precipitated silica is separated first from the quasi "metastable" solution. The filtrate is then d ischarged to a batch crystallizer, where the precipitation of the trihydrate is completed within several hours with the aid of some seed crystals. The separated trihydrate is converted into pure AlF 3 (97%) by calcination at 550 C.

A variant of this process has been developed by Der ivados del Fluor, (122) while Bayer (123) proposed that the reaction should be carried out at elevated temperature and pressure to form a water-depleted product, AlF3 H2O directly.

The ammonia treatment of fluosilicic acid results i n a solution of ammonium fluoride in the first step , which after separation of the silica, is converted first to ammonium cryolite by addition of partly calcined aluminum hydroxide and subsequently into p ure AlF3 (Mekog-Albatros process). (124)

The ammonia is recycled.

Cryolite

There are no significant differences between the va rious processes for manufacturing cryolite. (126-147) IG-Farben was the first to develop a process i n its factory at Oppau in 1940. It was based on neutralization with ammonia and treatment with sodi um aluminates.

This fundamental process was modified in many ways, for example to improve filtration of silica (148) or to minimize the impurities in the cryolite . (149)

According to a suggestion of VEB Stickstoffwer Pies teritz, (150) ammonium fluoride, formed by the neutralization of fluosilicic acid with ammonia, ca n be converted into to cryolite by reaction with sodium hydroxide and then aluminum fluoride.

Chemie Linz has developed a process to neutralize f luosilicic acid in different reaction vessels with aluminum hydroxide and soda ash, forming aluminum f luoride and sodium fluoride solutions, which after separation of the precipitated silica, react to give cryolite.

Instead of soda ash, caustic soda can be used.

Other routes use fluosilicates as an intermediate p roduct, for example, the process of Kaiser Aluminum, (151) Montedison, (152) and Onoda. (153) The Kaiser Aluminum process has been used in the United States for more than ten years. Howev er, a major disadvantage of this process is the dilute hydrochloric acid by-product.

Hydrofluoric acid

To produce hydrofluoric acid from fluosilicic acid, a number of processes have been developed, (154-174) but none has so far been used industriall y. According to their principles, five groups of processes can be distinguished.

a) Fluosilicic acid is decomposed, by the action of concentrated sulphuric acid, into the gaseous components of hydrofluoric acid and silicon tetrafl uoride. Hydrofluoric acid is separated from the sulphuric acid solution by means of distillation. P rocesses of this kind have been developed both in the U.S.S.R. (175) and by the Tennessee Corp. (178)

b) Another suggestion (179) refers to the thermal d ecomposition of fluosilicic acid. Because of its higher vapour pressure, silicon tetrafluoride is ev aporated preferentially and the water solution is enriched with hydrofluoric acid, which is purified afterwards by distillation.

c) Ammonium fluoride solution, prepared from fluosi licic acid and ammonia, is converted into ammonium hydrogen fluoride by means of evaporation. This component reacts with sulphuric acid forming hydrofluoric acid.

d) A quite different separation principle comprises using the better solubility of hydrofluoric acid i n organic solvents (for example polyether) during the evaporation of fluosilicic acid. (181)

e) Synthetic fluorspar made from fluosilicic acid m ay be used in place of the natural mineral in sulphuric acid attack.

Fluorspar

As for hydrofluoric acid, much research work has be en done to develop processes for the production of synthetic fluorspar from fluosilicic acid, although no industrial-scale application has been described to date. The number of publications increased in the last years as a result of the expected shortage of natural fluorspar reserves, an d the promising perspectives for the use of a mixture of calcium fluoride and silica as a fluorsp ar substitute in steelmaking. (182) Finally, pure synthetic fluorspar can be used as a raw material f or producing hydrofluoric acid, the basic compound of the fluorine industry. Unfortunately, t his process route is not yet economic.

The neutralization of fluosilicic acid with limesto ne or milk of lime is the main principle of fluorsp ar production. (182-187) Normally, the calcium fluorid e and silica are precipitated together but, under certain process conditions, silica remains metastab le in the solution. Alternatively, silica can be precipitated first by using the reaction between fl uosilicic acid and ammonia to form ammonium fluoride, which is afterwards converted into calciu m fluoride.

Fluosilicates

These components can easily be produced by treating fluosilicic acid with salts like calcium chloride and potassium chloride because of their low solubil ity in water.

Though their direct use is limited to some applicat ions in disinfectants, fluosilicates can serve as raw material for the production of other fluorine c ompounds, as has been described.

Prospects for fluorine recovery

More than 100 million tonnes of phosphate ore are c onsumed annually, from which approximately 1.2 million tonnes of fluorine could be recovered a nd converted into essential fluorine compounds. (198) The future development of fluorine recovery c an be considered optimistically because of the increasing environmental responsibility and positiv e perspectives in aluminum production. (199-201) Nevertheless, fluorine recovery and recycling in th e aluminum industry itself have to be taken into account, which reduce the specific fluorine consump tion. (202) However, as this applies mainly to the recovery of fluorine in the form of cryolite it is very likely that the specific consumption ratio of cryolite to aluminum fluoride will change in favor of aluminum fluoride.

Note: This online version of this article does not contain the lengthy list of references, nor the diagrams and all of the chemical equations that are contained in the original.

Vol. 28 BOOKS AND REPORTS 1007

chology and the 60 other extensive quo-tations from case histories of behaviorproblems and their treatment, it wouldbe described as a well organized andcarefully documented reference book.The author's clear interpretation of hismaterial and the practical applicationsof it give it added value as a " textbookfor students of clinical psychology."

Its contents may be briefly indicated:Part I-Methods, includes an introductory

chapter and two chapters on DiagnosticMethods, devoted to Anamnesis and Ex-amination and to Psychometrics, respectively.

Part II-Problems Correlated with Abili-ties, deals with the following topics, to eachof which a chapter is given: Mental De-ficiency or Feeble-Mindedness; School Re-tardation; Specific Disabilities in School Sub-jects; and Superiority.

Part III-Primary Behavior Problems, con-tains 6 chapters covering the following sub-jects: Behavior Problems: Introduction;Conduct Problems; Juvenile Delinquency;Speech Defects; Personality Problems; Psy-choneuroses and Psychoses.

Part IV-Problems Correlated with OrganicDisabilities is divided into two chapters, thefirst dealing with Sensory Defects and thesecond with Neurological and Physical Disa-bilities.

A list of references and a good indexcomplete the volume.

In a foreword L. T. Meiks, M.D.,emphasizes the unique opportunities ofthe family physician and the pedia-trician for observation and intimateknowledge of the family background ofchildren under their care and the recog-nition "of many of these behavior dis-orders in their incipience, before theuntrained associates of the child realizethat the reactions are in any way un-desirable. An enlightened medicalprofession," he says, " can do much toprevent the development of these dis-orders and to handle them in the properfashion once they have appeared."Both Dr. Meiks and the author recog-nize the need for the specialized technicsof the trained psychiatrist and clinicalpsychologist in solving many behaviorproblems. Running throughout the book

is the refrain, " Treat the child as anintegrated whole."The book should serve its purpose

well, whether its reader be the embryopsychoclinician, to whom it is ad-dressed, the medical student, or thephysician or school administrator seek-ing to keep abreast of the most recentwork in the field of clinical psychology.

FREDERICK W. BROWN

More of My Life-By AndreaMajocchi. New York: Knight Pub-lishers, 1938. 313 pp. Price, $2.50.

All who read Life and Death willwelcome this addition to the auto-biography of Italy's famous surgeon.The author speaks of these new storiesas "Pages from my life . . ." "notestorn from -a surgeon's diary," yet theyhave, as he says, a definite relationshipto one another although apparentlylittle connected. To a certain extentit is a biographical sketch of a greatfriend and senior surgeon, Dr. FrancoForti.

Biographies, even of the humblestpeople, if they are sincere, carry muchof interest. When we have the storyof a man who has come into contactwith life in so many varied forms asthe author of this book, it cannot butbe of intense interest. Some of thechapters have been dedicated. to threepersons, an unknown patient, a nun,and a priest, who had been deeplymoved by reading Life and Death. Wehave no hesitation in picking out thesechapters as easily the best in the book,The Sacrifice, The Hymn to the Sun,Mass at the Front, and Sunset. Tothese we would add, Human Depths.

It seems to have become the fashionfor doctors to write autobiographies.Among those which have appeared, thisstands easily among those at the top.It is the story of a man who has workedhard, studied both books and men, hasloved his kind and devoted his life totheir betterment. Above all, -it is simple

1008 AMERICAN JOURNAL OF PUBLIC HEALTH Aug., 1938

and sincere. It can be recommendedwithout reservation.The book is beautifully printed and

gotten up. It is a pity that the trans-lator did not consult a doctor, whichwould have avoided several errors whichjar on the professional man.

MAZYCK P. RAVENEL

Step by Step in Sex Education-By Edith Hale Swift, M.D. NewYork: Macmillan, 1938. 207 pp. Price,$2.00.

This is a unique presentation ofsex education material arranged indialogue form between parents anda boy and girl in the normal relationsof family life. It proceeds step bystep as the children advance in age togive them a scientific nomenclature ofsex anatomy and physiology, at thesame time revealing to each child thepersonal and social implications of sex.It is written primarily for parents whoare at a loss to know how to approachthe subject when confronted by thecuriosity and perplexing questionswhich modern children present. It isclothed in everyday conversationalstyle and is clear and concise withouta trace of morbidity, although theauthor does not stop at introducing themost intimate situations in sex relations.The only part of the book which mightarouse controversy is that dealing withcontraception, which is confined to afew pages at the end.

RICHARD A. BOLT

Fluorine Intoxication-A Clinical-Hygienic Study, with a review of theliterature and some experimental in-vestigation-By Kaj Roholm. Copen-hagen: Nyt Nordisk Forlag-London:H. K. Lewis and Co. Ltd., 1937.364 pp.

In a succinct review, it is impossibleto do adequate justice to what is prob-ably the outstanding contribution to theliterature of fluorine. The thorough

manner in which the author deals withthe subject expresses itself in a mono-graph which includes 57 tables, 96figures, and a bibliography of 893references.

Although primarily begun as an in-dustrial hygiene study, the author hasencompassed the whole field of fluorosisin a manner that makes the book one ofequal interest to those in other branchesof medicine, especially pediatricians,orthopedists, and radiologists, as well asepidemiologists, dentists, biochemists,veterinarians, and agriculturists.The discussion of the prevention of

fluorine intoxication embraces the wholegroup of fluorine compounds found inindustry. The author states (p. 310)that " it would be desirable to forbidthe employment of males under 18 yearsand females as a whole, on work withfluorine compounds which give off dustor vapour." The necessity for controlof all sources where fluoric dust or vaporis generated, is emphasized in detail,not only with respect to the workersbut to that area surrounding the factorythat might become contaminated byvolatile fluorine compounds.

Although numerous experiments ininduced experimental fluorosis haveshown considerable storage of fluorine inthe bones with a resultant developmentof defective osseous structure, Roholmdemonstrates that comparable condi-tions are not uncommon among cryoliteworkers.

In a chapter entitled " Post MortemExaminations of Two Cryolite Work-ers," the author records (p. 184):"After Skeletonizing, the bones presentmarked changes. All are of a chalky-white color, the surface is irregular andthe weight considerably increased."Calcification of the ligamentous attach-ments was commonly observed. Thefluorine content of the costal bones was9.9 and 11.2 mg. per gm. of bone ashrespectively whereas about 0.5-2.1 mg.of fluorine per gm. of bone ash is re-

Nutrition NoteworthyVolume 2, Issue 1 1999 Article 4

A Pediatrician’s Guide to Infant DentalHygiene: Focus on Fluoride and Nutrition

Sukey Egger∗

∗David Geffen School of Medicine at UCLA,

Copyright c©1999 by the authors, unless otherwise noted. This article is part of the collectedpublications of Nutrition Noteworthy. Nutrition Noteworthy is produced by the eScholarshipRepository and bepress.

Abstract

As future pediatricians some of us will be asked seemingly benign questions, the answersto which are not simple and are mired in current public health controversy. One of thesequestions will be about dental hygiene for infants. This paper poses some common questionsparents may ask, and attempts to provide the information necessary to provide the best answerspossible. Plaque is a buildup of microorganisms that produce acid as a byproduct of sugarmetabolism. This acid demineralizes the tooth’s enamel; fluoride slows acid production andprovides the substrate for remineralization. Development of caries depends on the relativerates of de- and remineralization. Los Angeles’ water supply is unusual for a major city inthe US because it contains amounts of fluoride well below the optimal levels recommended bypublic health officials (1.0 ppm). Despite the low fluoride content, fluoride supplementation forinfants is not recommended by the American Academy of Pediatrics due to evidence of dentalfluorosis (mottling of teeth) after exposure to excess fluoride. The clearest recommendationsfor parents of infants are to only provide sweets at mealtimes, including sweetened beverages,and to brush their children’s teeth with a low fluoride toothpaste as soon as the teeth erupt.

Keywords: infant, fluoride, nutrition, dental hygiene

Suggested Citation:Sukey Egger (1999) “A Pediatrician’s Guide to Infant Dental Hygiene: Focus on Fluoride andNutrition ”, Nutrition Noteworthy : Vol. 2: Article 4.http://repositories.cdlib.org/uclabiolchem/nutritionnoteworthy/vol2/iss1/art4

A Pediatrician's Guide to Infant Dental Hygiene: Focus on Fluoride and Nutrition

As future pediatricians some of us will be asked seemingly benign questions, the answers to which are not simple and are mired in current public health controversy. One of these questions will be about dental hygiene for infants. Our first priority is to our patients and their families, so we need the best answers to the most common questions. Second, we need to be aware of the classic and current research findings in order to feel confident in these answers and to help influence public policy regarding issues such as water fluoridation. This paper poses some common questions parents may ask, and attempts to provide the information necessary to provide the best answers possible. Many parents will respond best to the handy American Academy of Pediatrics table below, while others will want more detailed answers.

Parent's Question: I remember the commercials with Crest toothpaste vanquishing the "cavity creeps". They hated Fluoride. What is fluoride and why did they hate it so?

Information to Help You Answer This Question: Fluoride is a trace element that has been demonstrated to be effective in preventing and fighting dental caries. The "creeps" were actually bacteria in plaque that build up on teeth. These bacteria produce acid as a byproduct of sugar metabolism and this acid demineralizes the tooth's enamel (12). When fluoride is present in the oral cavity, along with calcium and phosphate, the tooth can use it to engage in remineralization of enamel. Development of caries into cavities is dependent on the relative rates of demineralization and remineralization (12; 1; 10; 4). Parents of an infant must consider both preeruptive and posteruptive effects; during the first year of life, infants' primary and permanent teeth will be developing (preeruptive), and some teeth will be erupting (posteruptive). Fluoride is administered by two methods accordingly: systemically and topically. Systemic administration of fluoride assists in development of teeth; in addition, systemic fluoride is released from salivary glands following stimulation by sugars, bathing the oral cavity in saliva containing fluoride (15).

In order to demonstrate the efficacy of fluoride in preventing dental caries, many types of studies have been conducted. Many studies (over 113 studies in 23 countries; 11) have established a clear causal link between fluoride and caries prevention. Some studies established test communities with optimally fluoridated water and control communities without water fluoridation. Other studies used an ABA design in which a community's dental health is evaluated before fluoridation, after fluoridation, and after cessation of fluoridation. While there are some methodological problems, such as communities being able to decide whether they are test or control communities, in general the findings are quite conclusive. Optimal caries protection by fluoride occurs between 1 and 2 ppm (1-2 mg/L water) (12, 1, 10; for excellent reviews).

Q: Sounds like fluoride is pretty important, but why do I have to worry about it for my child. Don't they put fluoride in the water these days?

A: In light of the discovery of Fluoride's protective effect, public health officials recommended adding fluoride to water supplies (3). However, these officials found that when water levels exceeded 1.5 ppm (1.5mg/L) there were significant increases in a mottling of the teeth, called fluorosis. Thus, optimal levels of fluoridation were set at 1 ppm.

1Egger: Infant Dental Hygiene: Focus on Fluoride and Nutrition

Produced by eScholarship Repository, 2008

Los Angeles' water is not optimally fluoridated, with levels often far lower than recommended. In fact, there are only seven of the 50 largest US cities without optimally fluoridated water (12). Many cities have reduced their fluoride content for several reasons, some political (people believe fluoridation violates their rights to 'pure water'; e.g., the landmark "Strathclyde Fluoridation Case"), and others scientific (evidence of fluorosis now that most people are receiving fluoride from other sources, such as fluoride toothpastes).

Water in Los Angeles comes from a variety of sources. The majority of West Los Angeles, the San Fernando Valley, and South Bay receive water from the Los Angeles Filtration Plant and the MWD Jensen Treatment Plant. Downtown and South Central Los Angeles receive water from all four sources below. The DWP monthly monitors the sources, reservoirs, tanks, and distribution mains to determine water contents. Fluoride content in 1997 from these sources were:

Fluoride Content

Source Range Average

Los Angeles Filtration Plant 0.4-0.6 0.5

MWD Jensen Treatment Plant 0.2 0.2

MWD Weymouth Treatment Plant 0.2-0.3 0.3

River Supply Conduit 0.3-0.5 0.4

Thus it can be concluded that children in Los Angeles are not receiving optimal levels of fluoride from their drinking water, and some may be getting significantly less that this amount.

Q: I've heard of Fluoride supplements. If my child isn't getting Fluoride from the water, should I be giving her these supplements? And if so, how much?

A. There are many types of supplements that children can take (see 10; 1; 12; for reviews). These include tablets, drops, rinses, and gels topically, and fluoridated milk and salt systemically. These supplements arose at the same time as water fluoridation, in response to significant community-wide dental problems. Some measures were taken in schools, such as having all children take tablets or rinses each day in school. Some infant formulas were also supplemented with fluoride in the hope of reducing "baby bottle mouth" (rampant caries from constant suckling on bottles filled with sweet solutions).

While these measures were effective at the time, today supplementation is problematic. Children now receive fluoride from many sources. Parents and physicians need to estimate the amount of fluoride children receive from all sources before deciding to implement supplementation in order to prevent fluorosis (mottling of the teeth) and fluoride overdose(14). Decisions about supplementation need to consider (a) all sources of fluoride, (b) child's age and size, and (c) child's caries risk status. Recently, the American Academy of Pediatrics developed the following guidelines on supplementation (7):

2 Nutrition Noteworthy Vol. 2 [1999], No. 1, Article 4

http://repositories.cdlib.org/uclabiolchem/nutritionnoteworthy/vol2/iss1/art4

American Academy of Pediatrics Fluoride Supplementation Recommendations

Water Fluoride Content (in ppm)

Age <0.3 0.3-0.6 >0.6

Birth-6 mo 0 0 0

6 mo - 3 yr 0.25 0 0

3 - 6 yr 0.50 0.25 0

6 - 16 yr 1.00 0.50 0

This table provides a helpful rule of thumb for a practioner in many cases. However, it is clear that it is problematic. First, the water fluoride content used in this table may not be helpful for the community in question. For example, in Los Angeles' Westside, water comes from two sources, which have average fluoride contents of 0.5 and 0.2. The proportion of the water that comes from each of these sources varies day to day, depending on the availability of water that day (2). In addition, the range of water from a site may vary week to week and month to month. For example, the aqueduct's water sometimes has levels as high as 0.6. This makes determination of "water fluoride content" very complex. Depending on the day of the week, a child may fall into any of the three categories above. Second, the table does not consider other sources of fluoride, such as swallowed toothpaste, and fluoridated products. Some infant foods, especially those high in chicken, have been found to have high fluoride content and should be considered (Heilman et al., 1997). Finally, the table does not consider caries risk status, which some researchers consider a function of previous caries, diet, and socioeconomic status. Despite the difficulty of using this table, it is clear that for parents of infants who are not believed to be at particular risk of caries, no supplemention is recommended, regardless of the level of water fluoridation.

Q: Can I brush his teeth with my own toothpaste?

A: Early research suggested that systemic ingestion of fluoride was most helpful in preventing caries. The most current research is suggesting that post-eruptive effects of fluoride in balancing the levels of demineralization and remineralization are most crucial. Thus, teeth should be brushed carefully as soon as they erupt. To prevent fluorosis and accidental overdose (14), children should use either a low fluoride paste (500mg) if possible and should be taught not to swallow as soon as they are old enough. Currently only between 2% and 39% of parents reported brushing their infant's teeth with fluoride dentifrice (9). In addition, some research has shown that teeth should not be rinsed after brushing in order to maximize the effectiveness of fluoride application. Tooth brushing and establishing a routine of brushing daily is likely to be one of the most effective dental preventive habits a parent can teach a child. This may be difficult and parents may need lots of reinforcement for helping their child establish good dental hygiene practices.



Q: What about my child's diet? Are there foods that are better or worse?

A: Nutrition is an important factor in controlling dental caries in children and adults. The most cariogenic foods are those high in sugars (particularly glucose, sucrose, and fructose), especially foods that are sticky and will remain in the mouth, such as raisins and toffee. Plaque pH falls below demineralization levels within 10 minutes of eating sugars, and pH levels do not return to baseline for 40 minutes after consumption (12). Thus, frequent eating of sugars places teeth at higher risk. Eating sweets with meals can be considered safe because this limits the amount of time the sugars are available to the microorganisms, and it also encourages the flow of saliva. Fast flow saliva is alkaline and can help balance the pH flux. This is thought to be the basis for some of the protective effects of foods that stimulate salivation (e.g., sugarless gum).

The presence of fluoride during and after meals can have several beneficial effects. In addition to aiding in remineralization, the presence of fluoride also has been shown to reduce the metabolic acid production rate of the plaque, resulting in smaller pH shifts (8).

The following table reviews foods that are cariogenic, non-cariogenic, and protective:

Cariogenicity Food

High Sugars (sucrose, glucose, fructose, maltose)

Fine processed grains with sugars (e.g., cookies, sweet breads)

Sugared, fruit-flavored drinks (e.g., Hi-C, Kool-Aid)

Sweetened fruit juices

Extremely high consumption of fruit (especially bananas and apples)

Very Low/Non Cooked, staple starchy foods (i.e., whole grain breads, rice, pasta, potatoes)

Artificial Sweeteners

Fresh fruit (especially citrus)

Protective FLUORIDE!!!!

Milk (Calcium, Phosphorus, Casein, Fat)

Cheese (possibly, not a lot of studies)

Plants (phospate/phytate, still under clinical investigation)

Fibrous Foods (possibly, due to intense chewing stimulating salivary flow)

Sugar-free chewing gum

Summary

In summary, when parents of infants under one year ask for advice about dental hygiene, a simple clear response often works best in terms of adherence to recommendations:



1. Diet: Limit sweets to mealtimes; includes sweetened beverages and sweeteners on pacifiers

2. Toothbrushing: Brush your children's teeth as soon as they erupt with a small (pea-sized) amount of fluoridated children's toothpaste (500mg). Do not allow them to swallow this toothpaste if possible.

3. No supplementation: Do not supplement infants with fluoride

4. Public health efforts: Consider purchasing fluoridated water or writing policymakers in support of public health efforts to optimally fluoridate your community's water source.

5. Ask again next year. Guidelines are different for older children and there is some evidence in support of fluoride-containing implants, fissure and pit sealants, and unique combinations of fluoride with other chemicals (10; 5) that may enhance its effectiveness. Currently these are problematic and expensive, but future developments may make them more practical.

REFERENCES

1. Burt BA, Eklund SA. Community-based Strategies for Preventing Dental Caries. In: Pine CM, ed. Community Oral Health. Oxford: Reed Educational & Professional Publishing Ltd.; 1997: 112-121.

2. California Department of Health Services (DHS). City of Los Angeles 1997 Annual Water Quality Report.

3. Dean HT, Arnold FA, Elvove E. Domestic water and dental caries, V. additional studies of the relation of fluroide domestic waters to dental caries experience in 4425 white children aged 12-14 years, of 13 cities in 4 states. Public Health Report. 1942; 57: 1155-1179.

4. Ehrlich A. Nutrition and Dental Health, 2nd ed. Albany, NY: Delmar Publishers; 1994.

5. Gaffar A, Blake-Haskins JC, Sullivan R, Simone A, Schmidt R, Saunders F. Cariostatic effects of a xylitol/NaF dentifrice in vivo. International Dental Journal. 1998; 48: 32-9.

6. Heilman JR, Kiritsy MC, Levy SM, Wefel JS. Fluoride concentrations of infant foods. Journal of the American Dental Association. 1997; 128: 857-63.

7. Klish WJ, Baker SS, Flores CA, Georgieff MK, Lake AM, Leibel RL, Udall JN. American Academy of Pediatrics Fluoride Supplementation for Childre: Interim Policy Recommendations. Pediatrics. 1995; 95.

8. Lenander-Lumikari M, Loimaranta V, Hannuksela S, Tenovuo J, Ekstrand J. Combined inhibitory effect of fluoride and hypothiocyanite on the viability and glucose metabolism of Streptococcus mutans, serotype c. Oral Microbiology and Immunology. 1997; 12: 231-5.



9. Levy SM, Kiritsy MC, Slager SL, Warren JJ, Kohout FJ. Patterns of fluoride dentifrice use among infants. Pediatric Dentistry. 1997; 19:50-55.

10. Murray JJ, Naylor MN. Fluorides and Dental Caries. In: Murray, JJ, ed. The Prevention of Oral Disease. 3rd ed. Oxford: Oxford University Press; 1996: 32-67.

11. Murray JJ Rugg-Gunn AJ, Jenkins GN. Fluorides in Caries Prevention, 3rd ed. Wright, Butterworth Heinemann: 1991.

12. Rugg-Gunn AJ. Dental Caries. In: Welbury, RR, ed. Paediatric Dentistry. Oxford: Oxford University Press; 1997: 93-114.

13. Rugg-Gunn AJ. Diet and Dental Caries. In: Murray, JJ, ed. The Prevention of Oral Disease. 3rd ed. Oxford: Oxford University Press; 1996: 3-31.

14. Shulman JD, Wells LM. Acute fluoride toxicity from ingesting home-use dental products in children, birth to 6 years of age. Journal of Public Health Dentistry. 1997; 57: 150-158.

15. Twetman S, Nederfors T, Petersson LG. Fluoride concentration in whole saliva and separate gland secretions in schoolchildren after intake of fluoridated milk. Caries Research.1998; 32: 412-6.

16. Brunette DM. Critical Thinking: Understanding and Evaluating Dental Research. Chicago: Quintessence Publishing Co, Inc.; 1996

17. Cecil Textbook of Medicine, 20th ed. http://home.mdconsult.com/das/book/view/201?sid=2307598.

18. Chen M, Andersen RM, Barmes DE, Leclercq MH, Lyttle CS. Comparing Oral Health Care Systems: A Second International Collaborative Study. Chicago: The World Health Organization; 1997.



http://home.mdconsult.com/das/book/view/201?sid=2307598

Health risks from drinking of demineralised water

http://www.lenntech.com/health-risks-demineralized-water.htm

Introduction A community’s drinking water supply comes from ground and surface water sources. Every country's regulations require communities to treat and disinfect drinking water before distributing it to the public, because of the possible presence of pollutants (micro organisms, toxic minerals and metals, organic chemicals, radioactive substances, additives). Usually surface water has to undergo many more purification steps than groundwater to become suited to drink. Every country has its own legal drinking water standards. These prescribe which substances can be in drinking water and what the maximum concentrations of these substances are. The standards are called maximum contaminant levels. They are formulated for any contaminant that may have adverse effects on human health and each company that prepares drinking water has to follow them up. The main guidelines about drinking water standards are published by the World Health Organization (WHO) and by the European Union (EU). There are several problems that can endanger the quality of the drinking water and some diseases can occur by drinking improperly treated water. Even if the water is purified and cleaned, it can miss some minerals or desirable substances, not being fully appropriate for consumption. In fact, not all substances present in water are necessarily harmful to our health: some substances are health improving. Water almost or completely free of dissolved minerals as a result of distillation, deionisation, membrane filtration, electrodialysis or other technology is called demineralised water. There are many pros and cons on drinking demineralised water. The argument in favour of drinking it is that the minerals present in water intervene with our body functions. Many books are written by doctors and nutritionists claiming that the presence of minerals in drinking water causes disease. The arguments against drinking demineralised water are that we lost a primary source of necessary minerals in our diet and that water that has lost its own minerals will attract and absorb minerals in our body, causing a mineral deficit.

Drinking water hardness

When water is referred to as 'hard' this means that it contains more minerals than ordinary water. These are especially the minerals calcium (Ca) and magnesium (Mg). Hardness is expressed in terms of calcium carbonate (CaC03). Water with less than 75 milligrams per litre (mg/l) is considered soft, 76-150 mg/l moderately hard, and above 150 mg/l hard water. The degree of hardness of the water increases when more calcium and magnesium dissolve. ‘Soft’ water is water that contains small amounts of calcium and magnesium. Some soft water is naturally occurring, but most of it is created by water softeners. A water softener is a unit that is used to soften water, by removing the minerals that cause the water to be hard. A water softener collects hardness minerals within its conditioning tank and from time to time flushes them away to drain. Ion exchangers are often used for water softening. When an ion exchanger is applied for water softening, it will replace the calcium and magnesium ions in the water with other ions, for instance sodium (Na) and potassium (K). The exchanger ions are added to the ion exchanger reservoir as sodium and potassium salts (NaCl and KCl).

Health risks There has been much publicity over the years about the negative health effects of drinking softened water, but recent research showed that the amount of salt consumed by drinking softened water is insignificant when compared to overall daily salt intake. Anyway over the past 25 years research has continued to amass in support of the beneficial role of minerals in water: studies of populations in areas of naturally occurring hard water and soft water have found few occurrences of cardiovascular diseases, cancer, diabetes, respiratory diseases or other health problems in hard water areas. A domestic, innovative system, which can be used to get perfectly balanced proportions of minerals good for our health in drinking water, is provided by Lenntech. For more information go to our home water filter web page. In the draft of the rolling revision of the WHO guidelines for drinking-water quality, titled ‘Health risks from drinking demineralised water’ by F. Kožíšek, the possible health consequences of low mineral content water consumption are divided in the categories: direct effects on the intestinal mucous membrane, practically zero calcium and magnesium intake, low intake of other elements, loss of calcium, magnesium and other essential elements in prepared food, possible increased dietary intake of toxic metals, possible bacterial re-growth. Direct effects on the intestinal mucous membrane It has been demonstrated that consuming water of low mineral content has a negative effect on homeostasis mechanisms. Homeostasis literally means ‘same state’ and it refers to the process of keeping the internal body environment in a steady state. In his publication Kožíšek states that "experiments in animals have

repeatedly shown that the intake of demineralized water leads to diuresis (increased urination caused by substances present in the kidney tubules), extra cellular fluid volume and serum concentration of sodium and chlorine ions and their increased

elimination from the body, lower volumes of red blood cells and other hematocritic

changes (alteration of the number of red blood cells)". A German study carried out by th German Society for nutrition proved instead that if distilled water is ingested, the intestine has to add electrolytes to this water, taking them from the body reserves. After the ingestion of distilled water the electrolytes dissolved in the body water are further dilute. Inadequate body water redistribution may compromise the function of vital organs. In the past, acute health problems were reported in mountain climbers who had prepared their beverages with melted snow. which was not supplemented with necessary ions. A more severe course of such a condition coupled with brain oedema, convulsions and metabolic acidosis was reported in infants whose drinks had been prepared with distilled or low mineral bottled water (CDC 1994). Practically zero calcium and magnesium intake Calcium and magnesium are essential elements for our body. They can be provided to our organisms by food, but even the diets rich in calcium and magnesium intake may not be able to fully compensate their absence in drinking water. Calcium is part of bones and teeth. In addition, it decreases neuromuscular excitability, is beneficial to the conducting myocardial system, heart and muscle contractility, intracellular information transmission and blood clotting. Osteoporosis is the most common manifestation of calcium deficiency; a less common but proved disorder attributable to Ca deficiency is hypertension. Magnesium plays an important role as a cofactor and activator of more than 300 enzymatic reactions including glycolysis, ATP metabolism, transport of elements such as sodium (Na), potassium (K) and calcium through membranes, synthesis of

proteins and nucleic acids, neuromuscular excitability and muscle contraction etc. It acts as a natural antagonist of calcium. Magnesium deficiency increases risk to humans of developing various pathological conditions such as vasoconstrictions, hypertension, cardiac arrhythmia, atherosclerotic vascular disease, acute myocardial infarction, preeclampsia in pregnant women, possibly diabetes mellitus of type II and osteoporosis (Rude, 1998; Innerarity, 2000; Saris et al, 2000). Researches and studies proved that water low in magnesium can cause increased morbidity and mortality form cardiovascular disease, higher risk of motor neuronal disease, pregnancy disorders, preeclampsia. Water low in calcium may be associated with higher risk of fracture in children, certain neurodegenerative diseases, pre-term birth and low weight at birth. Lack both in calcium and in magnesium can also cause some types of cancer. Water hardness and cardiovascular disease Over 80 observational epidemiological studies relating hardness and cardiovascular disease risks have been realized and their results had been discussed by experts at the meeting organized by the WHO European Centre in Rome on November 11-13, 2003. The conclusions are quoted in the WHO report titled: 'Nutrient minerals in

drinking-water and the potential health consequences of long-term consumption of

demineralized and remineralized and altered mineral content drinking-waters',

published in August 2004. It was observed a positive (protective) association between cardiovascular disease mortality and increased water hardness in countries around the world, both for population and on individual-basis. It was then supposed that these beneficial health effects can possibly be extended to large population groups on a long- term basis by adjusting the water quality. It was pointed out that magnesium and possibly calcium may be effective in reducing blood pressure in hypertensive individuals. Nutritional studies suggest that some other micronutrients may have a beneficial role associated with their presence in drinking water, even is they have not extensively considered in these epidemiological studies yet. More studies are needed to better understand the possible risks and benefits of essential and trace elements found in water. The discussion group concluded there is sufficient epidemiological evidence of and inverse relationship between magnesium concentration in drinking water and ischemic heart disease mortality, and therefore the reintroduction into demineralised water in the remineralisation process would likely provide health benefits. There are, in fact, no known harmful human health effects associated with the addition magnesium within a large range and the nutritional benefits are well known. It is thought that adding calcium provides the same benefits, however, a correlation between calcium in drinking water and decreases in the occurrence of heart disease is not yet proven substantially. Low intake of some essential elements The contribution of water to uptake of some essential elements for humans is important because the modern diets are often not an adequate source of some minerals. Moreover these minerals are often present in water as free ions, so they are more readily adsorbed from water compared to food. Recent epidemiological studies suggest that low mineral drinking water may be a risk factor for hypertension and coronary heart disease, gastric and duodenal ulcers, chronic gastritis, goitre, pregnancy complications and several complications in infants. A study of this kind conducted in 1992 by Lutai on two populations living in areas with different levels of dissolved minerals showed that the population of the area supplied with water low in minerals showed higher incident rates of these disease. Children living in this area

exhibited slower physical development and more growth abnormalities, pregnant women suffered more frequently from oedema and anaemia. High loss of calcium, magnesium and other essential elements in food prepared with low mineral water If soft water is used for cooking it can cause substantial losses of all essential elements from food. In contrast, if hard water is used, the loss of these elements is much lower. Since the current diet of many people does not provide all the necessary elements in sufficient quantities, it is important to not loose essential elements and nutrients during cooking. Therefore, in the areas supplied with soft water, we have to take into account not only a lower intake of magnesium and calcium from drinking water but also a lower intake of magnesium and calcium from food due to cooking in such water. Risk from toxic metals Low mineralised water is highly aggressive to materials with which it comes into contact. It easily adsorbs metals and some organic substances from pipes, coatings, storage tanks and containers. Moreover, calcium and magnesium in water and food are known to have an antitoxic activity: they can prevent the absorption of some toxic elements from the intestine into the blood. Population supplied with low-mineral water may be at a higher risk in terms of adverse effect from exposure to toxic substances compared to populations supplied with water of average mineralization. Calcium and to a lower extent also magnesium in both drinking water and food were previously found to have a beneficial antitoxic effect since they prevent – via either a direct reaction resulting in an no absorbable compound or competition for binding sites – absorption or reduce harmful effects of some toxic elements such heavy metals. Possible bacteria contamination of low-mineral water The bacterial re-growth is encouraged by the lack of a residual disinfectant and by the possibly great availability of nutrients in aggressive water, such the low-mineral water, particularly if it has a high temperature. Harmful effects of hard water No evidence is available to document harm to human health from harder drinking water. Perhaps only a high magnesium content (hundreds of mg/l) coupled with a high sulphate content may cause diarrhea. Other harmful health effects were observed in water rich in dissolved solids (above 1000 mg/l of TDS) showing mineral levels that are not common in drinking water. In areas supplied with drinking water harder than 500 mg/l CaCO3, higher incidence rates of gallbladder disease, urinary stones, arthritis and arthropathies as compared with those supplied with softer water were reported (Muzalevskaya et al, 1993). An epidemiological study carried out in a particular region (Tambov) found hard water (more than 400-500 mg/l of CaCO3) to be possible cause of higher incidence rates of some diseases including cancer (Golubev et al, 1994). Sensorial disadvantages of hard and soft water Higher water hardness may worsen sensorial characteristics of drinking water or drinks and meals prepared with such water: formation of a layer on the surface of coffee or tea, loss of aromatic substances from meals and drinks (due to bonding to calcium carbonate), unpleasant taste of water itself for some consumers. Very soft water, such as distilled and rain water as two extreme examples, is of

unacceptable taste for most people who usually report it to be of unpleasant to soapy taste. A certain minimum content of minerals, the most crucial of which are calcium and magnesium salts, is essential for the pleasant and refreshing taste of drinking water. Fluoride in drinking water Most drinking waters contain some fluoride. Processes such anion exchange, demineralisation and some other treatments which will remove it, affecting its concentration. High levels of excess fluoride intake cause crippling skeletal fluorosis. This is almost always associated with high fluoride intake from drinking water. Ingestion of excess fluoride during tooth development, particularly at the maturation stage, may also result in dental fluorosis. The optimal drinking water concentration of fluoride for dental health is generally between 0.5 to 1.0 mg/litre and depend upon volume of consumption and uptake and exposure from other sources. These values are based on epidemiological studies. The WHO drinking water quality guideline value for fluoride is 1.5 mg/l. The US Environmental Protection Agency has set a Maximum Contaminant Level of 4.0 mg/l in the US based upon prevention of crippling skeletal fluorosis and a guidance of 2.0 mg/l to avoid moderate dental fluorosis. A decision to use demineralised water as drinking water sources without addition of fluoride during remineralization will depend upon many factors: the concentration of fluorine in the existing local supply, the volume of water consumed, the prevalence of risk factors for dental caries, oral hygiene practices, level of public dental awareness, presence of alternative vehicles for dental care and fluoride available to the whole population. Desirable mineral content of demineralised drinking water In the late 1970’s, the issue of an optimum composition of drinking water, particularly if obtained by desalination, was in the centre of attention of the WHO. The WHO also emphasized the importance of mineral composition of drinking water and warned e.g. against the use of cation exchange sodium cycle softening in water treatment (WHO, 1978; WHO, 1979). In the 1980’s the wave of interest in the effect of water hardness on cardio vascular diseases morbidity rather subsided; it seemed that any new insight into the issue could not be expected. The focus was on confirming the role of magnesium as a crucial factor of hardness and on first attempts of more general quantification of its protective effect. In the 1990 criticisms of the existing studies started to make a new challenge to publications of further studies. These critics asserted that morbidity was evaluated at a population group based level, rather than at an individual-based level and individual exposure to calcium and magnesium from water was not established. In other studies, the confounders possibly involved in cardio vascular diseases morbidity such as age, socio-economic factors, alcohol consumption, eating habits, climatic conditions etc. were not adequately taken into account. Most new epidemiological studies of the 1990’s were able to specify the effect of either calcium or magnesium and also focused on morbidity other than cardio vascular diseases. During the 90’s research confirmed a protective effect of both drinking water magnesium and calcium against cardio vascular diseases, and more data on beneficial effect of these elements in drinking water on human health were presented. More recent studies have provided additional information about minimum and optimum levels of minerals that should be in demineralised drinking water. These studies suggest for magnesium a minimum of 10 mg/l and an optimum of 20-30

mg/l, for calcium a minimum of 20 mg/l and an optimum of about 50 mg/l, for fluoride an optimum of 0.5 – 1 mg/l and a maximum of 5 mg/l. For total water hardness the sum of calcium and magnesium should be 200 to 400 mg/l. At these concentrations, minimum or no adverse health effects were observed and the maximum protective or beneficial health effects of drinking water appear to occur.

Conclusion and recommendations Minerals are important parts of drinking water and are of both direct and indirect health significance. Sufficient evidence is now available to confirm that a certain minimum amount of minerals in water is desirable, since their deficiency have many negative health effects: diseases and possible aggression from toxic elements and bacteria. The optimum Ca and Mg levels in drinking water should lie within the following ranges: from 20 to 30 mg/l for Ca and from 40 to 80 mg/l for Mg and from about 200 to 400 mg/l for water hardness. Unfortunately, over the past two decades little research attention has been given to the beneficial or protective effects of drinking water substances. As recommended in the rolling revision of the WHO guidelines for drinking water quality, titled: ‘Nutrient minerals in drinking-water and the potential health

consequences of long-term consumption of demineralised and remineralized and

altered mineral content drinking-waters’, there is a need for more precise data on the impact of water composition and intake under a broader range of physiologic and climatic conditions, in order to more precisely evaluate the importance of minerals in drinking water on mineral nutrition. Additional studies should be conducted on potential health consequences associated with consumption of both high and low mineral content waters in addition to consideration of water hardness. When studies are conducted, investigators should consider exposures to both calcium and magnesium levels in combination with other minerals and trace elements that may be present in hard and soft waters. National governments and water suppliers should be encouraged to practice stabilization of demineralised water with additives that will increase calcium and magnesium levels and to conduct studies that monitor public health impacts. Community and bottled water suppliers should provide information to the general public and health professionals on the composition of water for constituents including possibly beneficial substances. Water bottlers should also consider providing waters with mineral compositions that are beneficial for population segments.

For all you questions on demineralised water move to the demineralised water FAQ or look at our demiwater web page.

References

• C. Ingram, The drinking water book, Ten Speed Press, 1991 • F. Kožíšek, Health risks from drinking demineralised water, WHO, 2004 • F. Kožíšek, Health significance of drinking water calcium and magnesium,

National Institute of Public Health, February 2003 • Consensus of the meeting August 2004, Nutrient minerals in drinking-water

and the potential health consequences of long-term consumption of

demineralized and remineralized and altered mineral content drinking-waters, WHO

IMC Fertilizer Group, Inc.

http://www.fundinguniverse.com/company-histories/IMC-Fertilizer-Group-Inc-Company-History.html Address: 2100 Sanders Road Northbrook, Illinois 60062 U.S.A. Telephone: (708) 272-9200 Fax: (708) 205-4804 Statistics: Public Company Incorporated: 1988 Employees: 5,000 Sales: $1.06 billion Stock Exchanges: New York Midwest SICs: 2819 Industrial Inorganic Chemicals, Nec Company History:

IMC Fertilizer Group, Inc. (IMCF) was created in 1988 when the onetime International Minerals & Chemicals Corporation divested its fertilizer assets in the form of a new, publicly traded company. As the fertilizer market was then in the midst of a long and disastrous slump, the spin-off proved to be most beneficial for the parent company, which promptly changed its name to Imcera Group, Inc., and entered the market of high-tech health and animal care products. IMCF, meanwhile, the largest private-sector producer of phosphate and potash fertilizers in the world, was left to contend with the continuing collapse of its domestic and international markets, which never recovered from the price shocks caused by the 1973-74 oil crisis. IMCF's strategy was a proposed joint venture with its nearest domestic competitor, Freeport-McMoRan Resource Partners, itself the result of a divestment move similar to that which created IMCF. If the joint venture was approved by antitrust regulators, it would control nearly half of all United States phosphate production--an enviable position to occupy, if and when the fertilizer market regained its former health.

The ancestor of IMCF was formed at the end of the nineteenth century, a time when farmers in the United States and western Europe were switching from traditional fertilizers to the use of commercial chemical fertilizers. Scientific experiments in the first half of the nineteenth century had identified precisely the nutrients needed for plant growth and continued soil fertility. Chief among these were nitrogen, phosphorus, and potassium, known by their chemical symbols as the basic N-P-K triad of nutrients. During the preceding centuries of farming, trial and error experiments had discovered sources for each of these nutrients in such traditional fertilizers as animal manure, bones, guano, and fish scrap; but with the progress of chemical knowledge came the search for methods by which N-P-K could be produced in their most concentrated and inexpensive forms. In the United States commercial fertilizer was especially desired in the eastern and southern states, where older, over-farmed land responded well to their application. By the last quarter of the nineteenth century a strong business had grown up around the phosphate mines of Florida and Tennessee.

The earliest predecessor of IMCF was founded in 1897 in Tennessee by Thomas C. Meadows and his brother-in-law Oscar L. Dortch. Meadows was an engineering graduate of Vanderbilt University who understood the potential market for Tennessee's phosphate rock, which when treated with sulphuric acid yielded a product rich in the form of phosphorus most readily absorbed by growing plants. With Oscar Dortch, Meadows formed T.C. Meadows & Co. to mine, process, and sell this "superphosphate" both by itself and in ready-mixed fertilizer containing suitable proportions of the other two basic nutrients, nitrogen and potash. These would have to be purchased on the market from sources originating as far away as Germany and Chile, making the business of fertilizers capital intensive and encouraging the development of large combines capable of supplying all three ingredients.

With that in mind, Meadows & Co. changed its name in 1899 to United States Agricultural Corporation and began acquiring the assets it would need to survive in the rapidly consolidating fertilizer industry. In 1900 it gained control of two companies engaged in the Florida phosphate mines, Florida Mining Company and Peoria Pebble Phosphate Company. Because Florida's phosphate fields, located in the central and northern parts of the state, were richer and easier to mine than those of Tennessee, they soon became the backbone of the U.S. phosphate industry. In most cases the mines were laid in remote, inhospitable, and sparsely settled areas where employers such as United States Agricultural could find few workers to perform the manual labor then required to extract phosphate. The mining companies turned this to their advantage, however, by building primitive "company towns" and importing convicts from the state of Florida and others from neighboring Georgia and Alabama. The combination of high-grade phosphate and cheap labor enabled United States Agricultural to make an excellent return on its Florida operation and attracted the attention of outside investors eager to get into the growing fertilizer industry.

Among the financial backers rounded up by Meadows and Dortch, the most important was Waldemar Schmidtmann, member of an Austrian family that controlled one of the largest potash mines in Germany--Kaliwerke Sollstedt. Potash is the most abundant mineral source of potassium and for many years virtually all of the world's known potash was found in Germany, giving that nation a powerful bargaining chip in its trade with the United States. An industrial cartel set prices and controlled production of German potash; only intermittently effective, the cartel was nevertheless sufficiently troublesome for United States importers to make the possibility of ownership in a German potash mine extremely appealing. Thus Meadows and Dortch were happy to listen when Schmidtmann proposed a union of their respective holdings, and in 1901 the Austrian became a partner in the newly renamed International Agricultural Corporation (IAC). Along with an investment of cash, Schmidtmann also brought to IAC a part interest in Kaliwerke Sollstedt, guaranteeing the U.S. company access to two of the three basic fertilizer nutrients.

IAC moved swiftly into the finished product end of the fertilizer business as well, buying up mixed fertilizer plants from Maine to Alabama in an effort to complete the vertical integration of the company. IAC was also heavily involved in the growing export market for high-grade Florida phosphate, whose value as a plant nutrient was gradually being recognized around the world. It would not be long before the peasants of China and villagers of remote Bulgaria were introduced to the wonders of commercial fertilizer, and, especially as population pressure increased in Asia and Africa toward the middle of the twentieth century, the export of phosphate and mixed fertilizer became increasingly important to the U.S. fertilizer industry.

By 1910 IAC was firmly established as one of the handful of consolidated companies dominating the U.S. fertilizer business. Controlling between 30 and 40 subsidiary companies engaged in every aspect of fertilizer production, IAC generated revenues of approximately $8.5 million, on which it earned a net income of about $1 million. The industry as a whole had enjoyed a tremendous upsurge over the preceding 20 years; U.S. commercial fertilizer consumption more

than quadrupled, while the traditional methods of organic fertilization all but disappeared from the landscape.

Problems arose with the approach of the World War I, however. Not only was IAC and the entire U.S. fertilizer industry dependent on German potash mines, German scientists had also developed the first reliable method of fixing atmospheric nitrogen in the form of ammonia, which could then be used in the production of two radically different but equally crucial materials--fertilizer and explosives. The war forced the U.S. government into a frenzied development of its own nitrogen-fixing process and the fertilizer industry into a long search for domestic sources of potash. IAC temporarily lost access to its Sollstedt mine in Germany, but upon the war's conclusion in 1918 resumed its imports of potash, leaving to other companies the 20-year search for North American deposits.

It was not until the late 1930s, when war again threatened to cut off German supplies, that IAC joined other fertilizer concerns in exploring the American Southwest for potash. Oil drilling had established the presence of potash near Carlsbad, New Mexico, as early as the mid-1920s, and in 1937 IAC invested $100,000 in the Union Potash Company in exchange for a portion of its findings. When these proved sizable, IAC effectively bought out Union Potash and built itself a state-of-the-art potash facility in time to meet its own needs before the onset of World War II in 1939. IAC has remained one of the largest American producers of potash, pioneering several new techniques at the Carlsbad mine and in 1962 opening a second major deposit at Esterhazy, Saskatchewan. The latter required five years of engineering effort to complete its 3,000-foot shaft but yielded an enormous find of unusually high quality potash.

Phosphate, however, remained the strength of IAC. The company continued to buy or lease acreage in the central Florida area, where in 1929 it pioneered the flotation method for separating phosphate pebbles from surrounding sludge, thereby greatly increasing the yield potential of any given mine. Shortly before that, IAC had opened its first major phosphate processing plant in Wales, Tennessee, where raw phosphorus was converted into a variety of products, including such fertilizers as superphosphate and diammonium phosphate and also cleaning agents like tri-sodium phosphate. By 1939 IAC was the largest producer of phosphate rock in the world. Population pressure in Asia and Latin America, combined with the needs of larger, state-owned farms in Eastern Europe and Russia, gave to the business of fertilizers an importance that ensured that the decades of the 1950s and 1960s would be highly profitable for manufacturers such as IAC.

As if anticipating the postwar explosion in its foreign trade, IAC in 1941 changed its name to International Mineral & Chemical, Inc. (IMC) and also shifted its headquarters from Atlanta to downtown Chicago. With the war's end in 1945, American agricultural methods were studied and adopted by nations first awakening to the problems of overpopulation and land exhaustion, and America's agriculture depended above all else on large quantities of fertilizer. Soon Japan was importing potash for its burdened rice fields, followed by India and a host of lesser Asian countries, while in the impoverished lands of Africa chemical fertilizers were adopted with the hope of averting wholesale famine. As long as the world's leading suppliers of commercial fertilizer were located in the United States and western Europe, fertilizer prices only strengthened as developing and communist countries upped their usage. Producers such as IMC responded by increasing capacity and enjoyed a 20-year period of solid profits and continued expansion.

In 1963 IMC made its belated entry into the nitrogen business, forming a joint venture with Northern Natural Gas of Omaha, Nebraska, to build an ammonia plant on the Mississippi River in Cordova, Illinois. A year later IMC underscored its faith in the export business by building its own ocean shipping terminal near Tampa, Florida, with storage facilities for phosphate rock and chemicals and a mechanized loading system capable of handling 2,500 tons per hour. At

the same time, to solidify its land transportation IMC began assembling its own fleet of rail cars, ensuring itself of adequate rolling stock for the highly seasonal business of mixed fertilizers. The company also took a few tentative steps toward diversifying its holdings with the 1967 purchase of two industrial mineral firms and the acquisition a few years later of several container companies.

By that time, however, the world fertilizer market was in the midst of a radical change. Third World and Communist-bloc nations had placed great emphasis on developing indigenous supplies of the basic fertilizer nutrients, seeking to free themselves of dependence on the Western multinationals, and as a result total world production was up sharply by the early 1970s. Many of the new producers were under government control or enjoyed state subsidies, making it impossible for Western suppliers to offer competitive pricing. This shift was dramatized by the oil crisis of 1973-74, when skyrocketing energy prices pushed fertilizers up by as much as 300 percent, providing further impetus for the development of Third World and Communist-bloc supplies. (The production of nitrogen in the form of ammonia is extremely energy-intensive, and as nitrogen is the most widely used fertilizer in the world, fertilizer prices tend to follow the cost of energy.)

Fertilizer prices quickly returned to pre-1973 prices, but the turmoil only confirmed the resolve of IMC president Richard A. Lenon to pursue a program of diversification. In 1975 IMC paid $207 million for Commercial Solvents Corporation, a major producer of industrial chemicals, hydrocarbons--including explosives--and pharmaceuticals, including various growth hormones for livestock. Commercial Solvents also brought with it a sizable ammonia plant in Sterlington, Louisiana, to which IMC soon added a second facility in an effort to protect itself against any further price panics in the nitrogen market. 1975 was also the year in which IMC's new state-of-the-art processing plant began operations near Mulberry, Florida, increasing the company's production of phosphate and other chemicals in anticipation of energy-driven cost and price surges.

Unfortunately for IMC, however, the fertilizer market has drifted continually downward ever since the mid-1970s. What the business periodicals referred to as "the notoriously cyclical fertilizer industry" was in fact entering a depression that has proven to be all but permanent. Worldwide use of fertilizers continued to climb, but an ever greater percentage of fertilizer was produced in developing and centrally planned economies. According to the World Bank, in 1950 the capitalist West produced about 70 percent of the world's fertilizer; by the 1980s that figure was down to around 30 percent, with the bulk of the new producers located in Communist-bloc countries that could sell their excess fertilizer below Western market prices. Exacerbating this general decline was the recession suffered by U.S. agriculture throughout the 1980s, when grain surpluses drove down the commodity markets and idled many farms in the United States and Canada. Further, the use of phosphates in detergent was banned by the Environmental Protection Agency in the 1970s, while a growing proportion of the U.S. public expressed concern about the presence of nonorganic fertilizers in their food.

In the meantime, IMC management made a number of poor business decisions in the early 1980s. The company embarked on a vast expansion of its Florida phosphate rock holdings, doubled the capacity of its processing plant at Mulberry, and pursued a technique for uranium oxide recovery at a time when the nuclear energy industry had been brought to a standstill by opposition from environmentalists. When the fertilizer market hit a ten-year low in 1986, new IMC Chairman George Kennedy succeeded at last in diversifying the company's holdings with the purchase of Mallinckrodt Corporation from Avon, Inc., for $675 million. Mallinckrodt, a 115-year-old St. Louis firm, was powerful in medical imaging technology and pharmaceuticals. IMC soon added Pitman-Moore, an Illinois-based manufacturer of animal health products.

IMC's Kennedy then made the kind of brilliant strategic decision that will doubtless be the subject of a business school case study. Recognizing the fundamental weakness of the fertilizer business, which then supplied about half of corporate revenue, he made IMC into a holding company with three separate subsidiaries--IMC Fertilizer, Mallinckrodt, and Pitman-Moore. When fertilizer prices rose briefly in early 1988, he sold off 62 percent of IMC's stock in a public offering, then gradually sold the remainder of IMC's holdings back to IMC itself. By means of this adroit maneuver, IMC freed itself of the troubled fertilizer business while picking up the cash to make another major purchase in 1989, when it added Cooper Animal Health Group. Kennedy changed IMC's name to Imcera Group, Inc., and has fared splendidly ever since.

IMCF has not prospered to nearly such a degree. U.S. agriculture remained weak, while the demise of communism brought an enormous amount of fertilizer into the open market at bargain prices; the formerly state-controlled economies were desperate to obtain cash from the West. The severe recession that began in 1989 was a further blow to IMCF's fortunes, as were a 1992 special charge of $166 million for accounting charges and a 1993 settlement of a lawsuit for $169 million. The suit was brought by various parties following an explosion at a nitroparaffin plant in Sterlington, Louisiana, in May of 1991; eight employees were killed and many injured by the explosion, which occurred in a plant operated by IMCF although owned by Angus Chemical Company.

With fertilizer prices dropping to their lowest levels since the mid-1970s, IMCF formed a joint venture in 1993 with Freeport-McMoRan Resource Partners to pool their phosphate holdings. While it is hard not to see this move as the rather desperate attempt of a staggering giant to salvage what it can from a hopeless situation, it may yet prove to be a winning combination once the world fertilizer market returns to some semblance of order. With one half of all U.S. phosphate production, the new joint venture would obviously dominate a healthy phosphate market, but as of 1993, it remained only the largest player in a losing game.

Further Reading: Chemical Week, January 27, 1993, p. 9. "Growing With Agriculture to Feed a Hungry World," Northbrook, Illinois: IMC Fertilizer corporate publication, c. 1991. "IMC Group Charts Chemical Course," Chemical Week, September 17, 1975, p. 18. "IMC: Slimmer Profits for a Fertilizer Giant," Chemical Week, March 17, 1982, pp. 44-50. Improving the Supply of Fertilizers to Developing Countries, Washington, DC: The World Bank, 1989. Kemezis, Paul, "Imcera's Quick-Change Act," Chemical Week, July 18, 1990, pp. 22-24. Nelson, Lewis B., History of the United States Fertilizer Industry, Muscle Shoals, AL: Tennessee Valley Authority, 1990. "Prairie Province Goes Wild Over Potash," Business Week, July 21, 1982, pp. 110-114.

Source: International Directory of Company Histories, Vol. 8. St. James Press, 1994.

1

MODELING THE IMPACT OF A

PHOSPHOGYPSUM STACK ON THE GROUNDWATER AQUIFER

by

Manfred Koch

and

Takashi Thomas Shinkawa

Temple University

Philadelphia, PA 19122

March, 1997

2

TABLE OF CONTENTS

1. INTRODUCTION………………………………………………

2. BACKGROUND……………………………………………….

Location…………………………………………………….

Geology……………………………………………………..

Hydrogeology………………………………………………

3. METHODS OF DATA ANALYSIS ..…………………………

Phosphogypsum Stack……………………………………

Surficial Aquifer………………………………………….

4. HYDROLOGIC DATA ..………………………………………

Stack Analysis……….……………………………………..

Analysis of Hydraulic Heads………….……………

Cooper-Jacob Straightline Method..…………………

Pressure Transducer Tests …………………………..

Borehole Flowmeter Tests …………………………….

Surficial Aquifer………………………………………….

Regional Flow Trend………………………………….

Water Table Contours……………………………….

Conductivity Analysis………………………………

Kirkham Auger HoleTest……………………

Bouwer Rice Test……………………………..

Precipitation………………………………………………

5. GROUNDWATER FLOW MODEL………………………….

Description of the MODFLOW model…………….

Mathematical Theory

Design of the flow model………………………

The conceptual model

Grid geometry……………………………………..

Hydrologic Parameters…………………………….

Boundary Conditions ……………………………..

3

Sources and Sinks ………………………………..

Calibration……………………………………………….

Sensitivity Analysis………………………………………

Leakance……………………………………………

Conductivities………………………………………

Ditch Specifications………………………………..

Water Budget Analysis…………………………………..

6. CONCLUSIONS……………………………………………

REFERENCES CITED………………………………………….

APPENDICES……………………………………………………….

I: Cooper-Jacob Straightline Plots

II: Pressure Transducer Tests

III: Hydraulic Head Contour Plots

IV: Bouwer Rice Plots

4

CHAPTER 1

INTRODUCTION

Phosphate mining in Florida is currently one of the state’s largest industries, and

produces approximately 40 million tons of material per year (Miller and Sutcliffe, 1984).

Estimates from previous studies indicate that 335 million tons of phosphatic waste have

been stockpiled in above-ground formations called “Phosphogypsum Stacks” (defined as

such by the source and product of their existence). Gypsum and silicon hexafluoride make

up the slimy waste that is pumped out to large evaporite ponds, where the former is

allowed to precipitate. Over time, accumulation at the bottom of the pond is dug out and

piled on the embankments of the pond. This practice is intended to strengthen the walls of

the pond, as it grows in size and elevation. Approximately eighteen such industrial

facilities are located in the Tampa area, with an average area of 227 acres and a range of

heights between 30 and 140 feet.

As the stockpile of gypsum stacks grow to a projected billion-plus tons by the year

2000 (May and Sweeney, 1983), the high concentrations of radionuclides, acid, fluoride,

phosphate, and sulfate become an increasingly problematic characteristic of this

resource, with the potential for groundwater pollution.

The primary focus of this study was to investigate the hydrologic controls of the

phosphogypsum stack, and to provide a model of groundwater flux upon which a future

transport and geochemical model can determine the migration and fate of possible

contaminant leachate plumes and to delineate the physical and chemical processes

involved. As to the more particular objectives of the hydrological part of the research

5

they amount to a quantification of the vertical and horizontal flow rates in the

phosphogypsum stack and the surficial aquifer, respectively, as well as to a

determination of the hydraulic impact of the phosphogypsum stack on the surficial

aquifer.

6

CHAPTER 2

ENVIRONMENTAL SETTING

Geography

The Piney Point Phosphates facility, located along the coast of western Florida,

lies approximately 30 kilometers south of downtown Tampa in Manatee County, along

Florida route 41 (figure 1). The study area is a rural setting with cattle ranches, citrus

groves, and vegetable farms making up a majority of the businesses close by.

Topographically, the area is relatively flat with drainage flowing either to the Manatee

River in the North, McMullen Creek in the South, or to the Gulf of Mexico in the West

(figure 2). The Piney Point Phosphates complex is at an elevation of 3 - 8 m. above mean

sea level, and is about two kilometers from the shoreline of the Gulf of Mexico.

The climate of the research area is subtropical. Convective thunderstorms

dominate the rainy weather of the summer months, while winter and spring are fairly dry.

Consequently, irrigation demands on the groundwater reach a peak from March through

May.

This particular site, although presently inactive, is an ideal location for studying

fluid migration from phosphogypsum stacks, owing to the fact that local groundwater

movement is toward the Gulf of Mexico and away from any large population in the area.

Major lithologies of stratigraphic units in the area define three distinct groups of

formations (figure 3). Each groups bears significance as a water producing unit with

respective hydrologic importance to its defining lithology. Although heterogeneous

7

Figure 1. Location of Research Area on Florida State map

8

Sho

relin

e

5

10

15 20

25

30

35

0 1 2 km.

SCALELEGEND

Piney Point Complex

Roads

Waterways

5

35

10

35

10

25

30

30

25

20

510

15

20

GULF of MEXICO

Figure 2. Topographical map of Research Area. Data has been taken

from USGS 7.5 -minute maps using 5 foot contour intervals.

9

characterization of lithologies within each group exist (table 1), generalization of the

groups’ defining units will be the limit to which the investigation is concerned.

The base of the stratigraphic column (figure 3) is made up of the Suwanee, Ocala,

and Avon Park Limestones. Together, these formations comprise a 150 - 250 m thick

limestone unit which is commonly referred to as the Floridian Aquifer. Boundaries of this

limestone group are defined beneath by a carbonate unit containing intergranular

evaporites, and above by another carbonate unit with higher percentages of clays (Miller

and Sutcliffe, 1984).

Overlying the Floridian Aquifer are alternating sandy limestone and clay layers.

This alternation of layers is classified as a second lithological group, and is composed of

the Tampa and Hawthorn Formations. Although this intermediate group can be used as a

source of water, it is primarily made of various clays. The upper confine of the unit is

delineated by a phosphatic clay, known as the Bone Valley Formation. It is used as the

ore for the phosphate industry in the area and has been called “one of the world’s most

important sources of phosphate” (Miller and Sutcliffe, 1984). Thickness of the

intermediate unit is from 75 - 125 m , with the phosphatic clay composing the upper 10 -

20 m.

At the surface, a 10-20 m thick unit of undifferentiated sands and clays is

classified as the third lithological group of this section of the stratigraphy. It consists

primarily of surficial sands with occasional clay lenses, and is lithologically distinct from

the other two units.

10

Figure 3. Stratigraphic Cross Section of Regional Geology

A Generalized Lithological Representation of Stratigraphic Units

below Piney Point Phosphates, INC.

11

Table 1. Stratigraphic Framework (Miller and Sutcliffe, 1984)

System

Series

Stratigraphic

Unit

General

Lithology

Major

Lithological

Unit

Hydrogeologic

Unit

Quaternary Holocene,

Pleistocene

Surficial

Sand, terrace

sand,

phosphorite

Predominantly fine

sand; interbedded

clay, marl, shell,

limestone,

phosphorite

Sand Surficial Aquifer

Pliocene Bone Valley

Formation

Clayey and Pebbly

Sand; clay, marl,

shell, phosphatic

Phosphatic

Clay

Confining unit

Hawthorn

Formation

Dolomite, sand,

clay, and

limestone; silty,

phosphatic

Carbonate

and Clastic

Intermediate

Aquifer system

(Includes First

and Second

Aquifers)

Miocene Tampa

Limestone

Limestone, sandy,

phosphatic,

fossiliferous; sand

and clay in lower

part in some areas

Tertiary Oligocene Suwanee

Limestone

Limestone, sandy

limestone,

fossiliferous

Ocala

Limestone

Limestone, chalky,

foraminiferal,

dolomitic near

bottom

Carbonate

Floridan Aquifer

Eocene,

Paleocene

Avon Park

limestone

Limestone and hard

brown dolomite

Lake City,

Oldsmar, and

Cedar Key

Limestones

Dolomite and

chalky limestone,

with intergranular

gypsum and

anhydrite

Carbonate

w/

intergranular

evaporites

lower confining

bed of floridan

aquifer

12

Hydrogeology

Groundwater in the area is commonly drawn from one of the three available water

producing units described above. Flow within these aquifers is, for the most part, in the

horizontal direction with little leakage between layers. The water table in the unconfined

unit varies with precipitation and evaporation, while underlying units modulate their

potentiometric yields according to changing lateral flow from inland areas of recharge

and local points of discharge. Seasonal highs and lows of the potentiometric surfaces

have been recognized by the U.S. Geological survey (Johnson et. al., 1981) as September

and May, respectively, and are mainly associated with groundwater pumpage for

agricultural irrigation.

Comparison of the potentiometric surfaces in the southeastern United States by

Johnston et.al. (1980,1981) before and after development has shown a regional trend in

the vertical flow between aquifer units. Following extensive development of the area in

the late 1970’s, Polk County to the East had become an area of recharge whereas the

coastal area along Tampa Bay had become a zone of discharge to the Gulf of Mexico.

This trend dictates a downward flow to the Floridan Aquifer in the area of recharge, and

an upward flow in the area of discharge. Because the Piney Point facility is in the area of

discharge, there exists an upward flow gradient in the water-bearing units through their

confining beds.

Locally, groundwater is drawn primarily from the Floridan Aquifer, although the

surficial and intermediate aquifers are equally important to some. The surficial unit is

used for domestic lawn irrigation, while the intermediate aquifer system is tapped for use

as a rural domestic source of water and for agricultural irrigation. Additionally, the

13

Floridan aquifer south of the Piney Point facility contains mineralized water, and

promotes the intermediate aquifer as the primary source for municipal water.

In the studies of Miller and Sutcliffe (1982) and Miller and Sutcliffe (1984) the

aquifer system around the Piney Point complex was probed for the first time in more

detail. About forty test holes (wells) whose depths extended from the surficial,

unconfined aquifer to the intermediate, confined (artesian) aquifer were drilled around the

ponds and the gypsum stack during this study. A few older, mostly abandoned irrigation

wells that extend further down into the confined Floridan aquifer were also monitored.

Various geophysical well-logging techniques were applied in some of the boreholes to

determine the lithology of the aquifer substratum. Groundwater table elevations were

taken data during the time and three wells were monitored continuously by means of

recorders. The hydrographs for the three continuously monitored wells show sporadic

evidence of an upward hydraulic head gradient between the intermediate and the surficial

aquifer. This has been taken as evidence that potential surface contamination cannot leak

into the lower intermediate aquifer. However, during the dry season (April to June), when

the intermediate aquifer is heavily pumped for agricultural irrigation, the situation may be

reversed and a downward gradient is observed. The water elevation data shows also a

topographic mounding effect of the gypsum stack on the groundwater-level in the

surficial aquifer.

The Piney Point Phosphate Inc.'s quarterly reports of the groundwater monitoring

survey around the phosphogypsum stack to the Florida Department of Environmental

Protection (FDEP) provide some evidence of the direction of the regional groundwater

flow in the vicinity of the stack. As part of the proposed extension of the phosphogypsum

14

stack to its present-day size, Gerathy & Miller Inc. was consulted by the Piney Point Inc.

to install 7 monitor wells extending into the surficial aquifer on the premises of the

company. Most of these monitor wells are still in use today and are being sampled on a

regular basis. Figures 4 and 5 show the piezometric isolines for two particular dates and

Figure 6 illustrates the hydraulic head surface for one of these dates in 3D form. One can

observe from these figures that the groundwater flow is mainly in northwestern direction.

Moreover, the flow system in the surficial aquifer appears to be very much in steady-

state, as witnessed by the similarity of the isoline contours taken two years.

As for the hydrogeology in the phosphogypsum stack itself, only the geotechnical

study of the slope stability carried out by Oaks Geotechnical Inc. (1980) as part of the

proposed extension of the gypsum stack to its present-day size provides some

rudimentary clues about the water flow in the stack. During this study several boreholes

were drilled into the flanks of the stack and water-table levels were monitored over a

period of several months. Because the exact well construction data has not been reported

precise inferences on the stack-flow cannot be made.

15

Gypsum Stack

Buckeye Road

Chemical

Plant

SeaboardCoast

LineRailro

ad

Cooling

Ponds

MW-1

MW-7

MW-5

MW-2

MW-6

MW-4

MW-3

WC-3WC-1

WC-2

0.00 1.00 2.00 3.00 4.00 5.00 6.00

1.00

2.00

3.00

4.00

5.00

6.00

Surface Contours: Piney Point 11-4-91

Figure 4. Contour Plot of the Piezometric Heads in the Surficial Aquifer

on November 4, 1991. (contour levels are in ft)

16

Gypsum Stack

Buckeye Road

Chemical

Plant

Seaboard C

oast Line R

ailroad

Cooling

Ponds

MW-1

MW-7

MW-5

MW-2

MW-6

MW-4

MW-3

WC-3WC-1

WC-2

0.00 1.00 2.00 3.00 4.00 5.00 6.00

1.00

2.00

3.00

4.00

5.00

6.00

Surface Contours: Piney Point 9-23-93

Figure 5. Contour Plot of the Piezometric heads in the Surficial Aquifer

on September 23, 1993. (contour levels are in ft)

17

3-D Views of Hydrological Head 9-23-93

Figure 6. 3D Plot of the Piezometric heads in the Surficial Aquifer on

September 23, 1993.

18

CHAPTER 3

METHODS OF DATA ANALYSIS

Compilation of the data as well as computation for the analyses was conducted in

spreadsheet format using Microsoft Excel. Representation of this data as graphs, in

addition to a regression for the topographical analysis were done in Axum 5.0.

Modification of some figures was accomplished through use of Microsoft Paint, and

Hijaak Pro.

Phosphogypsum Stack

Identification of hydrologic flow within the phosphogypsum pile itself was carried

out through a series of investigations centered around quantifying the hydrologic

parameters of the stack material, and identifying vertical gradients between stratigraphic

layers. Ten partially screened wells and one fully screened well were drilled into the

oldest portion of the stack. The wells were set at various depths (Table 2) in two clusters

of four wells and one cluster of three. Cluster one (PP1) in the west wall and cluster three

(PP3) in the center of the stack along an old working road wall had four wells, while

cluster two (PP2) in the south wall only had three wells (figure 7). The gypsum-aquifer

interface (base of the stack) is at a depth of 20.8 m from the surface, so there is only one

well which taps the surficial aquifer through the gypsum stack

19

00 300300 600600

Seaboard C

oast Line R

ailroad

Seaboard C

oast Line R

ailroad

82 32’82 32’

LakeLake

CoolingCooling

PondsPonds

Buckeye RoadBuckeye Road

55 22

S2

4A4A

38’38’R1

33

CHEMICALCHEMICAL

PLANTPLANT

R2

N

1616 1515

1717

99

10101111

1212

1414

39 39

33

3838 3737

1313

2727OO

41

1818 1919

2020

2121

2222

2424

2323

S1

New PhosphogypsumNew Phosphogypsum

Ponds Ponds

88 11

77

3636

3434

2323

Old Old

PhosphogypsumPhosphogypsum

PondsPonds

Figure 7 - Locations of Monitoring Wells at Figure 7 - Locations of Monitoring Wells at Piney Point Phosphates, Inc. Palmetto, FloridaPiney Point Phosphates, Inc. Palmetto, Florida

DIAMMONIUMDIAMMONIUM

PHOSPHATEPHOSPHATE

PONDPOND

Scale (meters)Scale (meters)

9, 10, 119, 10, 11

Research WellsResearch Wells

Surface Sample SiteSurface Sample Site

Rainfall Sample SiteRainfall Sample Site

Old PiezometersOld Piezometers

PG Stack WellsPG Stack Wells

LegendLegend

USGS WellsUSGS Wells

00

Monitor WellsMonitor Wells

(AMAX)(AMAX)

88

TT

UU

KK JJ

110110

131315156a6a

99

1010

1111

20

Table 2 - Depths of Sampling Wells Drilled into the Stack

Cluster # - Well #

Total Well Depth

(in m. from top of

riser)

Cased

Section

(m. depth)

Screened

Section

(m. depth)

1 - 1 18.0 0 - 14.8 14.8 - 18

1 - 2 14.8 0 - 12.5 12.5 - 14.8

1 - 3 12.5 0 - 9.5 9.5 - 12.5

1 - 4 9.5 0 - 6.6 6.6 - 9.5

2 - 0 23.6 0 - 22.0 22.0 - 23.6

2 - 1 18.0 0 - 14.8 14.8 - 18.0

2 - 2 14.8 0 - 12.5 12.5 - 14.8

2 - 3 11.5 0 - 8.2 8.2 - 11.5

3 - 1 18.0 none 0 - 18.0

3 - 2 14.8 0 - 12.5 12.5 - 14.8

3 - 3 11.5 0 - 8.2 8.2 - 11.5

All wells were constructed with a 10 cm. diameter PVC pipe. Screens were

packed in 20-30 mesh sand with approximately 50 cm of bentonite hole plug overlying

the sand pack except for the PP 2-0 well which has a 2m thick bentonite plug over the

sand pack. The risers were grouted to the surface with a bentonite-cement mixed grout

compound. For the fully screened well PP 3-0 grout-plugs were set at intervals of 1.5m,

in order to reduce the possibility of vertical outer-borehole flow which could corrupt the

borehole flowmeter tests.

Quantification of hydrologic parameters within the stack was determined by one

of the most commonly used non-equilibrium pump tests, the Cooper-Jacob (straight-line)

method. This method was used over the more popular Theis-curve match for its

asymptotic approximation of the well function for a small radius and long times, because

21

it is important to rule out the bias of values representative of the region directly around

the well. A Grundfos 1.2-amp pump was used to pump water out of the well at an

approximate rate of 6 L/min., and head measurements were taken with an electrical head

level indicator.

Hydraulic gradients within the stack were determined by using a pressure

transducer, a new electromagnetic borehole flowmeter (Molz et al., 1994) , and through a

comparison of hydraulic head values. Due to the significance of a hydrologic gradient for

the understanding of the flow system in the stack, the use of these different methods

should increase the reliability of the results obtained.

In situ vertical head measurements were made using a set of inflatable packers

bought from the Tennessee Valley Authority, and a 20 psi pressure transducer from Telog

Instruments, INC. Inflation of the packers above and below the pressure transducer

allowed a section of the well to be isolated, and a reading to be taken. Measurements of

the in situ pressure were taken at all screened intervals possible, along with 3 - 5 cased

intervals (to provide a standard hydrostatic gradient upon which to compare the screened

readings). Variations of anomalous readings in the screened sections were correlated with

the presence of a pressure perturbation (i.e., a flow gradient).

Borehole flowmeter tests were conducted by Quantum Engineering Corporation

using the deepest well of each stack cluster. Ambient flow, induced flow, and pump test

measurements were conducted at all wells; however, a complete analysis was only done

for well 1-1. Results for wells 2-1 and 3-1 were incomplete, owing to the onset of a

thunderstorm the day that the measurements were taken. Results from this testing have

provided data for ambient flow direction and magnitude, as well as response of various

22

vertical sections of the stack to induced flow conditions. Utilization of these induced flow

rates with the measurements for net flow can also be used

Hydraulic head measurements for the monitoring wells on the stack were taken

approximately every three months. Because wells in the same cluster were fairly close

together, comparison of the head measurements were used to indicate possible variations

of head gradients in the vertical direction within the stack. Organization of the data as a

cross-sectional view provided information on internal stack-stratification.

Surficial Aquifer

Analysis of the hydrology in the surficial aquifer includes calculations of

hydraulic conductivities and transmissivities, a contour analysis of monitoring well head

levels, and regional flow gradients in the surficial aquifer. Primary interest of this

research was to quantify horizontal flow rates in the surficial aquifer, as well as to

establish the direction of flow in an attempt to determine the hydraulic impact of the

phosphogypsum stack on the surficial aquifer.

Hydraulic conductivity analyses were conducted by two different analytical

methods, allowing for respective well geometries that were available. USGS well #9

(figure 7) was treated as an auger hole, while all other research wells were drilled to be

partially screened for their lowest 10 feet.

The hydraulic conductivity for the auger hole was calculated according to a

method prescribed by Boast and Kirkham (1971). The well was pumped out by a Grunfos

machine, and the water table (i.e. head) allowed to rebound over the next hour.

23

Measurements of the rebounding head elevation were taken with a conductive measuring

tape, and entered into in a spreadsheet calculation program.

The analysis for the partially penetrating monitor wells was conducted on

proprietary wells 1 and 8, and research wells 11, 18, 21, 22, and 24, using a method

described by Bouwer and Rice (1976). A volume of approximately 200 liters was pumped

out of each well using a Grunfos machine, and then the well was allowed to recharge. As

the hydraulic head rebounded, elevation measurements were taken and imported into a

spreadsheet program.

The contours of the water table on site were compiled every three months using

hydraulic head elevations taken from the following wells : proprietary wells 1 - 5, 8-11,

research wells 8 - 24, U.S.G.S. wells 8, 9, 34, 36, 37, 39, and stack well 2 - 0. Data files

were entered into the Surfer program, and contours generated using the Kriging method.

Because of the importance of the head measurement at well 2-0 (which wasn’t drilled

until March 1996), only contours for months that include measurements at this well are

presented.

The regional flow of the surficial aquifer is partly controlled by the confining unit

beneath it, and its direction and gradient was estimated through an assumption of a

consistent surficial aquifer thickness. Because of a lack of monitor wells further away

from the phosphogypsum stack that would have allowed to properly define the

groundwater gradient the standard assumption was made that the regional flow in the

surficial aquifer is primarily determined by the topographic slope of the land surface. To

determine the latter a three-dimensional regression of the drainage basin using an

equidistant node grid of elevations was made, leading to a first-order representation of the

24

regional flow without the mounding effect of the phosphogypsum stack.. Calculations of

the topographic plane were made in the AXUM graphing program using a collection of

data points taken from topographical maps of the area (figure 3). The transects for the

data point collection were made at a one unit interval (representing 200 m.) of plotted

data in an AutoCAD drawing.

The precipitation for the area was measured daily at stations on site, and at the

U.S.G.S. stations in Ruskin (10 miles to the north), and Bradenton (5 miles to the south).

These data were compared to monitoring well heads and stack pond levels in hydrograph

format. In addition, these hydrographs were analyzed for temporal and spatial relevance

to the possible recharge of the aquifer and the phosphogypsum stack..

25

CHAPTER 4

CHARACTERIZATION OF THE HYDROLOGICAL ENVIRONMENT

This chapter presents the results of the hydrologic characterization of the gypsum

stack and the underlying surficial aquifer, including an analysis of the regional

precipitation data. These characterizations are necessary for the parameter adjustments of

the groundwater model presented in the following chapter. Data are presented in

Appendices I, II, and III.

Stack Analysis

Analysis of Hydraulic Heads

Hydraulic head measurements for all three well clusters demonstrate a downward

flow in all instances. Specific gradients between stratigraphic layers of the gypsum stack

can be made for each of the well regions, as well as a determination of the flow gradient

to the surficial aquifer. Patterns of relative head do not change over time, but can be

correlated to the precipitation record (presented at the end of this chapter).

Well cluster 1 (figure 8) shows a typical illustration of gradualized downward

flow. The occurrence of a slight plateau between wells 1-2 and 1-3 points to a region of

slower flow when compared to the neighboring head gradients to wells 1-1 and 1-4.

Well cluster 3 (figure 9) illustrates flow toward the screening depth of well 3-2,

which is conceptually consistent with well cluster 1, because even though well 3-1 is the

deepest of the three wells, it is fully screened. Thus, head measurements are responding

26

0 2 4 6 8 10 12 14

Distance (m)

0.0

2.5

5.0

7.5

10.0

12.5

15.0

17.5

20.0

22.5

25.0

Hyd

rau

lic

Hea

d E

leva

tio

n (

m A

SL

)

7 / 18 / 95

11 / 15 / 95

2 / 9 / 96

3 / 25 / 96

5 / 6 / 96

9 / 19 / 96

1-1 1-2 1-3 1-4

Gypsum / Aquifer Interface

Figure 8. Hydraulic Head Comparison for Well Cluster 1. A general

downward gradient is found in consecutively deeper wells.

27

0 1 2 3 4 5 6 7 8 9 10 11

Distance (m)

0.0

2.5

5.0

7.5

10.0

12.5

15.0

17.5

20.0

22.5

25.0H

yd

rau

lic H

ead

Ele

va

tio

n (

m M

SL

)

7 / 18 / 95

11 / 15 / 95

2 / 9 / 96

3 / 25 / 96

5 / 6 / 96

5 / 26 / 96

9 / 19 / 96


3-1 3-2 3-3

Figure 9. Hydraulic Head Comparison for Well Cluster 3. A

downward gradient is found toward well 3-2, which represents a head

level for the deepest section of screening in the gypsum stack.

according to their highest screened elevations and force downward flow gradients

between all wells.

28

Well cluster 2 (figure 10) is of particular significance due to well 2-0, which is

drilled into the surficial aquifer. Gradients between all wells are still downward, which

also includes down into the surficial aquifer. The presence of a gradient toward well 2-0

provides one of the most critical factors needed for a distinction of flow into the surficial

aquifer; however, the relative magnitude of the actual gradient and of the hydraulic

conductivity will determine the flow velocity and the fluxes of stack water that can seep

into the surficial aquifer. A comparison to surficial aquifer head levels, as well as

quantitative modeling of flow rates, will provide a clearer picture of the factors

controlling the hydrological environment here.

Cooper-Jacob Straight-line Method

Transmissivity and storativity values were determined through a modification of

the Cooper-Jacob equation. The latter represents an asymptotic solution for large times t

of the Theis equation which describes the radially symmetric, non-equilibrium head-

drawdown s(r,t) in a confined aquifer as a function of the radius (distance) r and time t

under the influence of pumping. The Cooper-Jacob equation is then (Driscoll, 1986):

s r tQ

Tu( , ) ( . ln )= ⋅ − −

40 57772

π (4.1a)

29

0 1 2 3 4 5 6 7 8 9 10

Distance (m)

0.0

2.5

5.0

7.5

10.0

12.5

15.0

17.5

20.0

22.5

25.0H

yd

rau

lic H

ea

d E

levati

on

(m

MS

L)

7 / 18 / 95

11 / 15 / 95

2 / 9 / 96

3 / 25 / 96

5 / 6 / 96

5 / 26 / 96

9 / 19 / 96

2-0 2-1 2-2 2-3


Figure 10. Hydraulic Head Comparison for Well Cluster 2. A

downward gradient is found into the surficial aquifer represented by

well 2-0.

By substituting for the expression ur S

Tt=

2

4, and converting to log base-10 format one

gets the following equation:

s r tQ

TLog

Tt

r S( , )

.( . )= ⋅

2 3

42 25

2π

(4.1b)

30

By obtaining the drawdown s(r,t) observed in one log unit (figures 11 and 12), and a

known value for the pumping rate Q, a value for the transmissivity can be calculated for

the wells that were pumped (i.e. PP1-2, PP2-2, and PP3-1).

The storativity S is determined from the intercept time t_0 which corresponds to a

zero drawdown s=0 (i.e is obtained by setting the log-term equal to one). The intercept

time t_0 is depicted graphically from the intercept of the straight line tangent to the

Table 3. Transmissivity and Storativity Values for Stack Wells

Well Designation Transmissivity

(m2/day)

Storativity

1 - 1 16.163 0.00009143

1 - 2 6.883 -

1 - 3 47.638 0.00001568

1 - 4 90.512 0.00008784

2 - 1 2.526 0.00006698

2 - 2 0.846 -

3 - 1 0.445 -

3 - 2 10.842 0.00001706

3 - 3 32.526 0.000008922

31

10-1 2 3 44 5 6 100 2 3 44 5 6 101 2 3 44 5 6 102 2 3 44

Time (min)

12

11

10

9

8

7

6

5

4H

yd

rau

lic

Head

(m

)

Figure 11. Pump Drawdown vs Time in Stack Well 2-1. Of particular

note is the recharge that occurs in the data between 50 and 80 minutes

of pumping

32

2 3 4 55 6 100 2 3 4 55 6 101 2 3 4 55 6 102 2 3 4

Time (min)

6.8

6.6

6.4

6.2

6.0

5.8

5.6

5.4

5.2

5.0

Hyd

rau

lic

He

ad

(m

)

Figure 12. Pump Drawdown vs Time in Stack Well 2-2. Of particular

note is the recharge that occurs in the data between 65 and 90 minutes

of pumping.

33

drawdown curve with the horizontal axis. Values for the storativity S cannot be

determined for the wells that were pumped, since there is a singularity in the solution for r

=0.

Even though transmissivity values for only three of the stack wells were obtained

(Table 3), the wide range found indicates a variation of the transmissivity throughout the

stack. This variation may be caused by modification of the stack structure during

structural maintenance of the stack, whereby gypsum material from the pond is dug out to

strengthen the confining walls. The transmissivity value for well 3-1 is the best

representation of conductivity for the stack as an entire unit (owing to the well’s

representative screened length), while the values for wells 1-2 and 2-2 are more indicative

of particular horizons within the stack.

Storativity values are well constrained, with all values falling within one log unit.

An average of 4.8 x 10-5 denotes a value comparable to that of natural gypsum,

indicating that the waste material maintains storage properties similar to that of its

chemically related compound.

Although drawdown curves for most of the analyses are typical of a normal

aquifer response, wells 2-1 (figure 11) and 2-2 (figure 12) demonstrate a plateau in their

data close to the equilibrium stage of pumping. This occurrence has been classified as an

influence of recharge, resulting from a proximity to the stack pond. Additionally, the

delay observed between the wells is attributed to the recharge occurring closer to the

pump source. On the other hand, the plateau at well 2-2 is less dramatic because it is on

the perimeter of the drawdown influence.

34

Pressure Transducer Tests

Investigation with the pressure transducer was intended to provide an

identification of horizontal flow within the stack interior. Complete analysis of the

pressure at every depth in all three cluster areas was not possible because of the limited

range provided in the screened sections. Regardless of this restriction, anomalous

horizontal flow was identified in three of the wells. Wells 1-3 (figure 13) and 3-

1 (figure 14) illustrate sections of decreased ambient pressure, while well 3-2 (figure

15) demonstrates a single section of increased pressure. All other wells showed no

deviation from the hydrostatic reference pressure, as computed from the density of the

gypsum stack-water solution, indicating no significant vertical variations of the pressure

and the hydraulic heads in those depths. This means that either there is no significant

amount of vertical flow in that depth-section of the stack that would lead to a detectable

amount of vertical pressure head gradient, or the pressure transducer is just not sensitive

enough to pick it up.

The low pressure zone found at well 1-3 is on the west wall indicating the

presence of a vertical flow gradient at depths approximately 10 m below the surface.

Analysis of well 2-1 examines the same interval on the south wall, but does not indicate

flow different from the expected hydrostatic reference. Thus, no support for a conclusive

statement on the stack edges can be made, but the possibility for flow still exists.

Measurements made at well 3-1 were conducted in a different manner, owing to

the fully screened section of the well. Comparison to unpacked pressure readings instead

35

0 2 4 6 8 10 12 14

Pressure (PSI)

14

12

10

8

6

4

2

De

pth

be

low

Wa

ter

Ta

ble

(m

)Well 1-3

Hydrostatic Norm

Cased Section

Screened Section

Figure 13. Pressure Transducer Measurements for Well 1-3. Deviation

of readings in the screened section (9.5 - 12.5 m.) below the

hydrostatic norm show a regional decrease in ambient pressure.

36

0 2 4 6 8 10 12 14 16 18 20 22

Pressure (PSI)

20

18

16

14

12

10

8

6

4

2

0

De

pth

be

low

We

ll R

iser

(m)

Packers are used

Packers are not used

Your Text

Your Text


of readings in two sections below the hydrostatic norm (no packers

used) show a regional decrease in ambient pressure.

37

0 2 4 6 8 10 12 14 16

Pressure (PSI)

16

14

12

10

8

6

4

2D

ep

th b

elo

w W

ate

r T

ab

le (

m)

Well 3-2

Hydrostatic Norm

Cased Section

Screened Section


of readings in the screened section (12.5 - 15.0 m.) above the

hydrostatic norm show a regional increase in ambient pressure.

of a hydrostatic line allows a broader interpretation of the readings; however, two areas of

pressure anomalies are still apparent. Lower pressures found in the “packed”

measurements from 2 - 8 m. are most likely an influx of fluid flow from the nearby pond,

38

whereas spikes found at depths of 16.5 and 18.0 m. are more of a mystery. This

development is either evidence of poor field methods, or an indication of a flow conduit

The latter would suggest cracks or faulting at the intervals of the spikes, although the

large contrast in pressure would suggest that this explanation is unlikely. Therefore, the

spikes are interpreted as evidence of poor grouting of the well, whereby flow can seep

vertically between the outer side of the borehole casing and the back-fill formation..

The high pressure zone of well 3-2, at an approximate depth of 13 - 15 m is quite

important since it is located in the center of the stack between the north and south ponds.

This reading is an indication of an increase in overburden pressure and is evidence for the

conceptualized flow of a typical groundwater mounding model. Because of the fact that

this anomaly is located close to the low pressure anomaly found in well 3-1, the

measurements do not support a regional characterization of downward flow. Thus,

conflicting evidence from both wells indicates heterogeneity of the gypsum stack at

depth. However, because well cluster PP 3 is located essentially at an old pond

construction road, there is also the possibility that some of the observed anomalies do not

reflect the phosphogypsum formation alone, but also the compacted back-fill material

of the road.

Borehole Flowmeter Tests

The Borehole Flowmeter Tests (cf. Burnett et. al., 1985 for details) yield the

following three major pieces of information:

39

1) Ambient flow in the well under natural conditions. The nature of the ambient flow,

especially its direction, provides clues on anomalous fracture and fault zones and

vertical variations of the hydraulic heads.

2) Flow rates for each vertical section under steady-state pumping conditions.

3) Using the results from 1) and 2) vertical variations of the net flow rate in each of the

probed intervals that are directly proportional to the hydraulic conductivity K in that

vertical aquifer section.

Ambient flow measurements for both well 1-1 (figure 16) and well 3-1 (figure 17)

provide strong support for a natural, downward flow of fluid in the stack. This evidence

enhances the theory for topographical mounding of stack waters on the surficial aquifer,

and clarifies specific internal heterogeneities at particular depths. The ambient

differential readings of well 3-1 illustrate this point; readings fluctuate throughout the

stack. These flow inconsistencies indicate that localized fracturing and/or bedding

planes control flow.

A gradual decrease in the ambient flow is noted for both wells near the stack base,

and is important to qualifying the significance of any topographical mounding. Although

this trend is typical of unconfined units, its utilization in clarifying the permeability of the

surficial aquifer interface is critical. Understanding of flow beneath the interface will

determine whether this decrease is a product of an impermeable boundary, or the result of

an unconfined situation.

40

Figure 16. Borehole Flowmeter Results for Stack Well 1-1. Positive

values denote downward flow and negative values upward flow.

41

Figure 17. Borehole Flowmeter Results for Stack Well 3-1. Positive

values denote downward flow and negative values upward flow.

Induced pumping of the wells was undertaken in an attempt to investigate the

response of the aquifer to such conditions and to quantify possible vertical stratifications

of the hydraulic conductivity within the stack, as might be indicated by the presence of

bedding planes that are clearly visible at the stack. As depicted in well 3-1, changes in

42

increase of the net flow (or 2x net flow) denote a region of varied hydraulic conductivity.

This finding gives strength to a theory of the stack as a layered hydraulic structure, with

varying conductivities in different layers. Absolute values for these conductivities could

be calculated from a more complete set of values determined by the Cooper-Jacob Test,

along with the specific thicknesses of various identifying layers. However, this task has

not been carried out here since layered stack conductivities will not be required as an

input parameter in numerical mounding model to be presented in the next chapter .

Surficial Aquifer

Regional Flow Trend

The regression plot of topographical data (figure 18) taken from figure 3 denote a

flow gradient of 1.977 x 10-3

at an azimuthal direction of 303.19 0

. This gradient is at

such a low angle that localized influence of the water table will be a large factor on the

direction and speed of flow. Thus, these results may not represent small-scale flow

patterns and gradients for the area, but they do give the best approximation for a

generalized regional flow pattern. In addition, topography around the gypsum stack

complex is relatively flat, so that the resulting gradient from this calculation is still a good

representation of ambient conditions.

43

z = 21.619485 + 0.001655*x -0.001083*y

Figure 18. A 3-Dimensional Regression Plot of Topographic Data. The

above equation represents the trending plane in units of meters,

although the slope and direction of the plane is determined by the x

and y coefficients, which do not change. Resulting slope and

direction of the regression plane are approximated as regional flow

characteristics of the surficial aquifer, due to a consistent thickness of

the unconfined layer.

44

Water Table Contours

Contours of hydraulic heads for surficial aquifer monitoring wells are greatly

impacted with the addition of well 2-0. Thus, accurate representation of the water table in

the unconfined zone cannot be made without inclusion of a measurement taken at this

well. Contours for measurements taken on May 6, 1996 (figure 19) and November 8,

1996 (figure 20) are typical of other data sets analyzed, and represent the extent of values

found in the calculation of the water table for the surficial aquifer. Additional contours

drawn from measurements at other sampling dates are depicted in appendix III.

Most significant of the contouring plots is the influence of the head-reading taken

at well 2-0. The gradient between its location and other monitoring wells, namely,

wells MW 1, RW 8, 11, 18, 21, 22, & 24 is indicative of a flow in the vertical

direction, as well as a flow away from the gypsum stack in almost all horizontal

directions; though flow to the southeast is hindered due to the opposing force of regional

flow. A water table low in the southwest quadrant may be the result of the cooling pond

and the ditch system in that area. Presence of the ditches draws water flowing toward

them to be evaporated and essentially taken out of aquifer system. Thus, the

existence of the evaporating system leads to a lowering of the local water table.

Conductivity Analysis

Kirkham Auger Hole Test

Hydraulic conductivity of the well designated as USGS 9 was determined

following the so-called auger hole method described by Boast and Kirkham (1971) and

45

0 250 500 750 1000 1250 1500 1750 2000 2250 2500 2750

East - West (m)

0

250

500

750

1000

1250

1500

1750

2000

2250

No

rth

- S

ou

th (

m)

Figure 19. Contour Plot of the Surficial Aquifer on May 6, 1996.

Asterisks represent well measurements upon which the contour is

based. Noteworthy characteristics of the map include a large head

value at well 2-0 and regional low in the southwest quadrant.

46

0 250 500 750 1000 1250 1500 1750 2000 2250 2500 2750

East - West (m)

0

250

500

750

1000

1250

1500

1750

2000

2250N

ort

h -

So

uth

(m

)

Figure 20. Contour Plot of the Surficial Aquifer for

September 19, 1996. Asterisks represent well measurements upon

which the contour is based. Noteworthy characteristics of the map

include a large head value at well 2-0 and a regional low in the

southwest quadrant.

Amoozegar and Warrick (1986). This calculation dictates a relationship between the

drawdown (y), time (t), and hydraulic conductivity (K) in the following equation :

47

K r C t t y yi i i i= −+ +

{ / [ ( )]} ln( / )π2

1 1 (4.2)

The hydraulic conductivity is in units of cm/sec, and is compared to known ranges of

unconsolidated material (Bear, 1979). C is a shape factor that is commonly referred to as

a constant of the equation. Three variables are used to calculate the value of C/r in

equation 4.2 :

(1)- the ratio of the cavity height to the well radius,

(2)- the ratio of the cased well section to the well radius, and

(3)- the ratio of the impermeable layer depth beneath the cavity to the well radius.

Although the geometry of USGS 9 does not allow the determination of a constant

from known values (Youngs, 1968), a log base E curve-fit of these values (figure 21) was

able to obtain a viable solution for many ratios of the cavity height to the well radius

hc/r. Based on the most likely geometry of the well, the “hc/r=0” curve was selected as

the most reliable one. Using this type-curve a hydraulic conductivity in the range of

0.00075 - 0.00190 cm./sec. was determined, which is in the range of two geomorphic

classifications : clean sand ( 1 - 10-4

) and silty sand (10-1

-10-5

).

48

0 10 20 30 40 50 60 70 80 90

H/r Ratio

0

5

10

15

20

25

30

35C

on

sta

nt

C/ r

0

.5

1

2

4

8

hc / r Ratio

34.16 - 2.417*ln x

22.94 - 1.443*ln x

15.96 - 0.749*ln x

12.22 - 0.5549*ln x

10.1 - 0.4792*ln x

5.976 - 0.1349*ln x

Figure 21. Determination of Shape Factor C/r by a Natural log

Curve-fit. Approximation of the shape factor for large H/r values was

needed in calculating the conductivity for USGS well #9.

Bouwer Rice Test

Procedure for the pump analysis of wells 2-0, MW 1, RW 8, 11, 18, 21,

22, & 24 followed a “slug” recovery method, developed by H. Bouwer and R.C. Rice

49

(1976) This procedure takes into account the partially screened nature of many

monitoring wells (figure 22) in the calculation of hydraulic conductivity, and allows a

spatial analysis of conductivities around the site.

The Bouwer / Rice theory is based upon a modification of the Thiem equation to :

Q K Ly

R Re w

= 2πln( / )

( 4.3)

where Q is the volume of water flowing into a well at a specific depth y, K is the

hydraulic conductivity, L is the length of the screened section, and Re/Rw is a ratio of the

effective radius of the pumping influence over the effective radius of the well (including

the grouted radius). The rate of water level rise (dy/dt) can be represented as :

dy dt Q rc= − π2

( 4.4 )

where rc is the radius of the cased well section. Insertion of equation 4.4 into 4.3,

followed by integration will produce :

lnln( )

yKLt

r R Rc e w

= − +2

2constant ( 4.5 )

Applying this solution for limits yo and yt where t = 0 to t while solving for K yield the

finalized equation that was used :

Kr R R y y

Lt

c e w t=

2

0

2

ln( ) ln ( ) (4.6 )

50

Figure 22. Generalized Well Geometry of a Partially Screened Well.

Note values for H,L, and D.

Although most parameters are easily determined in the calculation, ln (Re/Rw) is

somewhat variable within various geologic environments. More specifically, the effective

51

radius of influence will vary in relation to the depth of the underlying confining unit

below the bottom of the well. Bouwer and Rice (1976) determined that ln (Re/Rw) varies

inversely with ln [H / Rw] and linearly with ln [(D-H)/ Rw]. Results enabled derivation of

the following two equations: eq. 4.6 for partially penetrating wells and eq (4.7) for

completely penetrating wells (where D-H = 0).

ln.

ln

ln /R R

H R

A B D H R

L Re w

w

w

w

= ++ −L

NMM

OQPP

−

111b g (4.6 )

ln.

lnR R

H R

C

L Re w

w w

= +LNM

OQP

−

1 11

(4.7 )

Coefficients A, B, and C from equations 4.6 & 4.7 are resolved by a relationship that has

been determined through an electrical node analysis (figure 23) presented in Bouwer and

Rice (1976).

In addition to the determination of the value for ln (Re/Rw), hydraulic head values

were graphed against time in a log plot (figure 24) (additional graphs are depicted in the

appendix IV). The resulting slope of the line determined an average value for ln(yo/yt)/t to

be used in the calculation of the hydraulic conductivity.

Results for the hydraulic conductivities determined by this method (Table 4)

characterize three zones of regional conductivity. Well 2-0 represents an area of a low

conductivity (1.3 x 10-5

cm/sec) for the region beneath the stacks, while higher

conductivities (mean ~ 3.9 x10 -4

cm / sec) are found in wells to the Northwest (RW 18,

52

Figure 23. Relationships of A, B, & C for the Calculation of Re/Rw. Using the formulas from the Bouwer/ Rice method, a range of

possible conductivities were determined for the pump analyses.

53

0 240 480 720 960 1200 1440 1680 1920 2160 2400

Time (sec)

0.010

0.100

1.000

8

2

3

4

567

9

2

3

4

556

8

2

3

4D

raw

do

wn

(m

)

Figure 24. Drawdown vs. Time Plot for Well 18. The slope of the dashed

line above is used in the calculation of conductivity as the value for

log (yo/yt)/t.

21, 22, 24). Southward of the stack (MW 1, USGS 9, RW 8 & 11) moderate values for

conductivities are found (mean ~ 1.3 x 10 -4

cm/sec). A comparison of the

conductivities for the wells in the south to those in the northwest shows that the highest

54

conductivities are determined for RW 18 & 24, where values are 3 - 4 times higher than

the mean for the more southern wells. This is peculiar in relation to the wells’ proximity

to the influence of the stack, but the difference can be attributed to variations in the local

geologic composition of the surficial aquifer.

Table 4. Conductivity Ranges for Surficial Aquifer Wells. Units for all values are in

cm./sec, with maximum and minimum values approximated from individual

slopes between head values in the drawdown plots.

Well Mean Minimum Maximum

PP 2- 0 0.0000131 0.0000093 0.0000136

MW 1 0.0001290 0.0000900 0.0001620

MW 8 0.0000710 0.0000360 0.0001690

USGS 9 0.0001480 0.0001330 0.0002290

MW 11 0.0001700 0.0001100 0.0003480

MW 18 0.0006130 0.0002100 0.0007690

MW 21 0.0002440 0.0001700 0.0003090

MW 22 0.0002590 0.0001130 0.0003180

MW 24 0.0004370 0.0002770 0.0006960

Precipitation

Precipitation records from all three available sources indicated that each was

unique in its measurements, and that not all of the sources could be relied upon in

correlation with the hydrologic system in the stack area. Thus, records from on-site

measurements for 1995-1996 were relied upon in the correlation to precipitation, while

readings from Bradenton and Ruskin were not considered.

55

Precipitation measurements showed a high degree of correlation to stack pond

levels (figure 25) and monitor well levels (figure 26). Therefore, hydrologic controls of

these water bodies were considered to be at relative equilibrium with their environment.

Water-table levels of the stack pond were shown to be very small on a monthly scale and

found to impact ambient levels only during large precipitation events, as depicted in the

records for October of 1994. Water-table elevations in monitoring wells are seen to

recover within weeks, owing to the high conductivity of the sandy composition in the

surficial aquifer.

Annual precipitation for 1995 was 159.2 cm. with the highest monthly records in

July and August, and the lowest in the months of December and January. Precipitation

highs and lows are attributable to seasonal variations, with large annual numbers due to

the area’s latitude and proximity to the Gulf of Mexico. Annual totals are minimally

variable from year to year, and consistent in their pattern of distribution each month.

In summary, precipitation has been highly variable spatially over the area but

similar in annual totals. This will, of course, lead to localized variations of the recharge

flux into the hydrologic environment (i.e. the gypsum stack and the surficial aquifer) from

day to day, but should even out when considered on a regional scale over longer periods

of time. Large precipitation events will impact hydraulic head levels in the stack ponds

for months, while influences on the surficial aquifer are found to only last weeks.

56

1-94

2-94

3-94

4-94

5-94

6-94

7-94

8-94

9-94

10-94

11-94

12-94

1-95

2-95

3-95

4-95

5-95

6-95

7-95

8-95

Date (monthly total)

0

2

4

6

8

10

12

14

16

18

Pre

cip

itati

on

(in

)

74

75

76

77

78

79

Old

Po

nd

Ele

vati

on

(fe

et)

53

54

55

56

57

58

59

60

61

62

New

Po

nd

Ele

va

tio

n (

fee

t)

Old North

Old South

New North

New South

Figure 25. Comparison of Precipitation Records to Stack Pond

Elevations. Correlation between the records is important for

October of 1994.

57

2-223-8

3-224-9

4-235-7

5-216-4

6-187-2

7-167-30

8-138-27

9-109-24

Date

3

4

5

6

7

8

9

10H

ead

Level (f

t)

0

1

2

3

4

Pre

cip

itati

on

(in

.)

MW11

MW10

MW9

RW 13

MW3

RW 15

RW 16

MW4

RW 17

MW8

Precip.

Figure 26. Comparison of Precipitation Records to Monitor Well

Levels. Correlation between the records is important during mid-

June.

58

CHAPTER 5

GROUNDWATER FLOW MODEL

Description of the MODFLOW model

Groundwater flow at the Piney Point facility was simulated using Processing

Modflow for Windows (1994), a computer-simulation software package (hereinafter

referred to as MODFLOW) that utilizes a three-dimensional, modular finite difference

method, first developed by McDonald and Harbaugh (1988) for the U.S. Geological

Society. This modeling practice makes use of a nodal network, whereby each node

represents a hydraulic head and is modified through adherence to aquifer parameters (i.e.,

hydraulic conductivity and transmissivity ) and environmental constraints (i.e., ditches

and ponds, recharge from precipitation and evaporation ). These simulations may be run

under transient or steady-state conditions; however, only steady-state solutions are

considered here.

Mathematical Theory

Modflow simulates groundwater flow under the assumption of constant fluid

density, and generates head values for each node within its environment by solving the

following partial differential equation (groundwater flow equation) for the hydraulic head

h as a function of space (x,y,z) and time t (cf. Anderson and Woessner, 1992):

∂

∂

∂

∂

∂

∂

∂

∂

∂

∂

∂

∂

∂

∂xK

x

h yK

y

h zK

z

hS

h

tRx y z s( ) ( ) ( )+ + = −

(5.1)

59

where Kx, Ky, and Kz are hydraulic conductivity values in the x, y, and z coordinate

directions, Ss is the specific storage of the geologic unit, h is the hydraulic head, and R is

a generalized sink / source term of external nature to the system (Anderson and

Woessner, 1992).

Eq. (5.1) is used in its steady-state form by setting the dh/dt-term on the right side

to 0. The resulting steady-state groundwater flow equation changes then to the Poisson

equation which is then integrated by a finite-difference method whereby discrete head

values at each node, by using information from neighboring nodes, are iterated through

the equation until the head change between two consecutive iterations is less than a

chosen value. The numerical procedure used for the iteration process was the

Preconditioned Conjugate Gradient method.

Design of the Flow Model

The Conceptual Model

Primary consideration for the design of the conceptual model was to isolate the

stack-surficial aquifer boundary in the environment, so that a determination of the

hydrologic flux between these two units could be made from the simulated hydraulic

conditions.

The model is comprised of two layers that represent the two aquifer units being

studied: The stack and the surficial aquifer (figure 27). The overlying stack layer consists

of two regions of 8 and 15m thicknesses, representing new and old stack accumulations,

60

respectively (figure 28), while the surficial aquifer layer is constructed as a flat-lying bed

of a constant 10 m thickness. Regions of the top layer not representing a gypsum unit are

designed to be insignificant through construction as a very thin unit (1 mm) with high

hydraulic conductivity; thus, any water contained within each unit is drained immediately

into the underlying layer and is of no consequence to any other head values.

Topography of the land surface will vary at the site, but it will have no influence

upon the hydrologic head because this value in an unconfined unit will be impacted more

by elevation of the water table. Thus, the effect of stack control on head levels in the

surficial aquifer are just as easily modeled impacting a topographically flat geologic unit

as a varied one.

Grid geometry

The simulation of the stack environment encompasses an area of 1183.36 hectares

and is organized into 6400 cells on an 80 x 80 unit grid (figure 28) . Each of the unit cells

is in a square configuration with dimensions of 43 m x 43 m, and models an actual land

surface of 1849 m2. Although the gypsum stack represents only 6.1% of the total grid, a

large modeling area was intended so that boundary conditions of the modeled

environment would not have any major effect on head values in the stack region.

61

Figure 27. Vertical Cross-section of the Modeled Environment. Actual

representation of the environment is made with each rectangle

representing a unit cell.

62

Figure 28. Specification of Layer 1 Regions. Pink cells are representative

of values in the old stack, blue cells for values in the new stack, and

green cells for the designation of insignificance in the top layer.

63

Hydrologic Parameters

Values for the hydraulic conductivities in both layers are adjusted so that the

horizontal component is calculated from the horizontal conductivity and thickness values

specified, while the vertical component is modeled in the model over the leakance values

between the stack and the surficial aquifer. The leakance value for the stack is varied in

the range of 1.0 x 10-2

- 1.0 x 10-3

day -1

, while the value at the bottom of the surficial

aquifer is specified five orders of magnitude lower, owing to the presence of the

confining Bone Valley formation. Horizontal conductivity in both units were defined

from the results of the aquifer pump tests; essentially, these estimations include the

transmissivity found for well 3-1 (0.443 m2/day) and the average of the conductivities

measured at the north and south monitoring wells (1.3 x10-6

m/s & 3.9 x10 -6

m/s).

Regions of horizontal conductivity are specified in the surficial aquifer (figure 29)

as three different sections: a sub-stack area (7.0 x 10-7

m/s), a northwest high conductivity

zone (3.9 x10 -6

m/s), and a generalized hydraulic conductivity for the remainder of the

modeled cells (1.3 x10-6

m/s). This modification was made to allow for a good match of

the modeled to the observed contoured head data.

Boundary Conditions

Constant head cells are specified in the top layer with initial head measurements of 18 m

and 25 m for the new and old stack regions, respectively (figure 27). The implication of

the constant head acting as a consistent source of water from stack ponds is intended, as

the ponds are kept at relatively constant levels from precipitation recharge.

64

Figure 29. Zones of Hydraulic Conductivity in the Surficial Aquifer.

Consecutively darker colors signify a relatively faster conductivity;

dark blue denotes a conductivity of 4.0x10-5

m/s, light blue a

conductivity of 1.3x10 -5

, and light green a conductivity of 7.0x10-6

.

65

Constant head cells are also specified at the east and west grid boundaries in

order to simulate regional groundwater flow driven by a constant gradient between these

boundaries. The angle and the slope of the regional head trend (determined from

topographical regression in chapter 4) is generated through an offset of northward

decreasing initial head values of the constant head cells. Initial head values for variable

cells of the surficial aquifer are set to 5 m.

Sources and sinks

Sources of water in the system were generated from the constant head designation

discussed above, while sinks for the system were modeled through use of the drain

package in the MODFLOW program.

Drainage cells have been included in the top layer to simulate evaporation from

stack flanks, and in the bottom layer to model the influence of engineered ditches around

the perimeter of the stack as, well as an influential pond south of the stack (figure 30).

The insertion of drainage cells involves a specification of the drain conductance and the

elevation of the drain bottom. Drains in the top layer are specified with an elevation of 10

m and a conductance of 43 m2/day. The latter has been determined as the product of the

area, the hydraulic conductivity of the ditch fill, and the assumed thickness of the ditch

bottom.

Drains in the surficial aquifer are generally located at elevations of 3.0 & 6.0 m

with respective conductances of 43 & 21 m2/day. Drainage for the pond south of the stack

was specified at an elevation of 3.0 m, with a conductance of 43 m2/day.

66

Figure 30. Designation of Drainage Cells in the Surficial Aquifer.

Darkened cells of the grid are specified as sinks conducting water out

of the system. Representation as ditches and a pond is intended.

67

Calibration

The water table in the surficial aquifer did not vary enough to demand a complete

calibration of the model to each of the set of monitoring well head levels. Thus, a

calibration to within 10% of the average deviation for any particular head data set was

accepted as satisfactory for the steady state solution. Heterogeneities that could not be

determined or modeled within the aquifer environment were believed to be responsible

for most of the large deviations between modeled and actual head values.

Calibration of the head values in the model to their present form (figure 31) was

initiated as a large scale match to a set of contrived constant head cells which represented

values for a data set of actually measured head observations. Model parameters were then

adjusted until aberrations caused by the constant head cells disappeared and the contours

seemed adequately fit. After this was accomplished, the constant head values for

monitoring wells were taken out, and fine tuning of the parameter values was attempted.

All parameter values were kept as uniform as possible, so as to bring out inconsistencies

that would clarify local heterogeneities. Actual calibration of the model was done

conceptually in four steps:

1) balancing of stack leakance values with sub-stack conductivity to produce a head

match to well 2-0 located in the surficial aquifer,

2) adjustment of stack leakance values to generate vertical fluxes that are consistent with

the effective recharge of the gypsum stack from precipitation (minus evaporation),

68

3.0

2.02.0

3.0

4.0 5.

0

6.0

7.0

3.0

4.0

5.0

6.02.0

7.0

20.0

Figure 31. Contours of the Modeled Heads in the Surficial Aquifer.

Contours are in m intervals. Note the large influence of the cooling

pond ditches on the water table in the northeast section of the

model

3) adjustment of horizontal conductivity values in the surficial aquifer to produce head

values close to those of nearby monitoring wells,

69

4) modification of drain conductance and elevation to constrain large anomalies in head

contours.

The first two steps in the calibration involved a determination of the leakance value

trying to both match the observed hydraulic head in the surficial aquifer well 2-0 and the

estimated effective recharge of the gypsum stack as calculated from the difference

between precipitation and evaporation as measured in the region over the last few years

(see section on precipitation in the previous chapter) . Results of this calibration effort

show the strong dependency of the vertical stack-aquifer flux upon the leakance value

chosen (figure 32). With an estimated effective recharge of about 1600 m 3 /day over the

total area of both the new and the old stack, an optimal leakance value of 3 x10 -3

/day is

obtained.

In the second step, values for horizontal conductivity zones outside of the stack

region were found to be accurately quantified from the aquifer pump tests, and did not

need to be adjusted.

The final part of the calibration was made through changes in ditch elevations and

ditch conductances. Within this step was the addition of drainage cells to represent a pond

to the southeast of the stack. It was thought that impact of this pond contributed to some

70

0 1 2 3 4 5 6 7 8 9 10

Leakance

500

800

1100

1400

1700

2000

2300

2600

2900

Eff

ecti

ve R

ech

arg

e (

cu

. m

/ d

ay)

( )x day10 4 1− −

Sensitivity of Effective Stack

Recharge to Leakance

Estimated Recharge

Op

timal V

alu

e

Figure 32. Relationship of Stack Recharge to Leakance Value. Estimated

recharge values are compared to leakance values so that an optimal

leakance value can be inferred.

of the head drop from the stack in that region. The incorporation of the drainage cells

modeled partly also the effective evaporation of groundwater from the pond and from the

stack flanks, the exact value of which was not explicitly known in this study.

71

Comparison of modeled head values to observed values for September 19, 1996

(figure 20) was made to ensure a model fit (Table 5 & figure 33). The average deviation

of modeled values from well measurements was found to be 24 centimeters, which

approximated an 8.7% variance from actual values. The largest deviation of modeled

head was found to be at MW 5, which is isolated in an agricultural field south of the

research area, and could possibly be under influence of additional hydrologic factors not

considered, (i.e. irrigation pumping). Another significant deviation is exhibited at well

RW 17, which by itself is an anomaly. Contour plots of observed data (figures 19 & 20)

show that RW 17 forces a loop in the 3 m equipotential contour around the complex area.

This pattern is not quite understood, but may be the influence of a high conductivity

region or additional recharge to the groundwater in that area.

Sensitivity Analysis

Values of significance to the calibration of the model were also prime candidates

for a sensitivity analysis of the hydrologic control parameters in both the gypsum

stack and the surficial aquifer. Modeled parameters for leakance, hydraulic conductivity

and ditch specifications were modified over a range of one order of magnitude in either

direction to investigate their relative effect on the contoured modeled heads.

Table 5. Model Output Comparison to Actual Head Values. Comparison is expressed

as both an absolute depth value (in meters above MSL) and as a percentage.

72

W ell num ber 9/19/96 Value M odeled Value D ifference Percentage

M W 1 7.59 7.3 -0.29 -3.82

M W 2 4.17 4.3 0.13 3.12

M W 3 3.08 3.18 0.10 3.25

M W 4a 1.64 1.84 0.20 12.20

M W 5 1.74 2.61 0.87 50.00

M W 8 1.53 1.73 0.20 13.07

M W 9 6.39 5.24 -1.15 -18.00

M W 10 6.82 6.99 0.17 2.49

M W 11 7.26 7.24 -0.02 -0.28

RW 8 7.27 7.22 -0.05 -0.69

RW 9 5.55 5 -0.55 -9.91

RW 10 4.04 4.37 0.33 8.17

RW 11 2.73 2.72 -0.01 -0.37

RW 12 2.97 3.41 0.44 14.81

RW 13 2.91 3.54 0.63 21.65

RW 14 3.39 3.65 0.26 7.67

RW 15 2.44 2.14 -0.30 -12.30

RW 16 1.86 1.89 0.03 1.61

RW 17 3.43 2.7 -0.73 -21.28

RW 18 1.57 2.27 0.70 44.59

RW 19 2.18 2.36 0.18 8.26

RW 20 3.12 3.64 0.52 16.67

RW 21 3.20 3.23 0.03 0.94

RW 22 3.06 3.38 0.32 10.46

RW 23 2.90 3.15 0.25 8.62

RW 24 2.61 3.36 0.75 28.74

USGS 8 6.99 6.76 -0.23 -3.29

USGS 9 4.15 4.51 0.36 8.67

PZ 34 6.58 7.04 0.46 6.99

PZ 36 6.33 6.28 -0.05 -0.79

PZ 37 6.04 6.08 0.04 0.66

Stack 2 - 0 11.73 11.73 0.00 0.00

Average 0.24 8.70

73

0 1 2 3 4 5 6 7 8 9 10 11 12 13

Observed Head (m)

0

1

2

3

4

5

6

7

8

9

10

11

12

13

Mo

de

led

Hea

d (

m)

Figure 33. Modeled versus observed head values. Shown are the

listed values of table 5 with the +/- 1m error band between modeled

and observed heads

Leakance

Uniform leakance volumes from beneath the stack were the most critical value in

reference to overall head values for the entire grid. Conceptually, the leakance was

important in supplying the general volume of water available for flow into the stack and

74

the surficial aquifer. The sensitivity of the effective recharge from the stack ponds and,

owing to a lack of information, neglecting the flank water losses, ergo the flux into the

surficial aquifer to the leakance value chosen can be clearly observed from figure 32.

Thus a variation of a unit change in the leakance was found to increase head levels

beneath the stack on the meter-scale, with a modification by one order of magnitude

leaving too much of an impact on volume fluxes of water into the surficial aquifer. Thus,

the physical flux through the confining layer between the gypsum stack and the surficial

aquifer surface has the most significant impact on the modeled environment.

Conductivities

Modeled conductivity values in the surficial aquifer zones were found to

definitely be within at least one order of magnitude of their actual, measured “group”

quantity. Modification of these values by single units allowed for better model fits to

some data sets, but not to others. Since a generalized, rather homogenous hydraulic

conductivity was intended, the best fit for a generic head representation of observed

values yielded the best solution (as indicated by the differences between modeled and

observed heads of table 5) in the steady state mode. Thus, the modeled values for the

hydraulic conductivities are probably within a range of 5 units from the actual values

determined from the aquifer pump tests (cf. figure 29). It is thought that internal

heterogeneities of the hydraulic conductivity are responsible for localized head anomalies.

Ditch Specifications

Ditch elevation and conductance was determined to be of the most importance to

sinks within the hydrologic environment. Although conductance signified the degree of

75

impact each ditch had, the elevation of the ditches was a limiting factor on whether or not

any impact would be made to the flow system. The presence of ditches within the system

therefore, were a crucial part of the flow barrier surrounding the stack. Actual values of

the ditch elevations were critical to head values nearer to the stack, and although these

numbers were not directly specified from engineered specifications, slight modifications

of the elevation could be made up with additional conductance (which was also not

quantified to specifications but rather to the model fit). Regardless, ditch presence was

absolutely necessary and its parameters could not be altered very much.

As an example of the sensitivity of the model to the conductance of the ditches,

figure 34 illustrates a case whereby a conductance of 0.43 m2/day, instead of the 43

m2/day in figure 31, was used for the cooling pond ditches. With such a low conductance

the inclination of the head contours toward the cooling pond in the western part of the

model , as indicated by the actual heads (figure 20), has nearly disappeared.

Predictions for alteration of the hydrologic system are somewhat restricted to a

change in ditch presence, owing to the fact that hydraulic conductivities and water

recharge from the stack will most likely not change. Filling in of ditches will allow a

76

3.0

2.0

4.0

5.0

6.0

7.0

3.0

4.0

5.0

6.0

2.0

7.0

20.0

Figure 34. Sensitivity of the Modeled Heads in the Surficial Aquifer to

the conductance of the cooling pond ditches. In comparison with

figure 30 where a conductance of 43 m2/day was used, this one here

is only 0.43 m2/day.

larger transfer of groundwater from the stack into the surficial aquifer, and will create a

larger impact (mounding effect) of the stack on the surficial aquifer. Quantification of this

77

influence will be dependent upon how much of the ditch is actually filled in. Greatest

influence of such a change would be made to the west and southwest perimeters, as the

head gradients in those ditches support the largest volume of water conducted out of the

system. As a recommendation for future studies of the problem, ditch elevations should

be monitored more precisely than has been undertaken during the course of this

investigation.

Water Budget Analysis

A volumetric flux analysis of the surficial aquifer (figure 35) shows the actual

impact of the stack on the surficial aquifer. Values for fluxes of the hydraulic system as

obtained from the MODFLOW program and from measured hydrological input

parameters made possible such an analysis of the total water budget of the aquifer system

(stack plus surficial aquifer).

The volumetric calculation of the budgets were made in terms of m3/day and

followed the generalized form of the continuity equation:

Input - Output = Change in Storage

Although there is a short term (weekly and seasonal) change in storage which is indicated

by water level changes in the stack ponds, it can be assumed that there is no

78

PrecipitationPond Evaporation

Flank Evaporation

Dewatering Pipes

????

????

Stack Infiltration

Regional Outflow

Ditch Drainage

Regional Inflow

46 3m day/62 3

m day/

1575 3m day/

15913

m day/

1591 3m day/

31823

m day/

Figure 35. Water Budget Analysis. Input and output of volumetric fluxes

to the gypsum stack and the surficial aquifer are represented as

arrows.

79

change in storage over longer periods that are of the order of the residence times of water

in the gypsum stack and the surficial aquifer (i.e. several seasons and years). Thus, input

will equal output, as required in the steady-state model.

The volumetric input flux of the stack is described completely upon the

precipitation, with large contributors of output flux being pond evaporation and stack

leakance to the surficial aquifer. Pond evaporation was calculated as 50 % of the input

flux, with the leakance taken from a water budget file in MODFLOW. Actual fluxes were

only modeled after pathways that were known, so that smaller pathways of output fluxes

such as flank evaporation, dewatering pipes, and sprayers on top of the stack were not

considered. Upon determination of larger contributions of these smaller fluxes to the total

net output, a smaller vertical flux to the surficial aquifer could be calculated in the future.

The value determined here (figure 35) is, therefore, most likely overestimated by an

unspecified amount and would thus represent a worst-case scenario for the infiltration of

possibly toxic leachates from the phosphogypsum tailings into the surficial aquifer.

With these reservations, the inputs for the surficial aquifer unit include an

(overestimated) leakance from the gypsum stack and transport of regional flow from the

southeast. Outputs include the ditch system, as well as regional losses of groundwater to

the northwest. Most important of to this flux analysis is the comparison of regional flow

input and output to the relative inputs and outputs of the stack and ditches. For the most

part, volumes of water transferred from the stack are taken up entirely by the ditch

system. Any volume of water not taken up by the ditches is added into the regional flow

and seen as a hydrologic impact from primarily the stack; i.e. the mounding effect. This

conceptualization of the flux budget is important for the understanding of the hydraulic

80

control of water in the system. A relatively complete consumption of water to the ditches

indicates that engineering of the hydraulic balances used to minimize impact on the

groundwater are fairly adequate and even if toxic leachate from the gypsum’s stack

infiltrates into the surficial aquifer, it will, to a large extent, be intercepted by the ditch

drainage system. Figure 34 illustrates that only about 16 m3/day of water is bypassing

the ditch structure and being swept with the regional flow. Although such an amount of

non-captured diluted leachate may seem large at first glance, the value must be taken to

be relative to total fluxes in the system. When compared to the input of the surficial

aquifer, it is ~38% of that value, however, in comparison to the stack leakance, this

value is ~1% of the infiltrating flux. Thus, the addition of water to the system is quite

small in comparison to the amount of water that could be impacting the aquifer were

there no ditches. However, the quantity of flux to the system is quite large when

considering the regional flow and must be taken as somewhat of a considerable impact to

the groundwater environment in the vicinity of the phosphogypsum stack.

81

CHAPTER 6

CONCLUSIONS

This study investigates one particular phosphogypsum stack and its environment,

in an attempt to characterize flow processes that would be typical for many of the other

stacks in west central Florida. In an effort to assess flow and transport in a specific

phosphogypsum stack and the possible interaction of the low pH stack solutions with

groundwater in the adjacent surficial aquifer, a comprehensive investigation that included

hydrological testing and flow modeling has been carried out.

Several wells were drilled into the stack and the adjacent aquifer and various

experimental aquifer tests were performed and head measurements over a period of about

18 months taken. The aquifers tests include pressure transducer tests, pump and recovery

tests such as the Cooper-Jacob straight-line method, the Kirkham auger hole test and the

Bouwer Rice test for partially screened and partially penetrating wells, and in situ

flowmeter tests which allow the determination of the vertical stratification of the

hydraulic conductivity.

The pressure transducer tests provide evidence for small vertical gradients that are

reflecting the mounding effect of the stack, accentuated by the presence of a standing

water pond on its top. Although the pump tests result in only average values of the

transmissivity and storativity of the phosphogypsum stack, together with the vertical head

gradients, it hints of some vertical recharge into the gypsum formation and, because of a

significant head gradient between the gypsum stack and the underlying surficial aquifer,

possibly of vertical leakage of gypsum water into the surficial aquifer.

82

The Bouwer Rice pump tests resulted in an anomalously low hydraulic

conductivity beneath the gypsum stack but indicated a high conductivity zone in the

northwest section of the model area. The results of the flowmeter tests for the hydraulic

conductivity support the notion that flow may be partly only along horizontal bedding

planes that were formed during the `sedimentation' process of the phosphogypsum slurry.

The hydrological data was used in a steady-state numerical mounding model using

the MODFLOW model to simulate the hydraulic effect of the stack on the regional flow

and to quantify flux rates from the phosphogypsum stack into the surficial aquifer. The

model was calibrated to within 10% of the average deviation for any particular observed

head data set by adjusting various hydrological input parameters, namely the horizontal

conductivity values in the surficial aquifer; the stack leakance values, and the drain

conductances and elevation of the dewatering ditches.

The sensitivity analysis of the hydrologic control parameters in both the

gypsum stack and the surficial aquifer illustrates that the model is the most sensitive to

the leakance rate and the ditch specifications. By adjusting the vertical stack leakance

values in the model, such as to generate vertical fluxes that are consistent with the

effective recharge of the gypsum stack from precipitation, an optimal value of 3 x10 -4

day -1

was found for the leakance.

The volumetric flux analysis of the surficial aquifer shows the actual impact of

the stack on the surficial aquifer and illustrates furthermore the effectiveness of the ditch

drains in intercepting possible toxic leachate that may have infiltrated from the gypsum

stack into the surficial aquifer. In fact, only a small amount of ~1% of the infiltrating flux

of gypsum stack water is not captured by the ditches and is carried further horizontally

83

through the surficial aquifer. However, because of the neglect of the, heretofore,

unknown estimates of stack water losses due to flank evaporation, spray losses, and

dewatering pipes, the real rate of infiltration may even be less than the value indicated by

the budget analysis presented here. Unfortunately, a more precise evaluation of the true

flux-impact of the phosphogypsum stack onto the surficial aquifer will be possible only

after a more precise quantification of these stack water losses will have become

available.

REFERENCES

Amoozegar, A., and Warrick, A.W. (1986) Hydraulic conductivity of saturated soils:

field methods. Methods of Soil Analysis: Part 1 - Physical and Mineralogical

Methods, Agronomy Monograph no. 9, 735-770.

Anderson, M.P., and Woessner, W.W. (1992) Applied groundwater modeling: simulation

of flow and advective transport. San Diego, California: Academic Press Inc.,

381 pp.

Bear, J. (1979). Hydraulics of groundwater, Mc Graw-Hill Inc., New York.

Boast, C.W., and Kirkham, D. (1971) Auger hole Seepage theory. Soil Science Society of

America Proceedings, 35, 365-373.

Bouwer, H., and Rice, R.C. (1976) A slug test for determining hydraulic conductivity of

unconfined aquifers with completely or partially penetrating wells. Water

Resources Research, 12, 423-428.

Burnett, W.C., Hull, C.D., and Koch, M. (1995) How does phosphogypsum storage affect

groundwaters? Florida Institute of Phosphate Research, draft year-1 report of

project 94-05-042, 70 pp.

84

Chiang, W.H., and Kinzelbach, W. (1994) Processing Modflow for Windows : a

simulation system for modeling groundwater flow and pollution. Software

instructional manual, 196 pp.

Driscoll, F.G. (1986) Groundwater and Wells, Johnson Division, St. Paul, MN.

Gerathy and Miller, INC. (1983) Groundwater monitoring plan, Amax chemical

corporation, piney point plant. Final Report, prepared for Amax chemical

corporation (Ground Water Consultants, Tampa, Florida), 82 pp.

Gerathy & Miller, INC. (1986). Revised groundwater monitoring plan at the AMAX

Phosphate Inc. complex, Technical Report, Gerathy & Miller Inc., Tampa, FL.

Johnston, R.H., Healy, H.G., and Hayes, L.R. (1981) Potentiometric surfaces of the

tertiary limestone aquifer system, southeastern United States: May, 1980. U.S.

Geological Survey, open file report 81-486, 1 pp.

Johnston, R.H., Krause, R.E., Meyer, R.W., Ryder, P.D., Tibbals, C.H., and Hunn, J.D.

(1980) Estimated potentiometric surface for the tertiary limestone aquifer system,

southeastern United States, prior to development. U.S. Geological Survey, open

file report 80-406, 1 pp.

Lewelling, B.R., and Wylie, R.W. (1993) Hydrology and water quality of unmined and

reclaimed basins in phosphate mining areas, west-central Florida. U.S. Geological

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May, A., and Sweeney, J.W. (1983) Evaluation of radium and toxic element leaching

characteristics of Florida phosphogypsum stockpiles. Bureau of Mines, report of

investigations 8776, Tuscaloosa AL, 18 pp.

May, A., and Sweeney, J.W. (1984) Assessment of environmental impacts associated

with phosphogypsum in Florida. The Chemistry and Technology of Gypsum,

ASTM Publication 861, 116-139.

Mcdonald, M.C., and Harbaugh, A.W. (1988) MODFLOW: a modular three-dimensional

finite difference ground-water flow model. U.S. Geological Survey, open file

85

report 83-875, 528 pp.

Miller, R.L. and H. Sutcliffe, Jr., (1982) Water-quality and hydrogeological data

for three phosphate industry waste-disposal sites in Central Florida,

U.S. Geological Survey, Water Resources Investigations Report 81-84,

Tallahassee, FL..

Miller, R.L., and Sutcliffe Jr., H. (1984) Effects of three phosphate industrial sites on

ground-water in central Florida, 1979 to 1980. U.S. Geological survey, water

resources investigations report 83-4256, 184 pp.

Molz, F.J., G.K. Boman, S.C. Young and W.R. Waltrop (1994).Borehole flowmeters:

field applications and data analysis, J. Hydrology, 163, 347—371.

Oaks Geotechnical Inc. (1980) Geotechnical investigation of the gypsum

stack complex of AMAX Phosphate Inc., Report, Oaks Geotechnical Inc.

Youngs, E.G. (1968) Shape factors for kirkham’s piezometer method for determining the

hydraulic conductivity of soil in situ for soils overlying an impermeable floor or

infinitely permeable stratum. Soil Science, 106, 235-237.

86

Appendix I: Cooper Jacob Straight-line Analyses

101 1022 3 4 5 6 7 8 9 2 3 4 5 6 7 8 9 2

Time (min)

5.0

4.8

4.6

4.4

4.2

4.0

3.8

Hyd

rau

lic H

ea

d (

m)

Well 1-1

87

10-1.0 100.0 101.0 102.0

Time (min)

11

10

9

8

7

6

5H

yd

rau

lic

Hea

d (

m)

Well 1-2

88

10-1.0 100.0 101.0 102.0

Time (min)

3.400

3.125

2.850

2.575

2.300H

yd

rau

lic

Hea

d (

m)

Well 1-3

89

100 101 102 103 6 3 8 5

Time (min)

2.7000

2.5625

2.4250

2.2875

2.1500H

yd

rau

lic

He

ad

(m

)

Well 1-4

90

100 101 1022 3 4 5 6 7 8 9 2 3 4 5 6 7 8 9

Time (min)

18

16

14

12

10

8

6

4

2

0

Dra

wd

ow

n (

m)

Well 3-1

91

100 101 1029 2 3 4 5 6 7 8 9 2 3 4 5 6 7 8 9

Time (min)

4.55

4.35

4.15

3.95

3.75D

raw

do

wn

(m

)

Well 3-2

92

100 101 1029 2 3 4 5 6 7 8 9 2 3 4 5 6 7 8 9

Time (min)

3.5000

3.3875

3.2750

3.1625

3.0500D

raw

do

wn

(m

)

Well 3-3

Appendix II : Pressure Transducer Tests

93

0 2 4 6 8 10 12 14 16 18 20 22 24

Pressure (PSI)

22

18

14

10

6

2

Depth

belo

w W

ate

r T

able

(m

)

Cased Section

Screened Section

Well 1-1

94

0 2 4 6 8 10 12 14 16 18

Pressure (PSI)

17

15

13

11

9

7

5

3

1

Dep

th b

elo

w W

ate

r T

able

(m

)Well 1-2

Screened Section

Cased Section

95

0 1 2 3 4 5 6 7 8 9 10

Pressure (PSI)

10

9

8

7

6

5

4

3

2

Depth

belo

w W

ate

r T

able

(m

)

Cased Section

Screened Section

Well 1-4

96

0 2 4 6 8 10 12 14 16 18

Pressure (PSI)

19.0

17.5

16.0

14.5

13.0

11.5

10.0

8.5

7.0

5.5

4.0

De

pth

belo

w W

ell

Ris

er

(m)

Screened Section

Cased Section

Well 2-1

97

0 2 4 6 8 10 12 14 16

Pressure (PSI)

16

14

12

10

8

6

4D

ep

th b

elo

w W

ate

r T

able

(m

)

Screened Section

Well 2-2

Screened Section

98

-1 1 3 5 7 9 11 13

Pressure (PSI)

12

10

8

6

4

2D

epth

belo

w W

ate

r T

able

(m

)

Well 3-3

Cased Section

Screened Section

Appendix III : Hydraulic Head Contour Plots

99

0 250 500 750 1000 1250 1500 1750 2000 2250 2500 2750

East - West (m)

0

250

500

750

1000

1250

1500

1750

2000

2250

No

rth

- S

ou

th (

m)

5-26-96

100

0 250 500 750 1000 1250 1500 1750 2000 2250 2500 2750

East - West (m)

0

250

500

750

1000

1250

1500

1750

2000

2250N

ort

h -

So

uth

(m

)

9-19-96

101

Appendix IV : Bouwer Rice Conductivity Tests

0 600 1200 1800 2400 3000 3600 4200 4800 5400 6000

Time (sec)

0.100

1.000

10.000

Dra

wd

ow

n (

m)

Well # : MW-1

102

0 800 1600 2400 3200 4000 4800 5600 6400 7200 8000

Time (sec)

0.100

1.000

10.000D

raw

do

wn

(m

)

Well # : MW-8

103

0 400 800 1200 1600 2000 2400 2800 3200 3600 4000

Time (sec)

0.100

1.000

10.000

Dra

wd

ow

n (

m)

Well # : MW-9

104

0 240 480 720 960 1200 1440 1680 1920 2160 2400

Time (sec)

0.010

0.100

1.000

10.000

Dra

wd

ow

n (

m)

Well # : MW-18

105

0 250 500 750 1000 1250 1500 1750 2000 2250 2500

Time (sec)

0.010

0.100

1.000

10.000

Dra

wd

ow

n (

m)

Well # : MW 21

106

-0 200 400 600 800 1000 1200 1400 1600 1800 2000

Time (sec)

0.100

1.000

10.000

Dra

wd

ow

n (

m)

Well # : MW 22

107

0 500 1000 1500 2000 2500

Time (sec)

0.100

1.000

10.000

Dra

wd

ow

n (

m)

Well # : MW 24

108

0 2500 5000 7500 10000 12500 15000 17500 20000 22500 25000

Time (sec)

1.000

10.000

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wd

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n (

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Well # : 2-0

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

WASHINGTON, D.C. 20460

OFFICE OF PREVENTION, PESTICIDES AND TOXIC SUBSTANCES

Inert Ingredients Permitted for Use in Nonfood Use Pesticide Products

Last Updated January 7, 2008

The following inert ingredients are permitted for use in nonfood use pesticide products. NOTE: All inert ingredients as described in 40 CFR Part 180 may also be used in nonfood use pesticide products.

CAS Reg. No. Chemical Name 100-02-7 p-Nitrophenol 100092-50-0 Sodium dodecylphenyl polyoxyethylene phosphates 10016-20-3 α-Cyclodextrin 10024-97-2 Nitrous oxide (N2O) 10025-67-9 Sulfur chloride (S2Cl2) 10025-74-8 Dysprosium chloride (DyCl3) 10025-76-0 Europium chloride (EuCl3) 10025-77-1 Ferric chloride 10025-94-2 Yttrium chloride (YCl3), hexahydrate 1002-62-6 Decanoic acid, sodium salt 10028-21-4 Sulfuric acid, iron(2+) salt (1:1), dihydrate 10028-22-5 Ferric sulfate 1002-89-7 Octadecanoic acid, ammonium salt 10031-30-8 Tricalcium phosphate (Ca3(PO4)2) 10034-76-1 Calcium sulfate hemihydrate 10034-85-2 Hydriodic acid 10034-88-5 Sodium bisulfate monohydrate 10034-99-8 Magnesium sulfate heptahydrate 10035-04-8 Calcium chloride 10035-10-6 Hydrobromic acid 100-37-8 2-(Diethylamino)ethanol 100403-38-1 Glycerides, animal, reaction products with sucrose 100403-39-2 Glycerides, palm-oil, reaction products with sucrose 100403-40-5 Glycerides, tallow, reaction products with sucrose 100403-41-6 Glycerides, vegetable-oil, reaction products with sucrose 100-41-4 Ethylbenzene

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CAS Reg. No. Chemical Name 100-42-5 Styrene 10043-01-3 Aluminum sulfate 10043-35-3 Boric acid 10043-52-4 Calcium chloride (CaCl2) 10043-67-1 Potassium aluminum sulfate 10043-83-1 Magnesium phosphate 10045-89-3 Ferrous ammonium sulfate 10049-04-4 Chlorine dioxide 100-51-6 Benzyl alcohol 100-52-7 Benzaldehyde 10058-23-8 Monopotassium peroxymonosulfate 100-66-3 Benzene, methoxy- 100684-20-6 Fatty acids, tall-oil, maleated, compds. with triethanolamine 100852-66-2 Citric acid, bis(dimethylamine) salt 1008-72-6 Benzenesulfonic acid, 2-formyl-, sodium salt

100934-04-1 2-Propenoic acid, 2-methyl-, polymer with methyl 2-methyl-2-propenoate and alpha-(2-methyl-1-oxo-2-propenyl)-omega-methoxypoly(oxy-1,2-ethanediyl)

10094-34-5 Butanoic acid, 1,1-dimethyl-2-phenylethyl ester 10094-62-9 D-Glycero-D-gulo-heptonic acid, sodium salt, dihydrate 100-97-0 Hexamethylenetetramine 10099-58-8 Lanthanum chloride 10101-39-0 Silicic acid (H2SiO3), calcium salt (1:1) 10101-41-4 Calcium sulfate dihydrate 10101-50-5 Sodium permanganate 10101-66-3 Diphosphoric acid, ammonium manganese(3+) salt (1:1:1) 101-02-0 Dehydrated castor oil-maleic anhydride adduct 10102-17-7 Thiosulfuric acid (H2S2O3), disodium salt, pentahydrate 10102-18-8 Sodium selenite 10102-40-6 Molybdic acid (H2MoO4), disodium salt, dihydrate 10103-46-5 Calcium phosphate 10107-99-0 Diethylene glycol abietate 10108-91-5 Dimethylditetradecylammonium chloride 10117-38-1 Potassium sulfite 10124-31-9 Ammonium phosphate 10124-41-1 Calcium thiosulfate 10124-43-3 Cobalt sulfate 10124-56-8 Sodium polymetaphosphate 10124-65-9 Dodecanoic acid, potassium salt 101-25-7 N,N'-Dinitrosopentamethylenetetramine 10137-74-3 Calcium chlorate 10138-04-2 Ferric ammonium sulfate 10143-60-9 Di(2-ethylhexyl)ether 101-86-0 alpha-Hexylcinnamaldehyde 10191-41-0 dl-α-Tocopherol 10192-30-0 Ammonium bisulfite

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CAS Reg. No. Chemical Name 10213-78-2 Ethanol, 2,2-(octadecylimino)bis- 10213-79-3 Silicic acid, disodium salt, pentahydrate 102-54-5 Ferrocene 102-60-3 2-Propanol, 1,1',1",1"'-(1,2-ethanediyldinitrilo)tetrakis- 102-71-6 Triethanolamine 102-76-1 Glyceryl triacetate

102782-92-3 Siloxanes and silicones, 3-[(2-aminoethyl)amino]propyl Me, di-Me, methoxy-terminated

10279-57-9 Silica, hydrate

102-81-8 N,N-Dibutyl, N-(2-hydroxyethyl), N-hydro, ammonium mono(2-methylethanol) maleate

102900-02-7 Poly(oxyethylene/oxypropylene) monoalkyl(C6-C10)ether sodium fumarate adduct

10294-56-1 Phosphorous acid 102980-04-1 Phenolsulfonic acid-phenol-formaldehyde-urea condensate, sodium salt 103-09-3 Acetic acid, 2-ethylhexyl ester 103-11-7 2-Ethylhexyl acrylate 103-23-1 Di-n-octyl adipate (List 1 inert) 103-24-2 Di-2-ethylhexyl azelate 103-26-4 Methyl cinnamate 103-41-3 Benzyl cinnamate 10361-29-2 Carbonic acid, ammonium salt 10361-65-6 Phosphoric acid, triammonium salt 10361-84-9 Scandium chloride (ScCl3) 10361-91-8 Ytterbium chloride (YbCl3) 10361-92-9 Yttrium chloride 10377-60-3 Magnesium nitrate 10378-23-1 Ethylenediaminetetraacetic acid tetrasodium salt hydrate 104133-09-7 Tetraethoxysilane, polymer with hexamethyldisiloxane 104-15-4 p-Toluenesulfonic acid 104199-39-5 Naphthalenesulfonic acid, C6-9-alkyl Me derivs., sodium salts 104-28-9 2-Ethoxyethyl p-methoxycinnamide 104-45-0 1-Methoxy-4-propylbenzene 104-46-1 Anethole 104-54-1 Cinnamic alcohol 104-55-2 Cinnamic aldehyde 104-61-0 Nonanoic acid, 4-hydroxy-, .gamma.-lactone 104-67-6 2(3H)-Furanone, 5-heptyldihydro- 1047-16-1 C.I. Pigment Violet 19 104-76-7 1-Hexanol, 2-ethyl-

104810-47-1 Poly(oxy-1,2-ethanediyl), α-{3-{3-(2H-benzotriazol-2-yl)-5-(1,1-dimethylethyl)-4-hydroxyphenyl}-1-oxopropyl}-ω-hydroxy-

104810-48-2 Poly(oxy-1,2-ethanediyl), alpha-[3-[3-(2H-benzotriazol-2-yl)-5-(1,1-dimethylethyl)-4-hydroxyphenyl]-1-oxopropyl]-omega-hydroxy-

10486-00-7 Perboric acid (HBO(O2)), sodium salt, tetrahydrate

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CAS Reg. No. Chemical Name 104-87-0 Benzaldehyde, 4-methyl- 105-16-8 2-Propenoic acid, 2-methyl-, 2-(diethylamino)ethyl ester 105362-40-1 Phosphoric ester of Tristyrylphenylehtoxylated 105-37-3 Ethyl propionate 105-54-4 Ethyl butyrate 105-55-5 1,3-Diethyl-2-thiourea 105-59-9 Ethanol, 2,2'-(methylimino)bis- 105839-17-6 Castor oil, epoxidized 105859-97-0 Lignin, alkali, reaction products with disodium sulfite and formaldehyde 105-87-3 Benzenemethanol,α-methyl-,acetate 10595-49-0 1-Propanaminium, N,N,N-trimethyl-3-[(1-oxododecyl)amino]-, methyl sulfate 106-11-6 9-Octadecanoic acid 2-(2-hydroxyethoxy)ethyl ester

106151-63-7

alpha-(p-Nonylphenyl)-omega-hydroxypoly(oxyethylene) mixture of dihydrogen phosphate and monohydrogen phosphate esters, potassium salt; the nonyl group is a propylene trimer isomer and the POE content averages 6 moles

106-22-9 3,7-Dimethyl-6-octen-1-ol 106-23-0 Citronellal 106-24-1 Geraniol (for fragrance use only) 106-25-2 2,6-Octadien-1-ol, 3,7-dimethyl-, (Z)- 106-27-4 Isoamyl butyrate 106-30-9 Ethyl heptanoate 106392-12-5 Oxirane, polymer with methyloxirane, block 106-42-3 4-Xylene 106-43-4 4-Chlorotoluene 1064-48-8 C.I. Acid Black 1, disodium salt 106-61-6 Acetin, 1-mono- 1066-33-7 Carbonic acid, monoammonium salt 106-65-0 Butanedioic acid, dimethyl ester 106-68-3 Ethyl amyl ketone 1067-25-0 Trimethoxysilylpropane 106-88-7 1,2-Butylene oxide 106-97-8 Butane 1070-03-7 Octyl dihydrogen phosphate 107-15-3 Ethylenediamine 107-18-6 Allyl alcohol 107-19-7 Propargyl alcohol 107-21-1 Ethylene glycol 107-22-2 Ethanedial 107-41-5 Hexylene glycol 107-54-0 3,5-Dimethyl-1-hexyn-3-ol 107-64-2 Distearyl dimethyl ammonium chloride 107712-67-4 Silsesquioxanes, Me 2,4,4-trimethylpentyl, methoxy-terminated 107-75-5 Hydroxycitronellal 107-88-0 1,3-Butanediol

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CAS Reg. No. Chemical Name 107-92-6 Butyric acid 107-98-2 1-Methoxy-2-propanol 108-01-0 Ethanol, 2-(dimethylamino)- 108-05-4 Acetic acid ethenyl ester 108-10-1 Methyl isobutyl ketone 108137-17-3 Polyoxyethylene polyoxypropylene block polymer, mono(nonylphenyl) ether 108171-28-4 Methylnaphthalenesulfonic acids, polymers with formaldehyde, sodium salts 108-21-4 Isopropyl acetate 108-24-7 Acetic anhydride 108-31-6 Maleic anhydride 108-32-7 Propylene carbonate 108-38-3 3-Xylene 108389-12-4 Naphthalenesulfonic acid, methylenebis[methyl-, disodium salt 108419-32-5 Acetic acid, C7-9-branched alkyl ester, C8-rich 108419-33-6 Acetic acid, C8-10 branched alkyl esters, C9-rich 108419-34-7 Acetic acid, C9-11-branched alkyl esters, C10-rich 108419-35-8 Acetic acid, C11-14-branched alkyl ester, C13-rich 108-46-3 Resorcinol 108-63-4 Adipic acid, bis(1-methylheptyl) ester 108-65-6 1-Methoxy-2-propyl acetate 108-78-1 1,3,5-Triazine-2,4,6-triamine

108797-84-8 1-Propanaminium, 3-butoxy-2-hydroxy-N-(2-hydroxy-3-sulfopropyl)-N,N-dimethyl-, inner salt

108797-85-9 1-Propanaminium, 3-[(2-ethylhexyl)oxy]-2-hydroxy-N-(2-hydroxy-3-sulfopropyl)-N,N-dimethyl-, inner salt

108-80-5 Cyanuric acid 108818-88-8 Poly(oxy-1,2-ethanediyl), α-isodecyl-ω-hydroxy-, phosphate 108-83-8 Diisobutyl ketone 108-88-3 Toluene 108-90-7 Monochlorobenzene 108-93-0 Cyclohexanol 108-94-1 Cyclohexanone 108-95-2 Phenol (List 1 Inert) 109-02-4 Morpholime, 4-methyl- 109027-47-6 Benzenesulfonic acid, coctadecyl-, sodium salt 109-21-7 Butyl butyrate 109-46-6 Dibutyl thiourea 109-52-4 n-Valeric acid 1095-66-5 Morpholine oleate 109-60-4 Propyl acetate 109-89-7 Diethylamine

109909-39-9 Poly(oxy-1,2-ethanediyl), alpha-sulfo-omega-(2,4,6-tris(1-methylpropyl)phenoxy)-, sodium salt

109961-42-4 2-Propenenitrile, polymer with 1,2,4-triethenylcyclohexane, hydrolyzed 109-99-9 Tetrahydrofuran

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CAS Reg. No. Chemical Name 110-05-4 Di-tert-butyl peroxide 110-11-2 Sulfuric acid, monooctyl ester 110-12-3 Methyl isoamyl ketone 110-15-6 Butanedioic acid 110-16-7 Maleic acid 110-17-8 Fumaric acid 110-19-0 Isobutyl acetate 110-25-8 Glycine, N-methyl-N-[(9Z)-1-oxo-9-octadecenyl] 110-27-0 Tetradecanoic acid, 1-methylethyl ester 110-30-5 Octadecanamide, N,N'-1,2-ethanediylbis- 110-43-0 Methyl n-amyl ketone 110-54-3 Hexane (List 1 Inert) 110-44-1 Sorbic acid 110615-47-9 D-Glucopyranose, oligomeric, C10-16-alkyl glycosides 110-63-4 1,4-Butanediol 110-64-5 2-Butene-1,4-diol 110-69-0 Butyraldoxime 110720-64-4 Siloxanes and silicones, 3-aminopropyl Me, Me stearyl 110-73-6 Ethyl ethanolamine 110-80-5 Ethylene glycol monethyl ether (List 1 Inert) 110-82-7 Cyclohexane 110-87-2 [(Tetrahydro-2H-pyran-yl)thio]ethyl tallate 110-91-8 Morpholine 11092-32-3 Aluminum oxide 11096-42-7 Ethoxylated nonylphenol comp. with iodine 110-97-4 Diisopropanolamine

11097-59-9 Aluminate (Al(OH)63-), (OC-6-11)-, magnesium carbonate hydroxide (2:6:1:4)

11099-07-3 Octadecanoic acid, ester with 1,2,3-propanetriol 111-01-3 Squalane 111-03-5 9-Octadecenoic acid (Z)-, 2,3-dihydroxypropyl ester

11111-34-5 Oxirane, methyl-, polymer with oxirane, ether with (1,2-ethanediyldinitrilo) tetrakis[propanol] (4:1)

111163-74-7 Distallates (petroleum), catalytic reformer fractionator residue, low-boiling, sulfonated, sodium salts

1111-78-0 Ammonium carbamate 111-20-6 Decanedioic acid 111-27-3 1-Hexanol 11130-12-4 Boric acid, sodium salt, pentahydrate 111-30-8 Glutaraldehyde 111330-30-4 Naphthalenesulfonic acid, (1-methylpropyl)-, sodium salt 11138-05-9 Dicocodimethylammonium nitrite 11138-66-2 Xanthan gum 111-40-0 Diethylenetriamine 111-41-1 N-(2-Hydroxyethyl)ethylenediamine

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CAS Reg. No. Chemical Name 111-42-2 Diethanolamine 111-43-3 Propane, 1,1'-oxybis- 111-46-6 Diethylene glycol 111-57-9 N-(2-Hydroxyethyl)octadecanamide 111-60-4 Octadecanoic acid, 2-hydroxyethyl ester 111-62-6 Ethyl oleate

111636-30-7 1H-Pyrazole-3-carboxylic acid, 4,5-dihydro-5-oxo-1-(4-sulfophenyl)-4-{(4-sulfophenyl)azo}-, sodium salt

111-70-6 1-Heptanol B29 111-76-2 2-Butoxyethanol 111-77-3 2-(2-Methoxyethoxy)ethanol 111-82-0 Dodecanoic acid, methyl ester 111-87-5 n-Octanol 1118-92-9 Octanamide, N,N-dimethyl- 111-90-0 Diethylene glycol monoethyl ether 1119-40-0 Pentanedioic acid, dimethyl ester 1120-01-0 Sodium hexadecyl sulfate 1120-04-3 Sodium octadecyl sulfate 112-00-5 1-Dodecanaminium, N,N,N-trimethyl-, chloride 112-02-7 N,N,N-Trimethyl-1-hexadecanaminium chloride 1120-34-9 Erucic acid, methyl ester 112-03-8 1-Octadecanaminium, N,N,N-trimethyl-, chloride 112-05-0 n-Nonanoic acid 112-07-2 2-Butoxyethanol acetate 112-10-7 Isopropyl stearate 112-18-5 1-Dodecanamine, N,N-dimethyl- 112-24-3 Triethylenetetramine 112-25-4 Ethanol, 2-(hexyloxy)- 112-27-6 Ethanol, 2,2'-(1,2-ethanediylbis(oxy)bis- 112-30-1 n-Decanol 112-31-2 Decanal 112-34-5 Ethanol, 2-(2-butoxyethoxy)- 112-35-6 Triethylene glycol methyl ether 112-39-0 Methyl palmitate 112-42-5 1-Undecanol 112-50-5 Triethylene glycol ethyl ether 112-53-8 Lauryl alcohol 112-54-9 Dodecanal 112-55-0 Dodecyl mercaptan 112567-52-9 Naphthalenesulfonic acid, bis(1-methylpropyl)-, sodium salt 112-57-2 Tetraethylenepentamine 112-60-7 Ethanol, 2,2'-[oxybis(2,1-ethanediyloxy)]bis- 112-61-8 Methyl stearate 112-62-9 9-Octadecenoic acid (Z)-, methyl ester 112-63-0 Linoleic acid, methyl ester

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CAS Reg. No. Chemical Name 112-69-6 1-Hexadecanamine, N,N-dimethyl- 112-70-9 Tridecyl alcohol 112-80-1 Oleic acid 112-85-6 Behenic acid 112-88-9 1-Octadecene 112-90-3 Oleylamine 112-92-5 Stearyl alcohol 112926-00-8 Silica gel, pptd., cryst.-free 112945-52-5 Silica, amorphous, fumed, cryst. -free 113133-74-7 2-Propenoic acid, polymers with acrylic acid-iso-pr alc. reaction products

113213-81-3 α-(1,1,3,3-Tetramethylbutyl)phenoxy-omega-polyoxypropylene block polymer with polyoxylethylene

113221-69-5 Maleic anhydride, polymer with ethyl acrylate and vinyl acetate, hydrolyzed 113-48-4 5-Norbornene-2,3-dicarboximide, N-(2-ethylhexyl)- 113609-83-9 Oxirane, methyl-, polymer with oxirane, mono(4-nonylphenyl) ether, block 113652-56-5 1-octanesulfonic-2- sulfinic acid 113669-58-2 1,2-Octanedisulfonic acid 113894-85-2 Amylopectin, acid-hydrolyzed, 1-octenylbutanedioate

114033-68-0 2-Propenoic acid, polymer with 2-propanol, reaction products with sodium acrylate

114133-44-7

Hexanedioic acid, polymer with N-(2-aminoethyl)-1,3-propanediamine, aziridine, (chloromethyl)oxirane, 1,2-ethanediamine, N,N''-1,2-ethanediylbis?1,3-propanediamineU,formic acid and alpha-hydro-omega-hydroxypoly(oxy-1,2-ethanediyl)

114355-33-8 Polyamine-epichlorohydrin resin

114535-82-9 Poly(oxy-1,2-ethanediyl), alpha-phosphono-omega-[2,4,6-tris(1-phenylethyl)phenoxy]-

114795-97-0 Dodecylbenzenesulfonic acid, compd. with 1,2-propanediamine (1:1) 115-10-6 Dimethyl ether 115321-78-3 Iron chloride (FeCl3), hydrate (2:3) 115-39-9 Phenol, 4,4'-(3H-2,1-benzoxathiol-3-ylidene)bis(2,6-dibromo-, S,S-dioxide

115593-69-6

2-Propenoic acid, 2-methyl-, butyl ester, telomer with 2-[(1,1-dimethylethyl)amino]ethyl 2-methyl-2-propenoate, 1-dodecanethiol,methyl 2-methyl-2-propenoate and rel-(1R,2R,4R)-1,7,7-trimethylbicyclo[2.2.1]hept-2-yl 2-methyl-2-propenoate

115-77-5 Pentaerythritol

115793-94-7

Cyclohexanemethanamine, 5-amino-1,3,3-trimethyl-, polymer with (chloromethyl)oxirane, 4,4'-(1-methylethylidene)bis(phenol) and C,C,C-trimethyl-1,6-hexanediamine

115-83-3 Pentaerythritol tetrastearate 115-86-6 Phosphoric acid, triphenyl ester 115-95-7 Linalool acetate 1163-19-5 Benzene, 1.1'-oxybis[2,3,4,5,6-pentabromo- 116469-86-4 Wheat bran 116-75-6 9,10-Anthracenedione, 1,4-bis{(2,4,6-trimethylphenyl)amino}-

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CAS Reg. No. Chemical Name

117272-76-1 Siloxanes and silicones, 3-hydroxypropyl Me, ethers with polyethylene glycol mono-Me ether

117-81-7 1,2-Benzenedicarboxylic acid, bis(2-ethylhexyl) ester (List 1 Inert) 117-84-0 Dioctyl phthalate 117875-77-1 Sulfuric acid, mono-C10-16-alkyl esters, compds. with triethanolamine 117989-77-2 Oxirane, methyl-, polymer with oxirane, monobutyl ether, block 118-47-8 1H-Pyrazole-3-carboxyliccid, 4,5-dihydro-5-oxo-1-(4-sulfophenyl)- 118-56-9 Homomenthyl salicylate 118-58-1 Benzyl salicylate 118-60-5 2-Ethylhexyl salicylate 118-71-8 4H-Pyran-4-one, 3-hydroxy-2-methyl- 118-93-4 Ethanone, 1-(2-hydroxyphenyl)- (tolerance exemption is pending) 119060-15-0 D-Glucitol, 1-deoxy-1(methylamino)-, N-C16 acyl derivs. 1191-50-0 Sodium tetradecyl sulfate

119239-21-3

2-Propenoic acid, 2-methyl-, cyclohexyl ester, polymer with 2-hydroxyethyl 2-methyl-2-propenoate, isodecyl 2-methyl-2-propenoate, and 2-(4-morpholinyl)ethyl 2-methyl-2-propenoate

119345-04-9 Benzene, 1,1'-oxybis-, tetrapropylene derivs., sulfonated, sodium salts 119-36-8 Methyl salicylate

119432-41-6 Poly(oxy-1,2-ethanediyl), α-sulfo-ω-[2,4,6-tris(1-phenylethyl)phenoxy]-,ammonium salt

119-47-1 2,2'-Methylenebis(4-methyl-6-tert-butylphenol) 119-61-9 Benzophenone

119724-54-8 2-Propenoic acid, 2-methyl-, polymer with α-methyl-ω- hydroxypoly(oxy-1,2-ethanediyl) and methyl 2-methyl-2-propenoate, graft

12001-26-2 Mica-group minerals 12001-27-3 Lime (chemical) dolomitic 12001-27-3 Magnesium lime 12001-76-2 Vitamin B 12001-85-3 Zinc naphthenate 12002-43-6 Gilsonite 12003-38-2 Mica 12003-51-9 Silicic acid (H4SiO4), aluminum sodium salt (1:1:1) 12008-41-2 Disodium octaborate 120-32-1 2-Benzyl 4-chlorophenol 120-36-5 2-(2,4-Dichlorophenoxy)propionic acid 120-40-1 Lauric acid diethanolamide 12042-91-0 Aluminum chlorohydrate (Al2 (OH)5 Cl) 12045-78-2 Potassium borate tetrahydrate 12045-88-4 Boron sodium oxide (B4Na2O7), pentahydrate 120-46-7 Dibenzoylmethane 120-47-8 Ethyl p-hydroxybenzoate 120-51-4 Benzyl benzoate 120-55-8 Diethylene glycol, dibenzoate 120-56-9 Ethanol, 2,2'-[1,2-ethanediylbis(oxy)]bis-, dibenzoate

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CAS Reg. No. Chemical Name 120-57-0 1,3-Benzodioxole-5-carboxaldehyde 12058-66-1 Sodium stannate 12063-19-3 Zinc iron oxide 120-65-0 2-((Dimethylamino)methyl)phenol 12068-03-0 Sodium toluenesulfonate 12068-04-1 Isopropylamine methylnaphthalene sulfonate 12068-07-4 Dodecylbenzenesulfonic acid, 1,2-propylenediamine salt 12068-08-5 Morpholine dodecylbenzenesulfonate 12068-09-6 Butylamine dodecylbenzenesulfonate 12068-13-2 1,1,2,3-Tetramethylbutylamine dodecylbenzenesulfonate 12068-15-4 Strontium dodecylbenzene sulfonate 12068-17-6 Sodium dodecylphenoxybenzene disulfonate 12068-86-9 Iron magnesium oxide (Fe2MgO4) (For colorant use only) 12069-69-1 Copper carbonate 120-72-9 1H-Indole 120-94-5 N-Methylpyrrolidine 120962-03-0 Canola oil 121116-34-5 Poly (oxy-1,2-ethanediyl), alpha-methyl-omega-[(2-methyl-2-propenyl) oxy]- 12124-97-9 Ammonium bromide 12125-02-9 Ammonium chloride 12125-28-9 Magnesium carbonate hydroxide 121-32-4 Ethylvanillin 121-33-5 Benzaldehyde, 4-hydroxy-3-methoxy- 12141-46-7 Aluminum oxide silicate 12142-33-5 Stannate (SnO3(2-)), dipotassium 1214-39-7 1H-Purin-6-amine, N-(phenylmethyl)- 121-44-8 Triethylamine 121-54-0 Diisobutylphenoxyethoxyethyl dimethyl benzyl ammonium chloride

121546-77-8 Poly(oxy-1,2-ethanediyl), α-sulfo-ω-hydroxy-, C12-15-alkyl ethers, sodium salts

12167-74-7 Calcium hydroxide phosphate (Ca5(OH)(PO4)3) 12168-85-3 Calcium oxide silicate (Ca3O(SiO4)) 1217-08-9 1H-Indene-5-ethanol, 2,3-dihydro-beta,1,1,2,3,3-hexamethyl- 12173-47-6 Hectorite 12174-11-7 Attapulgite 12174-11-7 Attapulgite-type clay 121776-33-8 3-(Dichloroacetyl)-5-(2-furanyl)-2,2-dimethyloxazolidine 12179-04-3 Boric acid (H2B4O7), disodium salt, pentaborate 121-79-9 Propyl gallate

121888-67-3

Quaternary ammonium compounds, benzylbis (hydrogenated tallow alkyl)methyl, bis(hydrogenated tallow alkyl)dimethylammonium salt with hectorite

121888-68-4 Quaternary ammonium compounds, benzyl (hydrogenated tallow alkyl) dimethyl, stearates, salts with bentonite

121-91-5 Isophthalic acid

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CAS Reg. No. Chemical Name 12199-37-0 Smectite-group minerals 12207-97-5 Magnesium oxide silicate (Mg3O(Si2O5)2), monohydrate 12217-48-0 C.I. Basic Red 14 122-19-0 Stearyl dimethyl benzyl ammonium chloride 12219-26-0 C.I. Acid Blue 182 122-20-3 Triisopropanolamine

12220-51-8

3-((4-Amino-9,10-dihydro-9,10-dioxo-3-(sulfo-4-(1,1,3,3-tetramethylbutyl)phenoxy)-1-anthracenyl)amino)-2,4,6-trimethylbenzenesulfonic acid disodium salt

1222-05-5 Cyclopenta{g}-2-benzopyran,1,3,4,6,7,8-hexahydro-4,6,6,7,8,8-hexamethyl- 12222-04-7 C.I. Direct Blue 199 12225-18-2 C.I. Pigment Yellow 97 12225-21-7 FD&C Yellow No. 5 aluminum lake 12227-62-2 C.I. Pigment Red 193

12236-62-3 Butanamide, 2-{(4-chloro-2-nitrophenyl)azo}-N-(2,3-dihydro-2-oxo-1H-benzimidazol-5-yl)-3-oxo-

12239-87-1 Copper, {C-chloro-29H,31H-phthalocyaninato(2-)-N29,N30,N31,N32}- 122-40-7 Heptanal, 2-(phenylmethylene)-

122436-67-3 Benzenesulfonic acid, 4-amino-, polymer with formaldehyde and 3-methylphenol

122-51-0 Triethoxymethane 12251-44-4 Orthoclase 122-57-6 3-Buten-2-one, 4-phenyl- 12259-21-1 Iron oxide (Fe2O3), hydrate 12269-78-2 Pyrophyllite (AlH(SiO3)2) 12270-13-2 C.I. Basic Blue 41 12271-01-1 C.I. Solvent Yellow 85 122-78-1 Benzeneacetaldehyde 12280-03-4 Disodium octaborate, tetrahydrate 122-99-6 Phenoxy ethanol 123-11-5 Benzaldehyde, 4-methoxy- 123-17-1 Trimethylnonyl-4-alcohol 123175-37-1 Lignosulfonic acid, ammonium magnesium salt 123-25-1 Butanoic acid, diethylester- 123-26-2 N,N'-Ethylenebis-12-hydroxystearamide 123-31-9 1,4-Benzenediol 123-38-6 Propionaldehyde 123-42-2 Diacetone alcohol 123465-33-8 Glycerides, C8-12 123-66-0 Ethyl hexanoate 123-77-3 Azodicarbonamide 123-79-5 Adipic acid, dioctyl ester 123-86-4 Butyl acetate 12389-75-2 Sodium ferric diethylenetriaminepentaacetate 123-92-2 1-Butanol, 3-methyl-, acetate

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CAS Reg. No. Chemical Name 123-94-4 Octadecanoic acid, 2,3-dihydroxypropyl ester 123-95-5 Octadecanoic acid, butyl ester 123-95-5 Butyl stearate 124018-38-8 Fatty acids, canola-oil 124-04-9 Adipic acid 124-07-2 Octanoic acid 124-10-7 Methyl tetradecanoate 124-13-0 Octanal 124-16-3 Butoxyethoxypropanol 1241-94-7 Phosphoric acid, decyl diphenyl ester 124-22-1 1-Dodecanamine 12427-27-9 Perlite 124-28-7 Dimethyloctadecylamine 124-38-9 Carbon dioxide 124-40-3 Dimethylamine 124-41-4 Sodium methylate 124-68-5 2-Amino-2-methyl-1-propanol 124-76-5 Isoborneol 125109-81-1 Amylopectin, hydrogen 1-octadecenylbutanedioate 12511-31-8 Aluminum magnesium silicate 125-12-2 Isobornyl acetate 125220-70-4 Benzenesulfonic acid, dodecyl-, compd. with 1,3-propanediamine 125279-66-5 Poly(oxy-1,2-ethanediyl, alpha-(tripropylenephenyl)-omega-hydroxy-

125302-22-9 Poly(oxy-1,2-ethanediyl), alpha,alpha'-phosphinicobis[omega-[2,4,6-tris(1-phenylethyl)phenoxy]-

125303-89-1 Castor oil, hydrogenated, polymer with adipic acid, ethylenediamine and 12-hydroxyoctadecanoic ac

1254-78-0 Phenyl didecyl phosphite 125496-22-2 Isoarachidyl neopentanoate 125590-73-0 alpha-D-Glucopyranoside, 2-ethylhexyl

125826-44-0 Hexanedioic acid, polymer with 2,2-dimethyl-1,3-propanediol, 1,6-hexanediol, hydrazine, 3-hydro

125997-17-3 Poly(oxy-1,2-ethandiyl),α-acetyl-ω-{3-{1,3,3,3-tetramethyl-1-{(trimethylsilyl)oxy}d

126-14-7 Sucrose octaacetate 126-30-7 Poly(oxy-1,2-ethanediyl),α,α',α'',α'''-[1,2-ethanediylbis[(3-sulfo-4,1-

126324-38-7

Poly(oxy-1,2-ethanediyl), α,α',α'',α'''-[[[4-(dimethylamino)phenyl]methyliumdiyl]bis(4,1-phenylenenitrilodi-2,1-ethanediyl)]tetrakis[ω-hydroxy-

12656-57-4 C.I. Pigment Orange 20 12656-85-8 C.I. Pigment Red 104 126-73-8 Tributyl phosphate 12676-37-8 Sodium N-coco beta-aminopropionate (No established approval) 126-86-3 5-Decyne-4,7-diol, 2,4,7,9-tetramethyl- 126-92-1 Sodium 2-ethylhexyl sulfate

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CAS Reg. No. Chemical Name 12694-22-3 9-Octadecanoic acid, monoester with oxybis(propanediol) 12694-22-3 9-Octadecanoic acid, monoester with oxybis (propanediol) 126-96-5 Acetic acid, sodium salt (2:1) 127036-24-2 Poly(oxy-1,2-ethanediyl),α-undecyl-ω-hydroxy-, branched and linear 127-08-2 Acetic acid, potassium salt 127087-87-0 Poly(oxy-1,2-ethanediyl), α-(4-nonylphenyl)-ω-hydroxy-, branched 127-09-3 Sodium acetate 12710-04-2 Lignosulfonic acid, ammonium calcium salt 12713-03-0 Burnt umber 127184-52-5 Benzenesulfonic acid, 4-C10-13-sec-alkyl derivs., sodium salts 127252-82-8 Ethoxylated methyl beta-glucopyranoside dioleate 12736-96-8 Silicic acid, aluminum potassium sodium salt 127-39-9 Sodium 1,4-diisobutyl sulfosuccinate 127-41-3 alpha-Ionone 127-47-9 Retinol acetate 12751-36-9 Pharmamedia 127-51-5 3-Buten-2-one, 3-methyl-4-(2,6,6-trimethyl-2-cyclohexen-1-yl)-

127519-17-9 Benzenepropanoic acid, 3-(2H-benzotriazol-2-yl)-5-(1,1-dimethylethyl)-4- hydroxy-, C7-9-branched

127646-44-0 Naphthalenesulfonic acid, iso-Pr derivs, sodium salts 12768-78-4 C.I. Acid Green 16 12788-84-0 Sodium salt of n-coco beta amino butric acid 12788-93-1 n-Butyl acid phosphate 127-91-3 Bicyclo[3.1.1]heptane, 6,6-dimethyl-2-methylene-

128192-17-6 Siloxanes and Silicones, di-Me, 3-hydroxypropyl Me, 3-hydroxypropyl group-terminated, ethoxylated propoxylated

128-37-0 Phenol, 2,6-bis(1,1-dimethylethyl)-4-methyl- 128446-33-3 .alpha.-Cyclodextrin, 2-hydroxypropyl ethers 128446-36-6 .beta.-Cyclodextrin, methyl ethers 128-44-9 Sodium 1,1-dioxide benzisothiazol-3(H)-one 128497-20-1 Oils, macadamia 128-80-3 1,4-Di-p-toluidinoanthraquinone 128-95-0 C.I. Disperse Violet 1 129037-80-5 Ball Powder 129-17-9 C.I. Acid Blue 1, sodium salt 129291-73-2 Disodium dodecylimidazolinum dicarboxylate 129423-54-7 C.I. Pigment Yellow 191

129702-02-9 2- Propenoic acid, 2-methyl-, 2-methylpropyl ester, polymer with 2- propenoic acid and N-(1,1,3,3- tetramethylbutyl)-2-propenamide

129757-67-1 Decanedioic acid, bis(2,2,6,6-tetramethyl-4-piperidinyl) ester, reaction products with tert-Bu hy

13006-05-8 Sulfuric acid, monooctadecyl ester, magnesium salt 1300-72-7 Sodium xylene sulfonate 1302-42-7 Sodium aluminate 1302-78-9 Bentonite

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CAS Reg. No. Chemical Name 13035-04-6 2-Naphthalenesulfonic acid, 6-methyl-, sodium salt

130353-60-5 2-Propenenitrile, polymer with diethenylbenzene, ethenylethylbenzene and 1,7-octadiene, hydrolyzed

1303-86-2 Boron oxide (B2O3) 1303-96-4 Borax (Na2B4O7.10H2O) (1303-96-4) 13040-18-1 Decanoic acid, potassium salt 130498-22-5 Wheat flour

130547-87-4

Poly(oxy-1,2-ethanediyl(dimethyliminio)-1,3-propanediyliminocarbonylimino-1,3-propanediyl(dimethyliminio)-1,2-ethanediyl dichloride), α-(2-chloroethyl)-ω-(2-chloroethoxy)-

1305-62-0 Calcium hydroxide 1305-78-8 Calcium oxide (CaO) 1306-05-4 Fluorapatite 13081-34-0 Polyoxyethylene* dodecylmercaptan *(8-12 moles) 1308-14-1 Chromium hydroxide (Cr(OH)3)

13081-97-5 Octadecanoic acid, 2-2,bis(hydroxymethyl)-1,3-propanediyl ester (clearance pending)

1308-38-9 Chrome oxide (Cr2O3) 130885-09-5 Perlite 13092-66-5 Magnesium phosphate, monobasic 1309-33-7 Ferric hydroxide 1309-37-1 Iron oxide (Fe2O3) 1309-42-8 Magnesium hydroxide (Mg(OH)2) 1309-48-4 Magnesium oxide 1309-64-4 Antimony trioxide 1310-58-3 Potassium hydroxide (K(OH)) 1310-73-2 Sodium hydroxide (Na(OH)) 131-11-3 Dimethyl phthalate 131-17-9 Diallyl phthalate 1312-76-1 Potassium silicate 13127-82-7 Oleyl diethanolamide 1313-13-9 Manganese oxide (MnO2) 131324-06-6 Poly(difluoromethylene), alpha-chloro-omega-(1-chloro-1-fluoroethyl)- 1314-13-2 Zinc oxide (ZnO) 131-55-5 2,2',4,4'-Tetrahydroxybenzophenone 131-56-6 Methanone, (2,4-dihydroxyphenyl)phenyl- 131-57-7 Methanone, (2-hydroxy-4-methoxyphenyl)phenyl- 1317-33-5 Molybdenum disulfide 1317-39-1 Cuprous oxide 1317-60-8 Hematite (Fe2O3) 1317-61-9 Iron oxide (Fe3O4) 1317-63-1 Limonite 1317-65-3 Limestone 13177-52-1 Sulfuric acid, monodecyl ester, ammonium salt 1317-95-9 Tripoli

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CAS Reg. No. Chemical Name 1318-00-9 Vermiculite 1318-02-1 Zeolites (excluding erionite (CAS Reg. No. 66733-21-9)) 1318-23-6 Boehmite (Al(OH)O) 1318-74-7 Kaolinite (Al2(OH)4(Si2O5)) 1318-93-0 Montmorillonite 1319-77-3 Cresol 1320-06-5 2-Naphthalenol, 1-{{4-{(dimethylphenyl)azo}dimethylphenyl}azo}-

1320-07-6 Benzenesulfonic acid, 4-{{3-{(dimethylphenyl)azo}-2,4-dihydroxyphenyl}azo}-, monosodium salt

1320-37-2 Dichlorotetrafluoroethane 1321-69-3 Naphthalenesulfonic acid, sodium salt 1321-74-0 Divinyl benzene

132175-04-3 Polyethylene glycol-polyisobutenyl anhydride-tall oil fatty acid copolymer (minimum number averag

132-27-4 Sodium 2-phenylphenate 1322-93-6 Sodium diisopropylnaphthalene sulfonate 1322-98-1 Sodium decylbenzene sulfonate 1323-19-9 Sodium triisopropylnaphthalene sulfonate

1323-38-2 9-Octadecenoic acid, 12-hydroxy-, (9Z,12R)-, monoester with 1,2,3-propanetriol

13235-36-4 Glycine, N,N'-1,2-ethanediylbis[N-(carboxymethyl)-, tetrasodium salt, tetrahydrate

1323-83-7 Glyceryl distearate 132-43-4 Taurine, N-cyclohexyl-N-palmitoyl-, sodium salt 132538-94-4 Oils, orange-juice, citrus sinensis 13254-34-7 2-Heptanol, 2,6-dimethyl-

132580-45-1 Alpha-{2,4,6-Tris{1-(phenyl)ethyl}phenyl}-omega-hydroxypoly(oxyethylene)poly(oxypropylene)copolym

132647-09-7 Fatty acids, coco, reaction products with 2-{(2-aminoethyl)amino}ethanol, bis(2-carboxyethyl)deri

1327-36-2 Aluminatesilicate 1327-41-9 Aluminum chloride, basic 1327-43-1 Silicic acid, aluminum magnesium salt 1327-44-2 Potassium aluminum silicate, anhydrous 132778-08-6 D-Glucopyranose, oligomeric, C9-11-alkyl glycosides 1328-53-6 C.I. Pigment Green 7 1330-20-7 Xylene 1330-38-7 Copper, (dihydrogen phthalocyaninedisulfonato(2-)), disodium salt 1330-43-4 Boron sodium oxide (B4Na2O7) 133-07-3 N-(Trichloromethylthio)phthalamide 1330-76-3 Dioctyl-2-butenedioate 1330-80-9 Propylene glycol monooleate 1331-61-9 Dodecylbenzenesulfonic acid, ammonium salt 1332-09-8 Pumice 1332-37-2 Iron oxide

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CAS Reg. No. Chemical Name 1332-58-7 Kaolin 1333-86-4 Carbon black 133-42-6 Gluconic acid 1335-30-4 Aluminum silicate 1335-46-2 Ionone, methyl- 1336-08-9 Aluminum oxide silicate (Al2O(SiO4)) 1336-21-6 Ammonium hydroxide ((NH4)(OH)) 1336-36-3 Chlorinated biphenyl

133636-82-5 Spiro{bicyclo{3.1.1}heptane-3,1'-{2}cyclohexen}-4'-one,2,6,6-trimethyl- ,{1S-(1α,2.beta.,3.

1336-93-2 Manganese naphthenate 1338-02-9 Copper naphthenate 1338-24-5 Naphthenic acid 1338-39-2 Sorbitan monolaurate 1338-41-6 Sorbitan monostearate 1338-43-8 Sorbitan monooleate 13393-71-0 1-Pentadecanol, hydrogen sulfate, sodium salt 13397-24-5 Gypsum (Ca(SO4).2H2O) 13397-26-7 Calcite (Ca(Co3)) 134-03-2 Sodium ascorbate 134134-87-5 Proteins, specific of class, oat

134180-76-0 Oxirane, methyl-,polymer with oxirane, mono[3-[1,3,3,3-tetramethyl-1-[(trimethylsilyl)oxy]disil

13419-37-9 1-Tetradecanol, hydrogen sulfate, potassium salt 13419-59-5 Trisodium sulfosuccinate 13429-27-1 Tetradecanoic acid, potassium salt 134-31-6 8-Quinolinol sulfate 13438-45-4 Benzenesulfonic acid, 4-methyl-, zinc salt 1343-88-0 Magnesium silicate 1343-90-4 Magnesium silicate hydrate 1343-98-2 Silicic acid 1344-00-9 Silicic acid, aluminum sodium salt 1344-09-8 Sodium silicate 1344-28-1 Aluminum oxide (Al2O3) 1344-43-0 Manganous oxide 13446-18-9 Magnesium(II) nitrate (1:2), hexahydrate 1344-67-8 Copper chloride 1344-95-2 Silicic acid, calcium salt 1344-98-5 C.I. Pigment Green 23 13450-80-1 Sulfuric acid, iron(2+) salt (1:1), pentahydrate 1345-25-1 Iron oxide (FeO) 13453-71-9 Lithium chlorate 13463-41-7 Zinc 2-pyridinethiol-1-oxide 13463-67-7 Titanium oxide (TiO2) 13463-98-4 Calcium abietate

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CAS Reg. No. Chemical Name 13472-39-4 Sulfuric acid disodium salt, heptahydrate 13475-82-6 Heptane, 2,2,4,6,6-pentamethyl- 13477-29-7 Calcium chloride (CaCl2), monohydrate 13477-39-9 Metaphosphoric acid (HPO3), calcium salt 13515-40-7 C.I. Pigment Yellow 73 135-19-3 2-Naphthol 135-37-5 Glycine, N-(carboxymethyl)-N-(2-hydroxyethyl)-, disodium salt 13547-17-6 Urea, N,N"-methylenebis-

135590-91-9 Diethyl-1-(2,4-dichlorophenyl)-5-methyl-2-pyrazolin-3,5-dicarboxylate (Mefenpyr-diethyl)

136303-47-4 Sollac PPA 136445-69-7 Alkenes, C>10 α-, polymers with vinylpyrrolidone 136-51-6 Hexanoic acid, 2-ethyl,- calcium salt 136-52-7 Cobalt 2-ethylhexanoate 136-53-8 Zinc 2-ethylhexoate 13693-11-3 Titanium sulfate

137-08-6 .beta.-Alanine,N-(2,4-dihydroxy-3,3-dimethyl-1-oxobutyl)-, calcium salt (2:1), (R)-

137091-12-4 Actic acid ethenyl ester,polymer with ethanol and alpha-2-propenyl-omega-hydroxypoly(oxy-1,2-etha

137-16-6 Glycine, N-methyl-N-(1-oxododecyl)-, sodium salt 13717-00-5 Magnesite 137-20-2 Sodium N-cis-1-oxo-9-octadecenyl-N-methyltaurine 13721-43-2 Sodium hypophosphate 137-30-4 Zinc dimethyldithiocarbamate 137-40-6 Sodium propionate 13747-30-3 Decanoic acid, calcium salt 13759-92-7 Europium chloride (EuCl3), hexahydrate 137-66-6 Ascorbyl palmitate 137672-70-9 Soprophor 4D384 13776-74-4 Silicic acid (H2SiO3), magnesium salt (1:1)

138003-56-2 Poly{oxy(methyl-1,2-ethanediyl)}, α-{2-(trimethylammonio)ethyl}- ω-hydroxy-, chlor

13822-56-5 1-Propanamine, 3-(trimethoxysilyl)- 138-22-7 Lactic acid-, n-butyl ester 13840-33-0 Lithium hypochlorite 13845-18-6 Sodium sulfamate 13845-36-8 Potassium tripolyphosphate

13863-31-5

Benzenesulfonic acid, 2,2'-(1,2-ethanediyl)bis[5-[[4-[(2-hydroxyethyl)methylamino]-6-(phenylamino)-1,3,5-triazin-2-yl]amino]-, disodium salt

13870-28-5 Silicic acid (H2Si2O5), disodium salt 13870-29-6 Disulfuric acid, disodium salt 138-86-3 Cyclohexene, 1-methyl-4-(1-methylethenyl)- 139-05-9 Sodium cyclamate

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CAS Reg. No. Chemical Name 139-08-2 N,N-Dimethyl-N-tetradecylbenzenemethaneaminium chloride 139-13-9 Aminotriethanoic acid

139168-80-2 Fatty acids, tall oil,polymers with bisphenol A, epichlorohydrin, ethylene-manuf.-by-product di

139-44-6 Glyceryl tris(12-hydroxystearate) 13961-86-9 Diethanolamine oleate 13983-17-0 Wollastonite (Ca(SiO3)) 13983-17-0 Soapbark (Quillaja saponin) 13986-24-8 Sulfuric acid, zinc salt (1:1), hexahydrate 139871-83-3 2-Butenedioic acid (Z)-, polymer with ethenol and ethenyl acetate, sodium salt 139-87-7 Ethyl diethanolamine 139-88-8 Sodium tetradecyl sulfate 139895-03-7 Diethoxylated methyl .alpha.-glucopyranoside 2,6-dioleate 139-89-9 Trisodium (2-hydroxyethyl)ethylenediaminetriacetate 139-96-8 Triethanolamine lauryl sulfate 140-01-2 Pentasodium diethylenetriaminepentaacetate 140-11-4 Benzyl acetate 1401-55-4 Tannic acid 14025-15-1 Ethylenediaminetetraacetic acid (EDTA), disodium copper(II) salt

14025-21-9 Potassium 3-(2-(2-((2-(2-hydroxyethyl)ethyl)octadecylamino)ethoxy)propionate

14038-43-8 C.I. Blue Pigment 27 1406-18-4 Vitamin E 140-66-9 4-(1,1,3,3-Tetramethylbutyl)phenol 140-95-4 N,N'-bis(Hydroxymethyl)urea 141-04-8 Diisobutyl adipate 141-22-0 9-Octadecenoic acid, 12-hydroxy-, (9Z,12R)- 141-32-2 Butyl acrylate

141370-38-9 2-Propenoic acid, polymer with ethenylbenzene and 2-methyl-2-[(1-oxo-2-propenyl}amino]-1-propanesulfonic acid, sodium salt

141-43-5 Ethanol, 2-amino- 141-53-7 Sodium formate 1415-93-6 Humic acids 14167-87-4 Decyl diphenyl phosphate 14168-73-1 Sulfuric acid magnesium salt (1:1), monohydrate 141754-64-5 2-Propenoic acid, telomer with 2-propanol, ammonium salt 141-78-6 Ethyl acetate 141-79-7 Mesityl oxide 141-97-9 Butanoic acid, 3-oxo-, ethyl ester 142-03-0 Aluminum acetate, basic 142-15-4 Sodium isethionate, oleic acid ester 142-17-6 9-Octadecenoic acid (9Z)-, calcium salt 142-18-7 Dodecanoic acid, 2, 3-dihydroxypropyl ester 142-31-4 Sodium octyl sulfate 14233-37-5 C.I. Solvent Blue 36

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CAS Reg. No. Chemical Name 142-47-2 Monosodium glutamate 142-48-3 Glycine, N-methyl-N-(1-oxooctadecyl)- 142540-51-0 Pylam Oil Yellow 142-62-1 Hexanoic acid 142-71-2 Copper acetate 142-72-3 Acetic acid, magnesium salt 142-78-9 N-(2-Hydroxyethyl)dodecanamide 142-82-5 Heptane 142-87-0 Sulfuric acid, monodecyl ester, sodium salt 142-91-6 Isopropyl palmitate 14297-82-6 Chrysanthemic anhydride 142-98-3 Sulfuric acid, monodecy ester

14302-13-7 Copper, {1,3,8,16,18,24-hexabromo-2,4,9,10,11,15,17,22,23,25,-decachloro-29H,31H-phthalocyaninato(2-)-N29,N30,N31,N32}-,(SP-4-2)-

143-03-3 Sulfuric acid, monooctadecyl ester 143-07-7 Lauric acid 143-08-8 1-Nonanol 143-18-0 Octadecenoic acid (9Z)-, potassium salt 143-19-1 Sodium oleate 143-28-2 Oleyl alcohol 14351-50-9 Dimethylcocoamine oxide 14351-66-7 Sodium salt of rosin 14356-36-6 4-Dodecylbenzenesulfonic acid, butylamine salt 143-74-8 Phenol Red

143819-63-0 Poly(oxy-1,2-ethanediyl), α-hydro-ω-hydroxy-, monoether with (hydroxymethyl)decane

144097-18-7 Acetic acid ethenyl ester, polymer with 2-methyl-3-[(1-propenyl) amino] -1-propanesulfonic acid monosodium salt

144-33-2 1,2,3-Propanetricarboxylic acid, 2-hydroxy- disodium salt 144538-83-0 Aspartic acid, N-(1,2-dicarboxyethyl)-, tetrasodium salt 144-55-8 Sodium bicarbonate 144-62-7 Oxalic acid 14464-46-1 Cristobalite 14492-68-3 Pyridinium, 1-(((2-hydroxyethyl)carbamoyl)methyl)-, chloride, stearate 14548-60-8 Benzyl hemiformal (approval pending do not use) 145578-88-7 Naphthalenesulfonic acid, Bu derivs, sodium salts 14576-08-0 Cyclohexene,4-(1-methoxy-1-methylethyl)-1-methyl- 146340-15-0 Alcohols, C12-14-secondary, beta-(2-hydroxyethoxy-, Ethoxylated (POE-10)

146632-08-8 Siloxanes and silicones, di-Me, Bu group- and 3-{(2-methyl-1-oxo-2-propenyl)oxy}propyl group-te

146753-99-3

2-Propenoic acid, 2-methyl-, polymer with ethenylbenzene, 2-ethylhexyl 2-propenoate, 2-hydroxyethyl 2-propenoate, N-(hydroxymethyl) -2-methyl-2-propenamide and methyl 2-methyl-2-propenoate, ammonium salt

147-14-8 Copper, {29H,31H-phthalocyaninato(2-)-N29,N30,N31,N32}-, (SP-4-1)- 14729-89-6 Disodium ferrous ethylenediaminetetraacetate

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CAS Reg. No. Chemical Name 14765-30-1 Cyclohexanone, 2-(1-methylpropyl)- 147-81-9 Arabinose 147900-93-4 Fatty acids, C18-unsatd.,trimers, compds. with oleylamine 14807-96-6 Talc (Mg3H2(SiO3)4) 14808-60-7 Quartz (SiO2)

148373-01-7 Amines, tallow alkyl, ethoxylated, compds. with polyethylene glycol hydrogen sulfate nonylphenyl ether

14899-09-3 Xanthylium, 3,6-bis(diethylamino)-9-(2-(ethoxycarbonyl)phenyl)-, chloride 14901-07-6 3-Buten-2-one, 4-(2,6,6-trimethyl-1-cyclohexen-1-yl)- 149022-20-8 5'-Adenylic acid, sodium salt, hydrate 14906-97-9 D-Gluconic acid, sodium salt 149-30-4 2-Mercaptobenzothiazole 149-44-0 Methanesulfinic acid, hydroxy-, monosodium salt 149458-07-1 Fatty acids, C12-18, Me esters, sulfonated, sodium salts 149-57-5 Hexanoic acid, 2-ethyl- 14960-06-6 .beta.-Alanine, N-(2-carboxyethyl)-N-dodecyl-, monosodium salt 14977-37-8 Potassium magnesium sulfate (Mg2K2(SO4)3) 14987-04-3 Magnesium silicon oxide (Mg2Si3O8) 14989-29-8 Magnesium chloride 150-13-0 4-Aminobenzoic acid 150-25-4 N,N-(2-Dihydroxyethyl) glycine 150-38-9 Trisodium ethylenediaminetetraacetate 15046-75-0 Benzenesulfonic acid, 2-methyl-, sodium salt 15059-52-6 Dysprosium chloride (DyCl3), hexahydrate 1506-02-1 6-Acetyl-1,1,2,4,4,7-hexamethyl tetralin

150678-63-0 Poly(oxy-1,2-ethanediyl), alpha-(carboxymethyl)-omega-(4-nonylphenoxy)- , branched

150-76-5 p-Methoxyphenol

151006-66-5

2-Propenoic acid, telomer with 2-methyl-2-((1-oxo-2-propenyl)amino)-1-propanesulfonic acid monosodium salt, sodium 4-ethenylbenzenesulfonate and sodium hydrogen sulfite, sodium salt

151-05-3 Dimethylbenzylcarbinyl acetate 151-21-3 Sodium lauryl sulfate 151-41-7 Lauryl sulfate

151574-10-6 2-Propenoic acid, 2-methyl-, telomer with 2-propanol and 2-propenoic acid, sodium salt

15163-46-9 Benzenesulfonic acid, 2-dodecyl-, sodium salt

151911-51-2 D-Glucopyranose, oligomeric, 6-(dihydrogen 2-hydroxy-1,2,,3-propanetricarboxylate), 1-(coco alkyl) ethers, sodium salts

152143-22-1 Poly(oxy-1,2-ethanediyl), alpha-(4-nonylphenyl)-omega-hydroxy-, branched, phosphates

15245-12-2 Nitric acid, ammonium calcium salt 152698-66-3 Distillates (petroleum), C3-6, piperylene-rich, polymers with isobutylene 15284-51-2 Tetradecanoic acid, calcium salt

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153163-36-1

2-Propenoic acid, 2-methyl-, polymer with butyl 2-propenoate, methyl 2-methyl-2-propenoate, methyl 2-propenoate and 2-propenoic acid, graft, compd. with 2-amino-2-methyl-1-propanol

1533-45-5 4,4'-Di (benzoxazol-2-yl) stilbene 15375-84-5 Ethylenediaminetetraacetic acid (EDTA), disodium manganese (II) salt 15414-89-8 1,3-Dimethyl-5,5-dimethylhydantoin 1541-81-7 Morpholine, 4-dodecyl- 154518-36-2 Alcohols, C9-11-iso-, C10-rich, ethoxylated propoxylated 15468-32-3 Silica, crystalline - tridymite 15537-82-3 Hypophosphoric acid, sodium salt 1555-53-9 9-Octadecenoic acid (9Z)-, magnesium salt 1559-34-8 Tetraethylene glycol butyl ether 15593-82-5 Silicic acid (H6Si2O7), hexasodium salt 1560-69-6 Cobalt propionate 15630-89-4 Sodium percarbonate 15662-33-6 Ryanodine 1569-01-3 2-Propanol, 1-propoxy- 1569-02-4 2-Propanol, 1-ethoxy- 15708-41-5 Sodium ferric ethylenediaminetetraacetate

157291-93-5 Formaldehyde, polymer with alpha-[bis(1-phenylethyl)phenyl]-omega-hydroxypoly(oxy-1,2-ethanediyl)

157544-93-9

2-Propenoic acid, 2-methyl-, 2-ethyl-2-{{(2-methyl-1-oxo-2-propenyl)oxy}methyl}-1,3-propanediyl ester, polymer with 1-ethenyl-2-pyrrolidinone, 1,2-propanediol mono(2-methyl-2-propenoate) and tridecyl 2-methyl-2-propenoate

15782-05-5 2-Naphthalenecarboxylic acid, 4-{(5-chloro-4-methyl-2-sulfophenyl)azo}-3-hydroxy-, strontium salt (1:1)

15790-07-5 C.I. Pigment Yellow No. 104 15792-67-3 C.I. Acid Blue 9, aluminum salt (3:2) 15821-83-7 1-Buthoxy-2-propanol

15827-60-8 Phosphonic acid, [[(phosphonomethyl)imino]bis[2,1-ethanediylnitrilobis(methylene)]]tetrakis-

159002-21-8

Siloxanes and silicones, di-Me, polymers with silica-1,1,1-trimethyl-N-(trimethylsilyl)silanamine hydrolysis products and silicic acid trimethylsilyl ester

1592-23-0 Octadecanoic acid, calcium salt 15956-58-8 Manganese 2-ethylhexanoate 15974-07-9 Calcium zinc phosphate (CaZn2(PO4)2)

16040-69-0 Copper, {2,9,16,23-tetrachloro-29H,31H-phthalocyaninato(2-)-N29, N30, N31, N32}-, (SP-4-1)-

16058-19-8 (Z)-2-(9-Octadecenyl)-2-imidazoline-1-ethanol

160611-49-4 Benzene, ethenyl-, telomer with 2,5-furandione and (1-methylethyl)benzene, 2-butoxyethyl ester, a

160611-50-7 2,5-Furandione, telomer with ethenylbenzene and (1-methylethyl)benzene, 2-butoxyethyl ester

16068-46-5 Potassium phosphate

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CAS Reg. No. Chemical Name 160875-66-1 Poly(oxy-1,2-ethanediyl), alpha-(2-propylheptyl)-omega-hydroxy- 16106-44-8 Benzenesulfonic acid, 4-methyl-, potassium salt ()

162568-32-3 2,5-Furandione, polymer with ethenylbenzene, reaction products with polyethylene-polypropylene glycol 2-aminopropyl Me ether

162627-18-1 Fatty acids, C18-unsatd., trimers, reaction products with triethylenetetramine 16291-96-6 Charcoal, activated 16298-74-1 Phosphoric acid, dibutyl ester, sodium salt 1632-73-1 Bicyclo(2.2.1)heptan-2-ol, 1,3,3-trimethyl- 163436-84-8 Polyoxyethylene tristyrylphenol phosphate, potassium salt 163440-89-9 Poly(difluoromethylene), alpha-(2,2-dichloro-2-fluoroethyl)-omega-hydro- 163520-33-0 3-Isoxazolecarboxylic acid, 4,5-dihydro-5,5-diphenyl-, ethyl ester 1638-16-0 Tripropylene glycol 16389-88-1 Dolomite 1639-66-3 Di-n-octyl sodium sulfosuccinate 16423-68-0 Erythrosine B 1643-20-5 N,N-Dimethyldodecylamine oxide 164462-16-2 Alanine, N,N-bis(carboxymethyl)-, trisodium salt

1652-63-7 1-Propanaminium, 3-{{(heptadecafluorooctyl)sulfonyl}amino}-N,N,N-trimethyl-, iodide

1655-29-4 Disodium 1,5-naphthalenedisulfonate

1658-56-6 1-Naphthalenesulfonic acid, 4-{(2-hydroxy-1-naphthalenyl)azo}-, monosodium salt

16589-43-8 Sodium methylsiliconate 166798-73-8 Lignosulfonic acid, ammonium sodium salt 16693-91-7 Benzenesulfonic acid, 4-hexadecyl-, sodium salt 1675-54-3 Bisphenol A diglycidyl ether 16800-11-6 Boric acid (HBO2), sodium salt, dihydrate 16893-85-9 Sodium fluosilicate 16919-19-0 Ammonium fluosilicate 16938-22-0 Hexane, 1,6-diisocyanato-2,2,4-trimethyl- 1694-09-3 FD&C Violet No. 1 17018-84-7 1-Hexadecanol, hydrogen sulfate, magnesium salt

170212-40-5 Siloxanes and silicones, 3-aminopropyl Me, di-Me, [[(3-aminopropyl) ethoxymethylsilyl] oxy]-terminated, 4-hydroxybenzoates

170424-64-3 Siloxanes and silicons, hydroxy Me, Me octyl, Me(gamma-omega-perfluoro C8-14-alkyl)-oxy, ether

17099-81-9 Iron chelate of ethylenediaminetetraacetic acid 17157-03-8 Octadecanoic acid, calcium zinc salt 17217-76-4 1,2,3-Propanetricarboxylic acid, 2-hydroxy-, iron (3+) salt (1:1), trihydrate 17272-45-6 Lanthanum chloride (LaCl3), hexahydrate 173145-38-5 D-Glucitol, 1-deoxy-1-(methylamino)-, N-C10-16 acyl derivs. 17354-14-2 9,10-Anthracenedione, 1,4-bis(butylamino)- 17372-87-1 Eosin Yellowish 17421-79-3 Sodium ethylenediaminetetraacetate 17465-86-0 gama-Cyclodextrin

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CAS Reg. No. Chemical Name 17511-60-3 4,7-Methano-1H-inden-6-ol, 3a,4,5,6,7,7a-hexahydro-, propanoate 17557-23-2 Oxirane, 2,2-{(2,2-dimethyl-1,3-propanediyl)bis(oxymethylene)}bis- 17572-97-3 Tripotassium ethylenediaminetetraacetate

176022-82-5

Poly[oxy(methyl-1,2-ethanediyl)], α-[2-[bis(2-hydroxyethyl)amino]propyl]-ω-hydroxy-, ether with α-hydro-ω-hydroxypoly(oxy-1,2-ethanediyl) (1:2), mono-C12-16-alkyl ethers

1762-95-4 Ammonium thiocyanate 17675-60-4 Urea, (aminoiminomethyl)-, phosphate

177038-04-9 2,5-Furandione, polymer with alpha-ethenyl-omega-methoxypoly(oxy-1,2-ethanediyl), sodium salt

177771-31-2 Octadecanoic acid, ester with 1,2-propanediol, phosphate, anhydride with silicic acid (H4SiO4) (9

177771-33-4 Octadecanoic acid, monoester with 1,2,3-propanetriol, phosphate, anhydride with silicic acid (H4S

17852-99-2 2-Naphthalenecarboxylic acid, 4-{(4-chloro-5-methyl-2-sulfophenyl)azo}-3-hydroxy-, calcium salt (1:1)

17955-88-3 Trisiloxane, 1,1,1,3,5,5,5-heptamethyl-3-octyl- 1797-33-7 Benzenesulfonic acid, 4-tetradecyl-, sodium salt 18015-76-4 C.I. Basic Green 4, oxalate 180294-41-1 1-Naphthalenesulfonic acid, 4,8-dibutyl-, sodium salt 1812-53-9 Dihexadecyldimethylammonium 18172-67-3 Bicyclo[3.1.1]heptane, 6,6-dimethyl-2-methylene-,(1S,5S)- 18282-10-5 Tin oxide (SnO2) 18312-04-4 Zirconium octanoate 18312-31-7 Cetyl stearyl octanoate 1843-05-6 2-Hydroxy-4-n-octyloxybenzophenone 18472-87-2 Phloxine B 1847-55-8 Sodium cis-9-octadecenyl sulfate 18479-58-8 7-Octen-2-ol, 2,6-dimethyl- 18483-17-5 beta-D-Glucopyranose, 1,3,6-tris(3,4,5-trihydroxybenzoate) 1863-63-4 Benzoic acid, ammonium salt 18662-52-7 Carbonic acid, dipotassium salt, trihydrate 186817-80-1 Propanoic acid, 2-hydroxy-, 2-ethylhexyl ester, (2S)-

187820-08-2 beta-Cyclodextrin, 6-chloro-1,4-dihydro-4-oxo-1,3,5-triazin-2-yl ethers,sodium salts

188027-78-3 5H-1,3-Dioxolo[4,5-f]benzimidazole, 6-chloro-5-[(3,5-dimethyl-4-isoxazolyl)sulfonyl]-2,2-difluoro

18917-93-6 Magnesium lactate 18924-66-8 Ethanol, 2,2'-(tetradecylimino)bis- 18924-67-9 Ethanol, 2,2'-(hexadecylimino)bis- 1897-45-6 2,4,5,6-Tetrachloroisophthalonitrile 18996-35-5 1,2,3-Propanetricarboxylic acid, 2-hydroxy-, monosodium salt 190012-21-6 1-Hexanethiol, telomer with butyl 2-propenoate and ethenylbenzene

19019-43-3 Glycine,N-(carboxymethyl)-N-[2-[(carboxymethyl)amino]ethyl]-, trisodium salt

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CAS Reg. No. Chemical Name 1907-65-9 Benzenesulfonamide, N-butyl-4-methyl- 19125-99-6 1H-Benz[de]isoquinoline-1,3(2H)-dione, 2-butyl-6-(butylamino)-

192230-19-6 Amides, from acetic acid, C5-9 carboxylic acids and diethylenetriamine-ethylenimine polymer

19224-26-1 1,2-Propanediol, dibenzoate

192726-52-6 Siloxanes and Silicones, di-Me, hydroxy-terminated, dthers with polyethylene-polypropylene glycol monoallyl ether

1934-21-0 1H-Pyrazole-3-carboxylic acid, 4,5-dihydro-5-oxo-1-(4-sulfophenyl)-4-((4-sulfophenyl)azo)-, trisodium salt

19381-50-1 C.I. Acid Green 1 19423-76-8 Cerium chloride (CeCl3), hydrate 19589-59-4 Benzenesulfonic acid, 3dodecyl-, sodium salt 197178-94-2 Propanol, 1(or 2)-(2-propenyloxy)-, benzoate 1984-06-1 Octanoic acid, sodium salt 199111-50-7 1-Octadecanaminium, N,N-dimethyl-N-[3-(trihydroxysilyl)propyl]- chloride 2016-56-0 Dodecylamine acetate 2031-67-6 Methyl triethoxysilane 20324-32-7 1-(2-Methoxy-1-methylethoxy)-2-propanol 20324-33-8 Tripropylene glycol monomethyl ether 20344-49-4 Iron hydroxide oxide (Fe(OH)O) 20427-58-1 Zinc hydroxide (Zn(OH)2) 20427-59-2 Copper hydroxide 2050-08-0 Benzoic acid, 2-hydroxy-, pentyl ester

205193-99-3 2-Butenedioic acid (2Z)-, monobutyl ester, polymer with methoxyethene, sodium salt

20526-58-3 Sodium sulfosuccinate 20587-61-5 Diethylene glycol monobenzoate 20662-14-0 Scandium chloride (ScCl3), hexahydrate 20727-33-7 Butanedioic acid, sulfo-, 1,4-bis(1-methylheptyl) ester, sodium salt 20749-68-2 12H-Phthaloperin-12-one, 8,9,10,11-tetrachloro- 20780-48-7 Tetrahydrolinalyl acetate

208054-84-6

1,3-Benzenedicarboxylic acid, polymer with 2,2-dimethyl-1,3-propanediol, hexanedioic acid, 1,6-hexanediol, 3-hydroxy-2-(hydroxymethyl)-2-methylpropanoic acid and 5-isocyanato-1-(isocyanatomethyl)-1,3.3-trimethylcyclohexane, compd. with 2-amino

20824-56-0 Diammonium ethylenediaminetetraacetate 2082-79-3 Octadecyl 3-(3',5'-di-tert-butyl-4'-hydroxyphenyl)propionate 208408-46-2 Vitamin D, 1,25-dihydroxy-, 26, 23-lactone, (1-alpha)- 20846-91-7 L-Aspartic acid, N,N'-1,2-ethanediylbis- 2090-05-3 Calcium benzoate 20908-72-9 Sulfuric acid, iron(2+) salt (1:1), tetrahydrate 2091-29-4 9-Hexadecenoic acid 2110-18-1 Pyridine, 2-(3-phenylpropyl)- 21142-28-9 Sulfuric acid, monododecyl ester, comp. with 1-amino-2-propanol (1:1) 2116-84-9 Phenyl tris(trimethylsiloxy)silane

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CAS Reg. No. Chemical Name 21245-02-3 4-(Dimethylamino)benzoic acid, 2-ethylhexyl ester

212842-88-1

1,3 benzene dicarboxylic acid, 5-sulfo-, 1,3-dimethyl ester, sodium salt, polymer with 1,3-benzene dicarboxylic acid, 1,4- benzene dicarboxylic acid, dimethyl 1,4-benzene dicarboxylate and 1,2-ethanediol

21564-17-0 2-(Thiocyanomethylthio)benzothiazole

215731-95-6 2,5-Furandione, polymer with alpha-ethenyl-omega-hydroxypoly(oxy-1,2-ethanediyl), sodium salt

2163-42-0 2-Methyl-1,3-propanediol 21645-51-2 Aluminum hydroxide (Al(OH)3) 21652-27-7 2-[(Z)-8-Heptadecenyl]-2-imidazoline-1-ethanol 21662-09-9 4-Decenal, (4Z)- 219714-96-2 Penoxsulam 22047-49-0 Octadecanoic acid, 2-ethylhexyl ester 2211-98-5 Sodium p-dodecylbenzenesulfonate 2211-99-6 Benzenesulfonic acid, 4-(1 -methylundecyl)-, sodium salt 2212-50-2 Benzenesulfonic acid, 4-(1 -ethyldecyl)-, sodium salt 2212-51-3 Benzenesulfonic acid, 4-(1 -propylnonyl)-, sodium salt 2212-52-4 Benzenesulfonic acid, 4-(1 -pentylheptyl)-, sodium salt 221667-31-8 Cyprosulfamide ( approval pending do not use)

222716-38-3 Fatty acids, tall-oil, esters with polyethylene glycol mono(hydrogen maleate), compds. with amides from diethylenetriamine and tall-oil fatty acids

222716-82-7 Siloxanes and silicones, di-Me, hydroxy Me, ethers with polypropylene glycol mono-Bu ether

2235-54-3 Ammonium dodecyl sulfate 2244-21-5 Troclosene potassium [USAN:INN] 22464-99-9 2-Ethylhexanoic acid, zirconium salt 225234-12-8 Borage seed oil 22620-93-5 Decanoic acid, aluminum salt 22691-02-7 Calcium chloride (CaCl2), hydrate 2269-22-9 2-Butanol, aluminum salt

23089-26-1 3-Cyclohexene-1-methanol,α,4-dimethyl-α-(4-methyl-3-pentenyl)-, {S-(R*,R*)}-

2321-07-5 Spiro(isobenzofuran-1(3H), 9'-(9H)xanthen)-3-one, 3',6'-dihydroxy- 23328-53-2 Phenol, 2-(2H-benzotriazol-2-yl)-6-dodecyl-4-methyl- 23386-52-9 Butanedioic acid, sulfo-, 1,4-dicyclohexyl ester, sodium salt 2353-45-9 FD&C Green No. 3 23696-85-7 2-Buten-1-one, 1-(2,6,6-trimethyl-1,3-cyclohexadien-1-yl)- 23783-42-8 Tetraethylene glycol methyl ether 2390-60-5 C.I. Basic Blue 7

241483-16-9 Poly(oxy-1,2-ethanediyl), alpha-methyl-omega-hydroxy-, maleated, calcium salts

2425-77-6 1-Decanol, 2-hexyl- 2425-85-6 C.I. Pigment Red 3 24360-05-2 Hexamethylene tetramine monohydrochloride

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CAS Reg. No. Chemical Name 2440-22-4 2-(2H-Benzotriazol-2-yl)-4-methylphenol 244149-17-5 3,6,9,12,15,18,21,24,27-Nonaoxanonacosan-1-ol, 29-(4-nonylphenoxy)- 2445-77-4 Butanoic acid, 3-methyl-, 2-methylbutyl ester 2452-01-9 Dodecanoic acid, zinc salt 2457-01-4 Barium 2-ethylhexanoate 24634-61-5 Sorbic acid, potassium salt 2465-27-2 C.I. Basic Yellow 2 2475-46-9 C.I. Disperse Blue 3 24800-44-0 Tripropylene glycol 2481-94-9 Benzenamine, N,N-diethyl-4-(phenylazo)- 24851-98-7 Cyclopentaneacetai acid, 3-oxo-2-pentyl-, methyl ester 2492-26-4 2-Mercaptobenzothiazole, sodium salt 24936-68-3 Poly[oxycarbonyloxy-1,4-phenylene(1-methylethylidene)-1,4-phenylene 24937-16-4 Poly[imino(1-oxo-1,12-dodecanediyl)] 24937-78-8 Vinyl acrylate-dioctylmaleate copolymer 24937-79-9 Ethene, 1,1-difluoro-, homopolymer 24938-04-3 Polyethylene terephthalate - polyethylene isophthalate film

24938-16-7 2-Propenoic acid, 2-methyl-, butyl ester, polymer with 2-(dimethylamino)ethyl 2-methyl-2-propen

24938-91-8 Poly(oxy-1,2-ethanediyl), α-tridecyl-ω-hydroxy- 24968-79-4 Methyl acrylate acrylonitrile graft copolymer 24991-31-9 Polyvinyl butyrate 25013-15-4 Vinyl toluene 25013-16-5 Butylated hydroxyanisole 25014-41-9 Polyacrylonitrile 25035-26-1 Acetic acid ethenyl ester, polymer with 2-butenoic acid and ethenyl propanoate 25035-68-1 Methacrylic acid butyl acrylate methyl methacrylate polymer

25035-69-2 2-Propenoic acid, 2-methyl-, polymer with butyl-2-propenoate and methyl 2-methyl-2-propenoate

25035-97-6 2-Propenoic acid, ethyl ester, polymer with chloroethene 25035-98-7 2-Propenoic acid, methyl ester, polymer with chloroethene

25036-16-2 2-Propenoic acid, 2-methyl-, polymer with butyl 2-propenoate and ethenylbenzene

25036-25-3 Bisphenol A-bisphenol A diglycidyl ether polymer 2503-73-3 C.I. Direct Blue 78, tetrasodium salt 25038-54-4 Polycaprolactam 25038-59-9 Polyethylene terephthalate

250591-55-0 2,5-Furandione, polymer with alpha-[4-(ethenyloxy)butyl]-omega-hydroxypoly(oxy-1,2-ethanediyl), sodium salt

25067-01-0 Vinyl acetate, polymer with n-butyl acrylate 25067-11-2 Hexafluoropropene, polymer with tetrafluoroethylene 25068-38-6 4,4'-(1-Methylethylidene)bisphenol polymer with (chloromethyl) oxirane 25084-90-6 Ethylene butyl acrylate copolymer 25085-02-3 Sodium acrylate, polymer with acrylamide 25085-34-1 Styrene acrylic acid copolymer

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CAS Reg. No. Chemical Name 25085-39-6 2-Propenoic acid, polymer with 1,3-butadiene and ethenylbenzene 25085-41-0 Vinyl acetate-butyl acrylate-acrylic acid terpolymer

25085-99-8 Oxirane,2,2'-[(1-methylethylidene)bis(4,1-phenyleneoxymethylene)]bis-, homopolymer-

25086-15-1 2-propenoic acid, 2-methyl-, polymer with methyl 2-methyl-2-propenoate 25086-29-7 Vinyl pyrrolidone - styrene copolymer latex 25086-48-0 Acetic acid ethenyl ester, polymer with chloroethene and ethenol 25086-89-9 2-Pyrrolidinone, 1-ethenyl-, polymer with ethenyl acetate 25087-06-3 Maleic acid monoethyl ester-vinyl methyl ether copolymer 25087-34-7 1-Butene, polymer with ethene 25103-23-5 Triisooctyl phosphate 25104-37-4 Polyvinyl ether ether 25119-68-0 Maleic acid monobutyl ester-vinyl methyl ether copolymer, 25119-83-9 2-Propenoic acid, polymer with butyl 2-propenoate 2512-29-0 Butanamide, 2-{(4-methyl-2-nitrophenyl)azo}-3-oxo-N-phenyl-

25133-97-5 2-Propenoic acid, 2-methyl-, polymer with ethyl 2-propenoate and methyl 2-methyl-2-propenoate

25135-39-1 2-Propenoic acid, 2-methyl-, methyl ester, polymer with ethyl 2-propenoate and 2-propenoic acid

25136-75-8 2-Propene-1-aminium, N,N-dimethyl-N-2-propenyl-, chloride, polymer with 2-propenamide and 2-propenoic acid

251479-93-3 2,5-Furandione, polymer with alpha-ethenyl-omega-methoxypoly(oxy-1,2-ethanediyl) and 2-propenoic acid, sodium salt

25153-40-6 Methyl vinyl ether-maleic acid copolymer ,minimum average molecular weigh 25153-46-2 2-propenoic acid, 2-ethylhexyl ester, polymer with ethenylbenzene 25154-52-3 Nonylphenol 25154-85-2 Propane, 1-(ethenyloxy)-2-methyl-, polymer with chloroethene 25155-30-0 Sodium dodecylbenzenesulfonate 251553-55-6 Alcohols, C>14, ethoxylated 25167-81-1 Dichlorophenol 25168-05-2 Benzene, chloromethyl-

25188-42-5 2-Naphthalenesulfonic acid, 7-(benzoylamino)-4-hydroxy-3-((4-((4-sulfophenyl)azo)phenyl)azo)-

25189-83-7 2H-Azepin-2-one, 1-ethenylhexahydro-, homopolymer 25212-83-3 Ethylene-acrylic acid copolymer, ammonium salt 25212-88-8 Ethyl acrylate- methacrylic acid copolymer 25213-02-9 1-Hexene, polymer with ethene 25213-24-5 Acetic acid ethenyl ester, polymer with ethenol

25213-88-1 2-Propenoic acid, 2-methyl-, methyl ester, polymer with ethenylbenzene and 2-propenenitrile

25214-39-5 Acrylonitrile-methyl methacrylate-vinylidene chloride polymer 25214-69-1 Hydrolyzed polyacrylonitrile 25231-21-4 Polypropylene glycol stearyl ether 25231-46-3 Benzenesulfonic acid, methyl- 25265-15-0 2-Propenoic acid, 2-methyl-, methyl ester, polymer with 2-ethylhexyl 2-

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CAS Reg. No. Chemical Name propenoate

25265-71-8 Dipropylene glycol 25265-77-4 2,2,4-Trimethylpentane-1,3-diol monoisobutyrate 25265-93-4 Polyethylene polysulfide 25266-02-8 Maleic anhydride-1-octadecene copolymer

25321-41-9 Xylene sulfonic acid and its ammonium, calcium, magnesium, potassium, sodium, and zinc salts

25322-68-3 Polyethylene glycol 25322-69-4 Polypropylene glycol

25322-99-0 2-Propenoic acid, 2-methyl-, butyl ester, polymer with butyl 2-propenoate and methyl 2-methyl-2-propenoate

25338-55-0 Dimethylaminomethylphenol 25339-17-7 Isodecanol 25395-31-7 Diacetin 25417-20-3 Dibutylnaphthalenesulfonic acid, sodium salt 25446-78-0 Ethanol, 2-?2-?2-(tridecyloxy)ethoxyUethoxyU-, hydrogen sulfate, sodiumsalt 25446-90-6 Sulfuric acid, monodecyl ester, calcium salt 25446-91-7 1-tetradecanol, hydrogen sulfate, magnesium salt 25446-93-9 Sulfuric acid, monodecyl ester, magnesium salt 25455-73-6 Silver oxide (Ag2O2) 25496-72-4 9-Octadecenoic acid (9Z)-, monoester with 1,2,3-propanetriol 25498-49-1 [2-(2-Methoxymethylethoxy)methylethoxy]propanol 25512-39-4 Silane, (3-chloropropyl)trimethoxy- 25550-98-5 Phosphorous acid, diisodecyl phenyl ester 25585-77-7 2-Propenoic acid, polymer with ethenylbenzene and ethyl 2-propenoate 25608-12-2 2-Propenoic acid, homopolymer, potassium salt

25608-33-7 2-Propenoic acid, 2-methyl-, butyl ester, polymer with methyl 2-methyl-2-propenoate

25618-55-7 Polyoxypropylene triol 25637-84-7 9-Octadecenoic acid (9Z)-, diester with 1,2,3-propanetriol 25638-17-9 Naphthalenesulfonic acid, butyl-, sodium salt

25640-14-6 1,4-Benzenedicarbixylic acid, dimethyl ester,polymer with 1,4-cyclohexanedimethanol and 1,2-ethanediol

25719-52-2 Lauryl methacrylate polymer 25719-60-2 Bicyclo(3.1.1)heptene, 6,6-dimethyl-2-methylene-, homopolymer 25722-70-7 Polyglycidol 25750-06-5 Styrene-methyl methacrylate-2-ethylhexyl acrylate copolymer 25750-82-7 Ethylene-acrylic acid copolymer, sodium salt 25750-84-9 2-Propenoic acid, butyl ester, polymer with ethene 25766-18-1 Bicyclo [3.1.1] hept-2-ene, 2,6,6-trimethyl- , homopolymer

25791-96-2 Poly(oxy(methyl-1,2-ethanediyl)), alpha,alpha',alpha",-1,2,3-propanetriyltris(omega-hydroxy-

25852-37-3 2-Propenoic acid, 2-methyl-, methyl ester, polymer with butyl 2-propenoate 25951-38-6 Butyl acrylate-hydroxyethyl acrylate-methyl methacrylate copolymer 25956-17-6 2-Naphthalenesulfonic acid, 6-hydroxy-5-{(6-methoxy-4-sulfo-m-tolyl)azo}-,

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CAS Reg. No. Chemical Name disodium salt

25973-55-1 Phenol, 2-(2H-benzotriazol-2-yl)-4,6-bis(1,1-dimethylpropyl)- 25987-30-8 Acrylamide, polymer with sodium acrylate 25987-55-7 Calcium polyacrylate

25987-66-0 Acrylic acid butyl ester, polymer with methacrylic acid, methyl methacrylate and styrene

2601-33-4 1-Tetradecanaminium, N-(carboxymethyl)-N,N-dimethyl-, inner salt 2601-98-1 Hexadecanoic acid, magnesium salt 26027-37-2 Polyethylene glycol mono-2-(oleylamido)ethyl ether 26027-38-3 Poly(oxyethylene) p-nonylphenol 26038-87-9 Monoethanolamine, boric acid salt 26038-90-4 Boric acid, monoisopropanolamine salt 2605-44-9 Dodecanoic acid, barium cadmium salt 2605-78-9 Octyl dimethyl amine oxide 26061-64-3 2-butenedioic acid (2Z)-, dioctyl ester, polymer with ethenyl acetate 26062-79-3 2-Propen-1-aminium, N,N-dimethyl-N-2-propenyl-, chloride, homopolymer 26099-09-2 Maleic acid, polymers

2610-05-1 1,3-Naphthalenedisulfonic acid, 6,6'-{(3,3'-dimethoxy(1,1'-biphenyl-)-4,4'-diyl}bis(azo)}bis{4-amino-5-hydroxy-, tetrasodium salt

2610-11-9 2-Naphthalenesulfonic acid, 7-(benzoylamino)-4-hydroxy-3-((4-((4-sulfophenyl)azo)phenyl)azo)-, disodium salt

2611-82-7 C.I. Acid Red 18, trisodium salt 26160-96-3 Polyvinylpyrrolidone, butylated

26161-33-1 Ethanaminium, N,N,N-trimethyl-2-[(2-methyl-1-oxo-2-propenyl)oxy]-, chloride, homopolymer

26172-55-4 3(2H)-Isothiazolone, 5-chloro-2-methyl- 26183-44-8 Lauryl polyoxyethylene sulfate 26183-52-8 Polyoxyethylene* decyl alcohol *(5.5 moles) 26221-73-8 1-Octene, polymer with ethene 2624-31-9 Hexadecanoic acid, potassium salt

262435-04-1 Lignin, alkali, reaction products with formaldehyde, sodium bisulfite and sodium chloroacetate

26248-24-8 Benzenesulfonic acid, tridecyl-, sodium salt 26254-89-7 Butanal, 2,2-diethyl- 26256-79-1 Sodium . beta.-.beta.-(laurylimino)dipropinate 26264-05-1 Benzenesulfonic acid, dodecyl-, compd. with 2-propanamine (1:1) 26264-06-2 Calcium dodecylbenzene sulfonate 26264-58-4 Sodium isopropylisohexylnaphthalenesulfonate 26266-57-9 Monohexadecanoate sorbitan 26266-58-0 Sorbitan trioleate

26266-76-2 1H-Imidazolium, 1-ethyl-2-(heptadecenyl)-4,5-dihydro-1-(2-hydroxyethyl)-, ethyl sulfate (salt)

2627-06-7 Benzenesulfonic acid, 4-decyl-, sodium salt

26300-51-6 2-Propenoic acid, 2-methyl, methyl ester, polymer with butyl 2-propenoate and 2-propenoic acid

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CAS Reg. No. Chemical Name 26316-40-5 1,2-Ethanediamine, polymer with methyloxirane and oxirane 26337-35-9 Acetic acid ethenyl ester, polymer with carbon monoxide and ethene 2634-33-5 1,2-Benzisothiazolin-3-one

26376-86-3 2-Propenoic acid, ethyl ester, polymer with 2-propenoic acid, 2-ethylhexyl ester

26401-27-4 Isooctyl diphenyl phosphite 26401-47-8 Poly(oxy-1,2-ethanediyl), alpha-(4-dodecylphenyl)-omega-hydroxy- 26402-22-2 Decanoic acid, monoester with 1,2,3-propanetriol 26402-26-6 Octanoic acid, monoester with 1,2,3-propanetriol

26403-62-3 Poly[oxy(methyl-1,2-ethanediyl)], alpha-(1-oxooctadecyl)-omega-[(1-oxooctadecyl)oxy]-

26446-35-5 Monoacetin 26447-09-6 Benzenesulfonic acid, methyl-, ammonium salt 26447-10-9 Ammonium xylenesulfonate 26468-86-0 Poly(oxy-1,2-ethanediyl), alpha-(2-ethylhexyl)-omega-hydroxy- 26499-65-0 Plaster of paris

2650-18-2

Benzenemethanaminium, N-ethyl-N-[4-[[4-[ethyl[(3-sulfophenyl)methyl]amino]phenyl](2-sulfophenyl)methylene]-2,5-cyclohexadien-1-ylidine]-3-sulfo-, inner salt, diammonium salt

26523-78-4 Phenol, nonyl-, phosphite (3:1) 26544-23-0 Diphenyl isodecyl phosphite 26545-53-9 Diethanolamine dodecylbenzenesulfonate 26545-58-4 Naphthalenesulfonic acid, methylenebis-, disodium salt

26588-80-7 Butyl acrylate, 2-hydroxyethyl methacrylate, methyl methacrylate and styrene copolymer

26590-05-6 2-Propen-1-aminium, N,N-dimethyl-N-2-propenyl-, chloride, polymer with 2-propenamide

26604-01-3 Acrylic acid,polymer with acrylonitrile,ethyl acrylate and N-(hydroxymethyl)acrylamide

26635-76-7 Ethoxylated tallowamine 26635-92-7 N,N'-Bis(poly(oxyethylene))stearylamine 26635-93-8 Polyoxyethylenated oleylamine 26635-94-9 Polyoxyethylenated cetylamine 26636-40-8 Docosyl polyethylene glycol ether 2664-42-8 N,N-Dimethyloleamide 26655-10-7 Butyl methacrylate, 2-ethylhexyl acrylate and styrene copolymer 26657-95-4 Hexadecanoic acid, diester with 1, 2, 3-propanetriol 26657-96-5 Hexadecanoic acid, monoester with 1, 2, 3-propanetriol 26658-19-5 Sorbitan tristearate 26658-42-4 Epichlorohydrin, polymer with tetraethylenepentamine 2673-22-5 Sodium ditridecyl sulfosuccinate 26761-40-0 Diisodecyl phthalate (Clearance pending) 26793-35-1 2-Propenoic acid, polymer with N,N-dimethyl-2-propenamide 2682-20-4 3(2H)-Isothiazolone, 2-methyl- 26836-07-7 Ethanolamine dodecylbenzenesulfonate

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CAS Reg. No. Chemical Name 26856-96-2 Sulfuric acid, monoisononyl ester, sodium salt

26873-77-8 2-Propenoic acid, 2-methyl-, polymer with ethenylbenzene, 2-ethylhexyl 2-propenoate and 2-propene

2687-94-7 2-Pyrrolidinone, 1-octyl- 2687-96-9 2-Pyrrolidinone, 1-dodecyl- 26885-07-4 Ethanesulfonic acid, 2-(methyl(1-oxoeicosyl)amino)-, sodium salt 26896-20-8 Neodecanoic acid 26915-70-8 Tridecyloxypoly(ethyleneoxy)ethyl phosphate 27012-62-0 Nitrile rubber modified acrylonitrile-methyl acrylate copolymers 27134-27-6 Benzenamine, ar,ar-dichloro- 27138-31-4 Propanol, oxybis-, dibenzoate 2717-15-9 Triethanolamine oleate 27176-87-0 Benzenesulfonic acid, dodecyl- 27177-77-1 Benzenesulfonic acid, dodecyl-, potassium salt 27177-79-3 Benzenesulfonic acid, octadecyl-, sodium salt 27178-87-6 Sodium dimethylnaphthalene sulfonate 2718-67-4 Tris(butoxyethyl) phosphite 27193-28-8 Phenol, (1,1,3,3-tetramethylbutyl)- 27193-86-8 Dodecylphenol 27213-90-7 Sodium diisobutylnaphthalene sulfonate 27214-38-6 Tetradecanoic acid, monoester with 1,2,3-propanetriol 27215-38-9 Dodecanoic acid, monoester with 1, 2, 3-propanetriol 27252-80-8 Poly(oxy-1,2-ethanediyl), alpha-methyl-omega-(2-propenyloxy)- 27252-83-1 Poly(oxy-1,2-ethanediyl),α-acetyl-ω-(acetyloxy)- 27252-87-5 Poly(oxy-1,2-ethanediyl),α-acetyl-ω-2-propenyl- 27253-30-1 Lithium neodecanoate 27253-31-2 Cobalt neodeconoate 27253-33-4 Calcium neodecanoate 27274-31-3 Poly(oxy-1,2-ethanediyl),α-2-propenyl-ω-hydroxy- 27277-00-5 [1,2,4]Triazolo[1,5-a]pyrimidin-5(4H)-one, 2-amino-6-methyl-4-propyl-

27306-78-1 Poly(oxy-1,2-ethanediyl),α-methyl-ω-{3-{1,3,3,3-tetramethyl-1-{(trimethylsilyl)oxy}

27323-41-7 Triethanolamine dodecylbenzenesulfonate 27344-41-8 Benzenesulfonic acid,2,2'-(4,4'-biphenylylenedivinylene)di-, disodium salt 27354-18-3 C.I. Solvent Red 169 27360-07-2 Butane, 1,1-bis(ethenyloxy)-, polymer with ethenol & ethenyl acetate 27458-92-0 Isotridecyl alcohol 27458-93-1 Isooctadecyl alcohol 27479-45-4 Benzenesulfonic acid, dodecyl-, magnesium salt 27519-02-4 cis-9-Tricosene 27536-89-6 Poly(ethylbenzene)

27553-55-5 Butyl acrylate, 2-hydroxyethyl methacrylate, methacrylic acid and styrene copolymer

27554-26-3 Diisooctyl phthalate (Clearance pending) 2756-56-1 Bicyclo(2.2.1)heptan-2-ol, 1,7,7-trimethyl-, propanoate, exo-

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CAS Reg. No. Chemical Name 2761-24-2 Amyl triethoxysilane 27636-21-1 Epichlorohydrin, polymer with hexamethylenediamine 27636-75-5 Benzenesulfonic acid, undecyl-, sodium salt 27636-82-4 Monomethylol-5,5-dimethylhydantoin 27638-00-2 Dodecanoic acid, diester with 1, 2, 3-propanetriol 27731-61-9 Poly(oxy-1,2-ethanediyl), α-sulfo-ω-(tetradecyloxy)-, ammonium salt 27731-62-0 Poly(oxy-1,2-ethanediyl), α-sulfo-ω-(tetradecyloxy)-, sodium salt 27756-15-6 Acrylic acid-stearyl methacrylate copolymer 27757-95-5 C.I. Pigment Red 52 2782-57-2 Troclosene 2783-94-0 6-Hydroxy-5-((4-sulfophenyl)azo)-2-naphthalenesulfonic acid, disodium salt

2786-76-7 2-Naphthalenecarboxamide, 4-((4-(aminocarbonyl)phenyl)azo)-N-(2-ethoxyphenyl)-3-hydroxy-

27987-00-4 Benzenesulfonic acid, (1-methylundecyl)-, sodium salt 28062-44-4 Acrylic acid-N-vinylpyrrolidone copolymer

2807-30-9 1,3-Benzenedicarboxylic acid, 5-sulfo-monosodium salt, polymer with 1,3-benzenedicarboxylic acid

28088-63-3 Xylenesulfonic acid, calcium salt 2809-21-4 Etidronic acid 28182-81-2 Hexamethylene diisocyanate (HDI) homopolymer

28188-24-1 Octadecanoic acid, 2-(hydroxymethyl)-2-(((1-oxooctadecyl)oxy)methyl)-1,3-propanediyl ester

28205-96-1 Acrylic acid-methacrylic acid copolymer, sodium salt 28211-18-9 2-Pyrrolidinone, 1-ethenyl-, polymer with 1-eicosene 28212-44-4 Poly(oxy-1,2-ethanediyl), α-(carboxymethyl)-ω-(4-nonylphenoxy)- 28231-03-0 1H-3a,7-Methanoazulen-5-ol, octahydro-3,8,8-trimethyl-6-methylene- 28299-18-5 Poly(oxy-1,2-ethanediyl), alpha-(2,4-dinonylphenyl)-omega-hydroxy- 28300-74-5 Antimony potassium tartrate 28348-27-8 Diethylene glycol, polyester with maleic acid and sebacic acid 28348-53-0 Sodium cumene sulfonate 28348-61-0 Benzenesulfonic acid, tetradecyl-, sodium salt 28348-64-3 Isopropylnapthalenesulfonic acid, sodium salt 28348-65-4 Naphthalenesulfonic acid, (2-methylpropyl)-, sodium salt 28349-72-6 2-Propenoic acid, polymer with 2-propenal 2836-32-0 Sodium glycolate

2837-89-0 2-Chloro-1,1,1,2-tetrafluoroethane (For use in sterilant mixture with ethylene oxide only)

28430-58-2 Vinyl acetate, polymer with methyl acrylate and methyl methacrylate 28514-75-2 Resorcinol, bis(xylylazo)- 28519-02-0 Benzenesulfonic acid, dodecyl(sulfophenoxy)-, disodium salt 28553-12-0 Diisononyl phthalate 28631-66-5 C.I. Acid Blue 22

2870-32-8 Benzenesulfonic acid, 2,2'-(1,2-ethenediyl)bis{5-{(4-ethoxyphenyl)azo}-, disodium salt

28804-88-8 Dimethylnaphthalene

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CAS Reg. No. Chemical Name 28805-58-5 Butanedioic acid, octenyl- 2893-78-9 Troclosene sodium 28983-56-4 C.I. Acid Blue 93 28984-69-2 2-(Heptadecenyl)-4,4(5H)-oxazoledimethanol 28987-17-9 Barium nonylphenate 29061-61-8 Dodecylbenzenesulfonic acid, diisopropylamine salt 29061-63-0 Dodecylbenzenesulfonic acid, triethylamine salt 29066-34-0 Cyclohexanol, 5-methyl-2-(1-methylethyl)-, acetate, (1α,2.beta.,5α)-(.+-.)- 29116-98-1 Sorbide dioleate 29169-69-5 Sodium N-oleyl taurine

2917-94-4 Ethanesulfonic acid, 2-(2-(2-(4-(1,1,3,3-tetramethylbutyl)phenoxy)ethoxy)ethoxy)-, sodium salt

29190-28-1 Resorcinol, 2,4-bis(xylylazo)- 2934-05-6 Diisopropylphenols 2934-07-8 2,4,6-Triisopropylphenol 29383-26-4 Octadecanoic acid, hydroxy-, 2-ethylhexyl ester 29385-43-1 1H-Benzotriazole, 4(or 5)-methyl-, sodium salt 29387-86-8 Propylene glycol monobutyl ether 29405-16-1 Benzenesulfonic acid, 4-hydroxy-, polymer with formaldehyde and urea

29434-28-4 2-Propenoic acid, butyl ester, polymer with N-(hydroxymethyl)-2-methyl-2-propenamide and 2-propenenitrile

29437-34-1 2-Propenoic acid, butyl ester, polymer with ethyl 2-propenoate and 2-propenenitrile

29658-97-7 3-(2-Dodecenyl)dihydro-2,5-furandione 29710-25-6 2-Ethylhexyl 12-hydroxystearate 29710-31-4 Cetyl octanoate 29733-18-4 Glutaric acid, diisodecyl ester 29781-80-4 alpha-D-Glucopyranoside, octyl 29781-81-5 alpha-D-Glucopyranoside, decyl 29806-73-3 Hexadecanoic acid, 2-ethylhexyl ester 298-07-7 2-Ethylhexyl monohydrogen phosphate 298-14-6 Carbonic acid, monopotassium salt 29836-26-8 (beta-D-Glucopyranoside, octyl 29887-08-9 1,4-Bis[(2-ethylhexyl)amino] anthraquinone 29911-27-1 2-Propanol, 1-(1-methyl-2-propoxyethoxy)- 29911-28-2 Dipropylene glycol monobutyl ether 299-27-4 Potassium gluconate 30025-38-8 Dipropylene glycol monoethyl ethyl 3006-15-3 Sodium 1,4-dihexyl sulfosuccinate 300-92-5 Aluminum, hydroxybis(octadecanoato-O)- 301-00-8 Methyl linolenate 3010-24-0 1-Octadecanaminium, N,N-bis(2-hydroxyethyl)-N-methyl-, chloride 30125-47-4 C.I. Pigment Yellow 138 3012-65-5 Diammonium citrate 30136-13-1 Propylene glycol monopropyl ether

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CAS Reg. No. Chemical Name 30227-71-5 Benzenesulfonic acid, pentadecyl-, sodium salt 3025-30-7 Ethyl (2E,4Z)-2,4-decadienoate 30260-72-1 Benzenesulfonic acid, dodecyl(sulfophenoxy)- 30260-73-2 Benzenesulfonic acid, oxybis(dodecyl- 3026-63-9 Sodium tridecyl sulfate 3032-58-4 Sulfuric acid, monododecyl ester, compd. with 2-propanamine (1:1) 30346-73-7 Potassium xylene sulfonate 30364-51-3 Glycine, N-methyl-N-(1-oxotetradecyl)-, sodium salt 3049-71-6 C.I. Pigment Red 178 30526-22-8 Potassium toluene sulfonate 30581-59-0 Vinyl pyrrolidone-dimethylaminoethylmethacrylate copolymer 30587-85-0 Benzenesulfonic acid, 2,4(2,6 or 3,5)-dimethyl-,sodium salt 30704-63-3 Poly(methylene-p-tert-butylphenoxy-poly(ethyleneoxy) ethanol) 30704-64-4 Formaldehyde, polymer with p-tert-butylphenol, methyloxirane and oxirane

30795-23-4 2-Propenoic acid, butyl ester, polymer with ethenylbenzene and 2-ethylhexyl 2-propenoate

308066-19-5 Biosolids (conforming to 40 CFR part 503) 308075-07-2 Sand 308076-02-0 Soapstone 30846-35-6 Poly(methylene-p-nonylphenoxy)poly(ethyleneoxy)ethanol 30862-33-0 1-Tridecanol, hydrogen sulfate, sodium salt 30938-41-1 Acrylic acid, butyl acrylate, vinyl chloride, vinyl acetate polymer 30968-45-7 Hydrogenated methyl abietate Magnesium dodecyl sulfate

31075-24-8 1,2-Ethanediamine, N,N,N',N'-tetramethyl-, polymer with 1,1'-oxybis[2-chloroethane]

3118-97-6 2-Naphthalenol,l-((2,4-dimethylphenyl)azo)- 31212-13-2 2-Propenoic acid, potassium salt, polymer with 2-propenamide 31212-99-4 Vinyl acetate-vinyl alcohol-alkyl lactone copolymer 31307-92-3 Polyoxyethylene sorbitol

31307-95-6 Maleic acid monoisopropyl ester-vinyl methyl ether copolymer, minimum average

31393-98-3 Bicyclo[3.1.1]hept-2-ene, 2,6,6-trimethyl-, polymer with 6,6-dimethyl-2-methylene bicyclo[3.1.1] heptane

31394-71-5 Polypropylene glycol monooleate 3147-75-9 2-(2-Hydroxy-5-tert-octylphenyl)benzotriazole

31512-74-0 Poly[oxy-1,2-ethanediyl (dimethyliminio)-1,2-ethanediyl (dimethyliminio)-1,2-ethanediyl dichloride]

31556-45-3 Octadecanoic acid, tridecyl ester 31566-31-1 Octadecanoic acid, monoester with 1,2,3-propanetriol 3164-85-0 Hexanoic acid, 2-ethyl-, potassium salt 31671-74-6 2-Hydroxy-2-(methylamino)-1,3-propanediol

31694-55-0 Poly(oxy-1,2-ethanediyl), alpha,alpha',alpha''-1,2,3-propanetriyltris[omega-hydroxy-

31800-88-1 Polyoxyethylene octyl ester of phosphoric acid

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CAS Reg. No. Chemical Name 31906-04-4 3-Cyclohexene-1-carboxaldehyde, 4-(4-hydroxy-4-methylpentyl)-

319926-68-6 Benzenesulfonic acid, dodecyl-, branched, compds. with N,N,-dimethyl-1,3-propanediamine (2:1)

32131-17-2 1,6-hexanediamine, polymer with hexanedioic acid 3214-47-9 C.I. Direct Yellow 50, tetrasodium salt 32171-27-0 Poly(oxy-1,2-ethanediyl), alpha-[4-(1-phenylethyl)phenyl]-omega-hydro 32345-29-2 Phosphorothioic acid, O,O-diethyl O-phenyl ester 3234-84-2 Dodecanoic acid, octadecyl ester 3234-85-3 Tetradecanoic acid, tetradecyl ester 32388-55-9 Acetyl cedrene (odor masking agent only) 32426-11-2 Decyl dimethyl octyl ammonium chloride

3244-88-0 Benzenesulfonic acid, 2-amino-5-[(4-amino-3-sulfophenyl)(4-imino-3-sulfo-2,5-cyclohexadien-1-ylidene)methyl]-3-methyl-, disodium salt

32458-06-3 Polymer of butyl methacrylate, 2-hydroxyethyl acrylate, methyl methacrylate and styrene

3246-20-6 Sodium dinonyl sulfosuccinate 32492-61-8 Polyoxyethylene* isopropylidenediphenol *(7-7.5 moles) 3251-23-8 Nitric acid, copper(2+) salt 32612-48-9 Poly (oxy-1,2-ethanediyl) , alpha-sulfo-omega- (dodecyloxy)-, ammonium salt 32649-30-2 2-Butenedioic acid (Z)-, polymer with ethenol, sodium salt 32686-95-6 Dipropylene glycol, monobenzoate

32687-78-8 Benzenepropanoic acid, 3,5-bis(1,1-dimethylethyl)-4-hydroxy-, 2-(3-(3,5-bis(1,1-dimethylethyl)-4-hydroxyphenyl)-1-oxopropyl)hydrazide

32687-84-6 2-Decanol, hydrogen sulfate, sodium salt 3282-85-7 Sodium heptadecyl sulfate

330977-00-9 [alpha]-hydro-[]-hydroxy-poly(oxyethylene) C8-C18-alkyl ether citrates, poly(oxyethylene) content is 4-12 moles which represent C8 alkyl ether citrate

330980-61-5 alpha-D-Glucopyranoside, 2-ethylhexyl 6-O-alpha-D-glucopyranosyl-

330985-58-5

[alpha]-hydro-[]-hydroxy-poly(oxyethylene) C8-C18-alkyl ether citrates, poly(oxyethylene) content is 4-12 moles which represent C10-C16 alkyl ether citrates

330985-61-0

[alpha]-hydro-[]-hydroxy-poly(oxyethylene) C8-C18-alkyl ether citrates, poly(oxyethylene) content is 4-12 moles which represent C16-C18-alkyl ether citrates

519290 C.I. Solvent Yellow 30 3332-27-2 1-Tetradecanamine, N,N- dimethyl-, N-oxide

33438-19-6 2-Propenoic acid, butyl ester, polymer with ethyl 2-propenoate and N-(hydroxymethyl)-2-propenamide

334-48-5 Decanoic acid 33734-57-5 Peroxyoctanoic acid 3386-57-0 Octanoic acid, magnesium salt 3391-86-4 1-Octen-3-ol 33939-64-9 Laureth-11 carboxylic acid, sodium salt 3414-89-9 9,12-Octadecadienoic acid (9Z, 12Z)-, potassium salt 34247-28-4 Sodium lauryl glyceryl ether sulfonate

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CAS Reg. No. Chemical Name 343-27-1 7-Methoxy-1-methyl-9H-pyrido?3,4-b|-indole hydrochloride 34363-01-4 p-Menth-1-ene, dimer 34396-03-7 Silane, trimethoxy(2,4,4-trimethylpentyl)- 343978-15-4 Heptadecanol, hydrogen sulfate, sodium salt, branched 343978-24-5 Hexadecanol, hydrogen sulfate, sodium salt, branched 34398-01-1 Poly(oxy-1,2-ethanediyl), α-undecyl-ω-hydroxy- 34451-19-9 Propanoic acid, 2-hydroxy-, ethyl ester (S) 34506-45-1 1-Tridecanol, hydrogen sulfate, ammonium salt 3452-97-9 1-Hexanol,3,5,5-trimethyl- 34590-94-8 Propanol, 1(or 2)-(2-methoxymethylethoxy)- 3468-63-1 2-Naphthalenol, 1-{(2,4-dinitrophenyl)azo}-

34690-00-1 Phosphonic acid, [[(phosphonomethyl)imino]bis[6,1-hexanediylnitrilobis(methylene)]]tetrakis-

348137-48-4

2-Propenoic acid, 2-methyl-, methyl ester, polymer with ethyl 2-propenoate, 2-methoxyethyl 2-propenoate, zinc bis(2-methyl-2-propenoate) and ZINC di-2-propenoate,2,2'-azobis[2-methylbutanenitrile]- and 2,2'-azobis[2-methylpropanenitrile]-initiated

3486-30-4

Benzenemethanaminium, N-(4-((2,4-disulfophenyl)(4-(ethyl(phenylmethyl)amino)phenyl)methylene)-2,5-cyclohexadien-1-ylidene)-N-ethyl-, hydroxide, inner salt, sodium salt

34902-57-3 Oxacyclohexadecen-2-one 35087-77-5 D-Gluconic acid, potassium salt 3520-42-1 C.I. Acid Red 52

35239-21-5 2-Propenoic acid, polymer with butyl 2-propenoate, chloroethene and N-(hydroxymethyl)-2-propenamide

35285-68-8 Sodium ethylparaben 35285-69-9 Sodium propylparaben 3531-23-5 Benzenepropanenitrile, beta-hydroxy-beta-phenyl- 35355-77-2 C.I. Pigment Red 63:2 35365-94-7 Triethyl ammonium phosphate 3539-43-3 1-Hexadecanol, dihydrogen phosphate 354-33-6 Ethane,1,1,1,2,2-pentafluoro- 3555-47-3 Trisiloxane, 1,1,1,5,5,5-hexamethyl-3,3-bis((trimethylsilyl)oxy)-

3564-21-4 4-((5-Chloro-4-methyl-2-sulfophenyl)azo)-3-hydroxy-2-naphthalenec-arboxylic acid, disodium salt

35674-65-8 Urea, N,N''-1,3-prpanediylbis?N'-octadecyl-

3567-65-5

1,3-Naphthalenedisulfonic acid, 7-hydroxy-8-{{4'-{{4-{{(4-methylphenyl)sulfonyl}oxy}phenyl}azo} {1,1'-biphenyl}-4-yl}azo}-, disodium salt

3567-66-6 C.I. Acid Red 33

3567-69-9 1-Naphthalenesulfonic acid, 4-hydroxy-3-{(4-sulfo-1-naphthalenyl)azo}-, disodium salt

35691-65-7 2-Bromo-2-(bromomethyl)pentanedinitrile 3586-55-8 Methanol, {1,2-ethanediylbis(oxy)}bis- 3609-96-9 1,2,3-Propanetricarboxylic acid, 2-hydroxy-, dipotassium salt

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36148-84-2 9,12-Octadecadienoic acid (Z,Z)-, 3,4-dihydro-2,5,7,8-tetramethyl-2-(4,8,12-trimethyltridecyl)-2H-1-benzopyran-6-yl ester, {2R*(4R*,8R*)}-(.+-.}-

3622-84-2 Benzenesulfonamide, N-butyl- 3624-77-9 Glycine, N-methyl-N-(1-oxo-9-octadecenyl)-, sodium salt 36311-34-9 Isohexadecanol

36347-52-1 Ethanaminium, N,N,N-trimethyl-2-[(2-methyl-1-oxo-2-propenyl)oxy]-, chloride, polymer with methyl 2-methyl-2-propenoate

36354-80-0 Octanoic acid, diester with 1,2,3-propanetriol 36366-93-5 Phenyltetraethylene glycol

364066-68-2 2-Propen-1-aminium, N,N-dimethyl-N-2-propenyl-, chloride, polymer with 2-propenoic acid, sodium salt, reaction products with disodium (disulfite)

36445-71-3 Decyl phenoxybenzenedisulfonic acid, disodium salt 36452-21-8 1,3,5-Triazine-2,4,6(1H,3H,5H)-trione, disodium salt 36457-20-2 Sodium butylparaben 36653-82-4 1-Hexadecanol 36729-43-8 Xylenesulfonic acid, magnesium salt 36729-46-1 Xylenesulfonic acid, zinc salt 36747-44-1 Benzenesulfonic acid, 4-methyl-, calcium salt () 3681-71-8 3-Hexen-1-ol, acetate, (3Z)- 3687-46-5 Decyl oleate

36915-65-8 Sodium isethionate, coconut fatty acid ester trimer isomer and the POE content averages 6 moles

3696-28-4 Pyridine, 2,2'-dithiobis-, 1,1'-dioxide 37086-84-3 1,2-Propanediol, 1-benzoate 3710-84-7 N,N-Diethylhydroxylamine 37189-83-6 Linoleic acid dimer-diethylenetriamine copolymer 37199-81-8 Sodium salt of a copolymer of maleic anhydride and diisobutylene 37205-87-1 Poly(oxy-1,2-ethanediyl),[alpha]-(isononylphenyl)-ω-hydroxy- 37207-89-9 Lignosulfonic acid, sodium salt, sulfomethylated

37211-53-3 Oxirane, methyl-, polymer with oxirane, mono(bis(1-methylpropyl)phenyl) ether

37211-54-4 tert-Alkyl* amine (ethylene oxide)** (propylene oxide)*** *(100% C12-C13) **(35%) ***(45%) (Mol. Wt. 3150)

37220-82-9 9-Octadecenoic acid (Z)-, ester with 1,2,3-propanetriol 37244-96-5 Nepheline syenite 37251-69-7 Oxirane, methyl-, polymer with oxirane, mono(nonylphenyl) ether 37271-20-8 SK (surfactant) 37280-82-3 Oxirane, methyl-, polymer with oxirane, phosphate 37281-47-3 Triton DF 12 37281-48-4 Triton H 66 37281-78-0 Poly(oxy(methyl-1,3-ethanediyl)), α-(1-oxo-9-octadecenyl)-ω-butoxy-, (Z)- 37286-64-9 Polypropylene glycol methyl ether 37294-49-8 Butanedioic acid, sulfo-, 4-isodecyl ester, disodium salt 37299-86-8 Rhodamine WT 37310-83-1 Oleyl ether phosphate (neutral)

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CAS Reg. No. Chemical Name 37311-02-7 Oxirane, methyl-, polymer with oxirane, monooctyl ether 37314-65-1 Lignosulfonic acid, potassium salt 37325-33-0 Lignosulfonic acid, calcium sodium salt 37332-31-3 C8-12 triglycerides

37340-60-6 Poly(oxy-1,2-ethanediyl), alpha-nonylphenyl-omega-hydroxy, phosphate, sodium salt

3734-33-6 Benzenemethanaminium, N-[2-[(2,6-dimethylphenyl)amino]-2-oxoethyl]-N,N-diethyl-, benzoate

3734-67-6 C.I. Acid Red 1 3737-55-1 Sodium N-hexadecanoyl-N-methyltaurine 3738-00-9 Naphtho{2,1-b}furan, dodecahydro-3a,6,6,9a-tetramethyl- 37449-19-7 Manganese isooctanoate 37452-11-2 Dimethylamine dodecylbenzenesulfonate 374602-90-1 Ashes (residues), sunflower seed hull 37523-33-4 Poly(methylene-p-nonylphenoxy) poly(propyleneoxy) propanol 375348-43-9 Xanthan gum, polymer with ethanedial 3758-54-1 Stearamidopropyl dimethyl 2-hydroxyethyl ammonium dihydrogen phosphate 3761-53-3 C.I. Acid Red 26 37764-25-3 Acetamide, 2,2-dichloro-N,N-di-2-propenyl-

37767-39-8 L-Aspartic acid, N-(3-carboxy-1-oxosulfopropyl)-N-octadecyl-, tetrasodium salt

37971-36-1 2-Phosphonobutane-1,2,4-tricarboxylic acid 38011-25-5 Glycine, N,N'-1,2-ethanediylbis-, disodium salt 3811-04-9 Potassium chlorate

38193-60-1 1-Propanesulfonic acid, 2-methyl-2-[(1-oxo-2-propenyl)amino]-,monosodium saltpolymer with 2-propenamide

38251-37-5 Benzenesulfonic acid, 3-methyl-, sodium salt) 3843-16-1 Dihydrogenated tallow dimethyl ammonium methosulfate

3844-45-9

Benzenemethanaminium, N-ethyl-N-(4-((4-(ethyl((3-sulfophenyl)methyl)amino)phenyl)(2-sulfophenyl)methylene)-2,5-cyclohexadien-1-ylidene)-3-sulfo-, hydroxide, inner salt, disodium salt

38640-62-9 Diisorpropyl naphthalene 38660-45-6 9,12,15-Octadecatrienoic acid, potassium salt, (9Z, 12Z, 15Z)- 38916-42-6 Aspartic acid, N-Carboxy-1-oxo-3-sulfopropyl)-N-octadecyl-, tetrasodium salt 3896-11-5 2-(2-Hydroxy-3-tert-butyl-5-methylphenyl)-5-chloro-2H-benzotriazole

3905-19-9 2-Naphthalenecarboxamide, N,N'-1,4-phenylenebis[4-[(2,5-dichlorophenyl)azo]-3-hydroxy-

39105-95-8 2,2-Dichloro-N-(1-methylethyl)-N-phenylacetamide 39236-46-9 Imidazolinidyl urea 3926-62-3 Acetic acid, chloro-, sodium salt

39277-28-6 Benzenesulfonamide, ar-methyl-, polymer with formaldehyde and 1,3,5-triazine-2,4,6-triamine

39310-05-9 Polymethylene polyphenyl isocyanate

39332-53-1 2-Propenoic acid, 2-methyl-, polymer with methyl 2-methyl-2-propenoate and 2-propenoic acid

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CAS Reg. No. Chemical Name 39354-45-5 Sodium salt of lauryl alcohol polyglycol ether sulfosuccinate 39362-51-1 Oxirane,methyl-, polymer with oxirane, acetate 39393-37-8 Santicizer 711 39421-75-5 Hydroxypropyl guar gum

39443-63-5 alpha-Alkyl(C8-15)-omega-hydroxypolyoxyethylene* polyoxypropylene polyoxyethylene* *(9.5 to 10 moles)

39444-23-0 Ammonyx 4080

39444-87-6 Cyclohexane, 1,1'-methylenebis[4-isocyanato-, polymer with α-hydro-ω-hydroxypoly(ox

39445-23-3 Calcium magnesium hydroxide (CaMg (OH)4) 3944-72-7 1-Octanesulfonic acid

39464-64-7 Poly(oxy-1,2-ethanediyl), [alpha]-(dinonylphenyl)-[omega]-hydroxy-,phosphate

39464-70-5 Phenoxy tri(ethoxy) phosphoric acid 39471-52-8 Phosphoric acid, octadecyl ester 39587-22-9 Alcohol, C9, ethoxylated

396089-99-9 Poly(oxy-1,2-ethanediyl, alpha-[2,4,6-tris(1-phenylethyl(phenyl)]-omega-hydroxy-,sulfate

397256-50-7

2-Propenoic acid, polymer with sodium ethanesulfonate, peroxydisulfuric acid, disodium salt- initiated, reaction products with tetrasodium ethenylidenebis (phosphonata)

3982-82-9 Trisiloxane, 1,3,3,5-tetramethyl-1,1,5,5-tetraphenyl- 3999-01-7 (Z,Z)-9,12-Octadecadienamide 40372-66-5 1,2,4-Butanetricarboxylic acid, 2-phosphono-, sodium salt 40379-24-6 Acetic acid, isononyl ester 40382-75-0 Sodium dodecylnaphthalene sulfonate 4040-48-6 Dodecanoic acid, magnesium salt 4040-50-0 Tetradecanoic acid, alumnium salt 4065-45-6 2-Hydroxy-4-methoxybenzophenone-5-sulfonic acid 40716-42-5 N,N-Bis(2-hydroxyethyl)ricinoleamide 4075-81-4 Calcium propionate 40798-65-0 Phenol, polymer with formaldehyde, sodium salt

4080-31-3 3,5,7-Triaza-1-azoniatricyclo(3.3.1.13,7)decane,1-(3-chloro-2-propenyl)-, chloride

408-35-5 Hexadecanoic acid, sodium salt 4086-70-8 Tetradecanoic acid, magnesium salt 4107-98-6 N,N-Diisopropylaniline 4124-42-9 Benzenesulfonic acid, 4-methyl-, ammonium salt

4129-84-4

Benzenemethanaminium, N-[4-[[4-(diethylamino)phenyl][4-[ethyl[(3-sulfophenyl)methyl]amino]phenyl]methylene]-2,5-cyclohexadien-1-ylidene]-N-ethyl-3-sulfo-, inner salt, sodium salt

41444-50-2 n-Octyl glucoside 41444-55-7 Decyl glucoside 41451-28-9 Diisoheptyl phthalate (Clearance pending) 41487-53-0 2-Propenoic acid, 2-methyl-,polymer with ethyl 2-propenoate, sodium salt

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CAS Reg. No. Chemical Name 41556-26-7 Bis(1,2,2,6,6-pentamethyl-4-piperidinyl) decanedioate

41618-91-1 2-Propenoic acid, 2-hydroxypropyl ester, polymer with chloroethene and ethenyl acetate

41928-09-0 Polyoxyethylene* methylenebis(octylphenol) *12 moles

4197-25-5 1H-Perimidine, 2,3-dihydro-2,2-dimethyl-6-{{4-(phenylazo)-1-naphthalenyl}azo}-

42003-39-4 2,8,9-Trioxa-5-aza-1-silabicyclo{3.3.3}undecane, 1-(chloromethyl)- 42065-76-9 Isopropylamine sulfonate

42557-13-1 Poly(oxy(methyl(3,3,3-trifluoropropyl)silylene)), alpha-(trimethylsilyl)-omega((trimethylsilyl)oxy)-

4270-70-6 Triphenylsulfonium chloride 42808-36-6 Sodium salt of sulfonated butyl oleate

4292-10-8 1-Propanaminium,N-(carboxymethyl)-N,N-dimethyl-3-[(1-oxododecyl)amino]-,inner salt

42966-30-3 Decanoic acid, magnesium salt

43035-18-3

Benzenesulfonic acid, 4-{{3-{{2-hydroxy-3-{{(4-methoxyphenyl)amino}carbonyl}-1-naphthalenyl}azo}-4-methylbenzoyl}amino}-, calcium salt (2:1)

431040-31-2 2-Propanamine, compd. with alpha-phosphono-omega-butoxypoly(oxy-1,2-ethanediyl) (2:1)

431062-72-5 2-Propanamine, compds. with polyethylene glycol dihydrogen phosphate C8-10-alkyl ether (2:1)

43154-85-4 Butanedioic acid, sulfo-, 1-[1-methyl-2-[(1-oxo-9-octadecenyl)amino]ethyl] ester, disodium salt ()

4316-73-8 Sodium sarcosinate 431-89-0 Propane, 1,1,1,2,3,3,3-Heptafluoro-

4321-69-1 2,7-Naphthalenedisulfonic acid, 5-(acetylamino)-3-{{4-(acetylamino)phenyl}azo}-4-hydroxy-, disodium salt

4337-75-1 Sodium N-dodecanoyl-N-methyltaurine 4365-60-0 Phosphonium, (2-carboxyethyl)triphenyl-, hydroxide-, inner salt

4368-56-3 2-Anthracenesulfonic acid,1-amino-4-(cyclohexylamino)-9,10-dihydro-9,10-dioxo-, monosodium sal

4395-65-7 9,10-Anthracenedione, 1-amino-4-(phenylamino)-

4403-90-1 Benezenesulfonic acid, 2,2'-{(9,10-dihydro-9,10-dioxo-1,4-anthracenediyl)diimino}bis{5-methyl-, disodium salt

4404-43-7 Benenesulfonic acid, 2,2'-(1,2-ethenediyl)bis{5-{{4-{bis(2-hydroxyethy) amino}-6-(phenylamino)-1,3,5-triazin-2-yl}amino}-

441045-43-8

Sulfuric acid, monododecyl ester, compds. with hydrolyzed hexamethylenediamine-N,N'''-1,6-hexanediylbis[N'-cyanoguanidine]-N,N'-(methylenedi-4,1-phenylene)bis[N-(oxiranylmethyl)oxiranemethanamine]polymer hydrochloride

4430-18-6 Benzenesulfonic acid, 2-{(9,10-dihydro-4-hydroxy-9,10-dioxo-1-anthracenyl)amino}-5-methyl-, monosodium salt

4437-85-8 1,3-Dioxolan-2-one, 4-ethyl- 3097-08-3 D-Gluconic acid, zinc complex 4468-42-2 Benzene,(1-ethylbutyl)-

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4474-24-2 Benzenesulfonic acid, 3,3'-((9,10-dihydro-9,10-dioxo-1,4-anthracenediyl)diimino)bis(2,4,6-trimethyl-, disodium salt

4477-79-6 2-Naphthalenol, 1-{{2,5-dimethyl-4-{(2-methylphenyl)azo}phenyl}azo}- 4542-57-8 Dodecyl ether

4548-53-2 1-Naphthlenesulfonic acid, 4-hydroxy-3-((6-sulfo-2,4-xylyl)azo)-, disodium salt

4574-04-3 1-Tetradecanaminium, N,N,N-trimethyl-, chloride 461-58-5 Dicyanodiamide 461679-05-0 Amines, tallow alkyl, ethoxylated, compds. with polyethylene glycol 463-40-1 9,12,15-Octadecatrienoic acid, (9Z, 12Z, 15Z)- 4645-07-2 C.I. Solvent Yellow 72 4696-46-2 Sulfuric acid, monooctadecyl ester, ammonium salt 4696-56-4 Dodecanoic acid, calcium salt 470-08-6 1,3,3-Trimethyl-2-norbornanol, (1S-exo)- 470-67-7 7-Oxabicyclo(2.2.1.)heptane, 1-methyl-4-(1-methylethyl)- 4706-78-9 Potassium dodecyl sulfate 4707-47-5 Benzoic acid,2,4-dihydroxy-3,6-dimethyl-,methyl ester 4712-55-4 Diphenyl phosphite 471-34-1 Calcium carbonate 47236-10-2 Benzenesulfonic acid, 4-dodecyl-, calcium salt 4754-44-3 1-Tetradecanol, hydrogen sulfate 479-61-8 Chlorophyll a 480-16-0 Morin 4845-99-2 Brucine sulfate 487-06-9 2H-1-Benzopyran-2-one, 5,7-dimethoxy- 488-30-2 D-Arabinonic acid 489-01-0 2,6-Di-tert-butyl-4-methoxyphenol 493-52-7 Benzoic acid, 2-((4-(dimethylamino)phenyl)azo)- 4940-11-8 4H-Pyran-4-one, 2-ethyl-3-hydroxy-

4948-15-6 Anthra{2,1,9-def:6,5,10-d'e'f'}diisoquinoline-1,3,8,10 (2H, 9H)-tetrone, 2,9-bis(3,5-dimethylphenyl)-

49553-76-6 9-Octadecenoic acid, ester with 1,2,3-propanetriol 496-46-8 Imidazo(4,5-d)imidazole-2,5(1H,3H)-dione, tetrahydro- 497-19-8 Carbonic acid, disodium salt 498-81-7 Cyclohexanemethanol, alpha, alpha, 4-trimethyl- 499-83-2 2,6-Pyridinedicarboxylic acid 50-14-6 9,10-Secoergosta-5,7,10(19),22-tetraen-3-ol, (3.beta.,5Z,7E,22E)- 50-21-5 Lactic acid 5026-62-0 Sodium methylparaben 5045-40-9 C.I. Pigment Yellow 109 504-60-9 1,3-Pentadiene 506-12-7 Heptadecanoic acid 5064-31-3 Trisodium nitrilotriacetate 50643-20-4 Poly(oxy-1,2-ethanediyl), α-hexadecyl-ω-hydroxy-, phosphate 506-87-6 Carbonic acid, diammonium salt

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CAS Reg. No. Chemical Name 506-93-4 Guanidine nitrate 50-70-4 Sorbitol 50769-39-6 Butylpolyethoxyethanol esters of phosphoric acid 50-81-7 L-Ascorbic acid 509-34-2 Spiro(isobenzofuran-1(3H),9'-(9H)xanthen)-3-one, 3',6'-bis(diethylamino)- 5098-94-2 1-Naphthalenol, 4-{(2-methylphenyl)azo}- 50-99-7 D-Glucose, anhydrous 51-05-8 Procaine hydrochloride 51142-18-8 Bactopeptone 5116-94-9 1-Tridecanol, dihydrogen phosphate 5116-95-0 1-Tridecanol, hydrogen phosphate 51192-09-7 Polyoxyethylene glycerin monooleate 51200-87-4 Oxazolidine, 4,4-dimethyl- 512-13-0 1,3,3-Trimethyl-2-norbornanol, (1S-endo)- 51229-78-8 cis-1-(3-Chloroallyl)-3,5,7-triaza-1-azoniaadamandtine chloride 512-42-5 Sodium methyl sulfate 51274-00-1 C.I. Pigment Yellow 42 5131-66-8 1,2-Propylene glycol 1-monobutyl ether 51344-60-6 Ethoxylated abietylamine

51344-62-8

Poly(oxy-1,2-ethanediyl), α,α'-((((1,2,3,4,4a,9,10,10a-octahydro-1,4a-dimethyl-7-(1-methylethyl)-1-phenanthrenyl)methyl)imino)di-2,1-ethanediyl)bis(ω-hydroxy-,(1R-(1α,4a.beta.,10aα))-

5136-55-0 Glycine, N-methyl-N-(1-oxooctadecyl)-, sodium salt 5137-55-3 Tricaprylyl methyl ammonium chloride 513-77-9 Barium carbonate 513-79-1 Cobalt carbonate 5138-18-1 Sulfosuccinic acid 51395-75-6 Cellulose, mixt. with cellulose carboxymethyl ether sodium salt 5146-66-7 2,6-octadienenitrile, 3,7-dimethyl- 51-55-8 Atropine 515-98-0 Ammonium lactate

51609-41-7 Poly(oxy-1,2-ethanediyl), [alpha]-(4-nonylphenyl)-[omega]-hydroxy-, phosphate

51609-52-0 Egg solids 51617-79-9 Polyoxyethylene octadecyl phenol 51650-46-5 Benzenesulfonic acid, 4-methyl-, magnesium salt 51811-79-1 Poly(oxy-1,2-ethanediyl),α-(nonylphenyl)-ω-hydroxy-,phosphate 518-47-8 Fluorescein, disodium 51937-00-9 9,12-Tetradecadien-1-ol, (9E,12Z)- 519-62-0 Chlorophyll b 52019-36-0 Poly(oxy-1,2-ethanediyl),α-decyl-ω-hydroy-,phosphate 520-45-6 2H-Pyran-2,4(3H)-dione, 3-acetyl-6-methyl- 52225-20-4 Vitamin E acetate (dl-form) 52232-27-6 Methyl oxirane polymer with oxirane, methyl 2-propenyl ether 52238-92-3 C.I. Pigment Red 242

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52277-29-9 Phenol, polymer with formaldehyde, hydroxybenzenesulfonic acid and urea, sodium salt

52286-56-3 Benzenesulfonic acid, octyl-, potassium salt 52299-20-4 2-((Hydroxymethyl)amino)-2-methyl propanol 52304-21-9 1-Hexadecanol, hydrogen sulfate, ammonium salt 52337-77-6 Benzoic acid, 2-methyl-, barium salt

52500-92-2 2,5-Furandione, telomer with ethenylbenzene and (1-methylethyl)benzene, sodium salt

52503-15-8 Poly (oxy-1,2-ethanediyl), [alpha]-(nonylphenyl) -[omega]-hydroxy-,phosphate, potassium salt

52-51-7 Bronopol 52558-73-3 Glycine, N-methyl-N-(1-oxotetradecyl)-

52623-95-7 Poly(oxy-1,2-ethanediyl), α-((1,1,3,3-tetramethylbutyl)phenyl)- ω-hydroxy-, phosphate

52668-97-0 Poly(oxy-1,2-ethanediyl), α-(1-oxooctadecenyl)-ω-[(1-oxooctadecenyl)oxy]-

52673-60-6 Poly(oxy(methyl-1,2-ethanediyl)), α-hydro-ω-hydroxy-, ether with methyl .beta.-D-glucopyranoside (4:1)

52677-44-8 1-Naphthalenesulfonic acid, 4-{{4,5-dihydro-3-methyl-5-oxo-1-(3-sulfophenyl)-1H-pyrazol-4-yl}azo}-3-hydroxy-, chromium complex

526-95-4 D-Gluconic acid 527-07-1 Sodium gluconate 527-09-3 Cupric gluconate 5280-66-0 C.I. Pigment Red 48:4 1234986 C.I. Pigment Red 57:1

52821-24-6 1H-Benz(de)isoquinoline-1,3(2H)-dione, 2-(3-hydroxypropyl)-6-((3-hydroxypropyl)amino)-

52829-07-9 Bis(2,2,6,6-tetramethyl-4-piperidinyl)sebacate 52831-04-6 2-propenoic acid, polymer with ethenylbenzene and (1-methylethenyl)benzene

52831-07-9 Butanedioic acid, methylene-, polymer with 1,3-butadiene, ethenylbenzene and 2-methyl-2-propenoic acid

52836-31-4 Oxazolidine, 3-(dichloroacetyl)-2,2,5-trimethyl- 52880-57-6 Acrylic acid homopolymer, trimethanolamine salt 52-90-4 Cysteine 53124-00-8 Starch, hydrogen phosphate, 2-hydroxypropyl ether 532-02-5 2-Naphthalenesulfonic acid, sodium salt 53219-21-9 Myrcenol, dihydro- 532-32-1 Benzoic acid, sodium salt 5323-95-5 9-Octadecenoic acid, 12-hydroxy-, monosodium salt, (9Z,12R)- 5324-84-5 Sodium octyl sulfonate 5329-14-6 Sulfamic acid 533-00-6 Benzoic acid, barium salt 53306-54-0 1,2-Benzenedicarboxylic acid, bis (2-propylheptyl) ester

53317-61-6 Toluene diisocyanate, oligomeric reaction products with 2,2'-oxydiethanol and. propylidenetrimethanol

53320-86-8 Lithium magnesium sodium silicate

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CAS Reg. No. Chemical Name 5333-42-6 2-Octyl dodecanol 533-74-4 Tetrahydro-3,5-dimethyl-2H-1,3,5-thiadiazine-2-thione 533-96-0 Carbonic acid, sodium salt (2:3) 53404-44-7 9-Octadecenoic acid, 12-(sulfooxy)-, dipotassium salt 53404-45-8 Phosphoric acid, disodium salt, compd. with 2-aminoethanol (1:1) 53404-49-2 Ethylene glycol ether of pinene 53404-78-7 Ethanol, 2-amino-, hydrogen phosphate (ester), monosodium salt 534-13-4 Thiourea, N,N'-dimethyl- 53467-00-8 Sodium dodecyldiphenyl oxide sulfonate 53504-41-9 Polyurethane 53516-76-0 BTC 776 53563-63-6 Tetradecanoic acid, diester with 1,2,3-propanetriol 53610-02-9 Poly(oxy-1,2-ethanediyl),[alpha]-(carboxymethyl)-[omega]-(nonylphenoxy)-

53633-54-8 2-propenoic acid, 2-methyl-, 2-(dimethylamino)ethyl ester, polymer with 1-ethenyl-2-pyrrolidinone, compd. with diethyl sulfate

53651-69-7 Propyl L-lactate

53694-15-8 Poly(oxy-1,2-ethanediyl),alpha-hydro-omega-hydroxy-, ether with D-glucitol (6:1)

53801-42-6 Isobutyl methacrylate homopolymer 53850-34-3 Proteins, thaumatins 5392-40-5 Citral

53956-04-0 alpha-D-Glucopyranosiduronic acid, (3beta, 20beta)-20-carboxy-11-oxo-30-norolean-12-en-3-yl 2-O-beta-D-glucopyranuronosyl-, monoammonium salt

53980-88-4 2-Cyclohexene-1-octanoic acid, 5(or6)-carboxy-4-hexyl- 53988-05-9 Calcium isononanoate 53988-07-1 Decanoic acid, diester with 1, 2 ,3-propanetriol 53998-07-1 Decanoic acid,diester with 1,2,3-propanetriol 540-10-3 Hexadecanoic acid, hexadecyl ester 540-18-1 Amyl butrate 540-69-2 Ammonium formate 540-88-5 Tert-butyl acetate 541-02-6 Cyclopentasiloxane, decamethyl- 54116-08-4 Tridecyl polyoxyethylene sodium sulfate 5413-60-5 4,7-Methano-1H-inden-6-ol, 3a,4,5,6,7,7a-hexahydro-, acetate 5413-75-2 C.I. Acid Red 73 54193-36-1 Sodium polymethacrylate 54-21-7 Sodium salicylate 542-42-7 Hexadecanoic acid, calcium salt 5437-45-6 Acetic acid, bromo-, phenylmethyl ester 54390-90-8 Hypophosphoric acid, ammonium salt 544-31-0 N-(2-Hydroxyethyl)hexadecanamide 54452-17-4 2-Propenoic acid, polymer with ethenylbenzene, sodium salt 544-60-5 Ammonium oleate 544-63-8 Myristic acid 544-64-9 9-Tetradecenoic acid, (9Z)-

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CAS Reg. No. Chemical Name 54549-23-4 D-Glucoside, octyl 54549-24-5 D-Glucopyranoside, hexyl 54579-44-1 Formaldehyde, polymer with p-tert-butylphenol and Bisphenol A 54612-36-1 Nonylphenylpolyoxyethylene sulfosuccinate 5466-77-3 Octyl p-methoxycinnamate

5468-75-7 Butanamide, 2,2'-[(3,3'-dichloro[1,1'-biphenyl]-4,4'-diyl)bis(azo)]bis[N-(2-methylphenyl)-3-oxo

546-93-0 Carbonic acid, magnesium salt (1:1)

54811-79-9 Isocyanic acid, polymethylenepolyphenylene ester, polymer with N-(2-aminoethyl)-1,2-ethanediamine, decanedioyl dichloride and 1,2-ethanediamine

548-26-5 Spiro(isobenzofuran-1(3H),9'-(9H)xanthen)-3-one, 2',4',5',7',-tetrabromo-3',6'-dihydroxy-, disodium salt

54846-79-6 Polyoxyethylene sorbitan heptaoleate 54862-84-9 Iron chloride (FeCl3), dihydrate

55008-57-6 2-Propenoic acid, 2-methyl- 2-(dimethylamino)ethyl ester, polymer with 1-ethenyl-2-pyrrolidinone, compd. with dimethyl sulfate

55069-68-6 Polyethylene glycol hexaether with sorbitol, diester with dodecanoic and oleic acids

55172-98-0 Neodecanoic acid, barium salt 552-30-7 Trimellitic acid andydride (TMA) 55349-01-4 Octadecanamide, N,N'-1,6-hexanediylbis[12-hydroxy- 5536-61-8 Sodium methacrylate 553-70-8 Magnesium benzoate 5538-94-3 1-Octanaminium, N,N-dimethyl-N-octyl-, chloride 55406-53-6 Carbamic acid, butyl-, 3-iodo-2-propynyl ester 554-13-2 Lithium carbonate 55470-69-4 N,N-Dimethyl-1,3-propandiamine dodecyl-4-benzenesulfonate 555-31-7 2-Propanol, aluminum salt 555-35-1 Hexadecanoic acid, aluminum salt 555-43-1 Octadecanoic acid, 1,2,3-propanetriyl ester 55589-62-3 1,2,3-Oxathiazin-4(3H)-one, 6-methyl-, 2,2-dioxide, potassium salt 55598-86-2 Lignosulfonic acid, calcium magnesium salt 55622-30-5 Lithium hydroxide 556-67-2 Cyclotetrasiloxane, octamethyl- 557-04-0 Octadecanoic acid, magnesium salt 557-05-1 Octadecanoic acid, zinc salt 557-09-5 Zinc octanoate

55819-53-9 Propanoic acid, 2-hydroxy-, compd. with N-{3-(dimethylamino)propyl}octadecanamide (1:1)

55840-82-9 C.I. Basic Blue 3 5590-18-1 Isoindolinone yellow 55934-93-5 Tripropylene glycol n-butyl ether

55989-05-4 2-Propenoic acid, 2-methyl-, polymer with ethyl 2-propenoate and methyl 2-methyl-2-propenoate, ammonium salt

56073-24-6 Calcium chloride (CaCl2), hydrate (3:1)

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CAS Reg. No. Chemical Name 56090-69-8 Oxirane, methyl-, polymer with oxirane,monoacetate, 2-propenyl ether 563-71-3 Ferrous carbonate 56388-96-6 Poly(oxyethylene)tridecylacetic acid 56399-31-6 Carbonic acid, disodium salt, heptahydrate 56590-81-9 Plurafac RA 40 56633-27-3 Ethanol, 2-amino-, sulfate (salt)

56709-13-8 Poly(oxymethylene),alpha-(1H,3H,5H-oxazolo{3,4-c}oxazol-7a(7H)-ylmethyl)- omega -hydroxy-

56780-58-6 Starch, 2-hydroxy-3-(trimethylammonio)propyl ether, chloride 56-81-5 Glycerin 56-85-9 Glutamine 56-86-0 L-Glutamic acid 56863-02-6 9,12-Octadecadienamide, N,N-bis(2-hydroxyethyl)-, (Z,Z)-

568-63-8 Spiro(isobenzofuran-1(3H),9'-(9H)xanthen)-3-one,3',6'-dihydroxy-2',4',5',7'-tetraiodo-, disodium salt

56-95-1 Chlorhexidine diacetate 56970-73-1 Bis(1-methylheptyl) maleate 5700-49-2 Ethylenediamine dihydroiodide 57-09-0 N,N,N-Trimethyl-1-hexadecanaminium bromide 57-10-3 Hexadecanoic acid 57-11-4 Octadecanoic acid 57-13-6 Urea 57345-19-4 5H-3,5a-Epoxynaphth{2,1-c}oxepin, dodecahydro-3,8,8,11a-tetramethyl- 5743-26-0 Acetic acid, calcium salt, monohydrate 5743-27-1 L-Ascorbic acid, calcium salt (2:1) 57451-03-3 Triethanolamine nonylphenyl polyoxyethylene* sulfuric acid *(6 moles) 57455-37-5 C.I. Pigment Blue 29 57-48-7 D-Fructose 574-93-6 Phthalocyanine 57-50-1 Sucrose 57-55-6 Propylene glycol 57689-21-1 2-Decanol, hydrogen sulfate, sodium salt 577-11-7 Dioctyl sodium sulfosuccinate 5785-44-4 Calcium citrate tetrahydrate 57866-49-6 Lignosulfonic acid, zinc salt 57-88-5 Cholest-5-en-3-ol (3.beta.)- 58048-89-8 Butyl acrylate, butyl methacrylate, methacrylic acid and styrene copolymer 58-08-2 1H-Purine-2,6-dione, 3,7-dihydro-1,3,7-trimethyl- 58128-22-6 Octadecanoic acid, 12-hydroxy-, homopolymer, octadecanoate 58145-14-5 Ethanol, 2-[bis(2-aminoethyl)amino]- 582-25-2 Benzoic acid, potassium salt 582-25-2 Potassium benzoate 584-08-7 Carbonic acid, dipotassium salt 58430-94-7 3,5,5-Trimethylhexyl acetate 5850-16-8 1-Naphthalenesulfonic acid, 4,4'-{(2,4-dihydroxy-1,3-phenylene)bis(azo)}bis-,

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CAS Reg. No. Chemical Name disodium salt

5850-86-2 Benzenesulfonic acid,4-[(2-hydroxy-1-naphthalenyl)azo]-3-methyl-, monosodium salt

58-56-0 Thiamine mononitrate 58572-79-5 Polyflo 130 5858-33-3 C.I. Acid Red 17, disodium salt 5858-82-2 C.I. Pigment Red 52, disodium salt 58-61-7 Adenosine 58654-67-4 2-Octanone, 5-methyl- 586-62-9 Cyclohexene, 1-methyl-4-(1-methylethylidene)- 58694-75-0 Iron chloride (FeCl3), trihydrate 58694-79-4 Iron chloride (FeCl3), nonahydrate 58694-80-7 Iron chloride (FeCl3), dodecahydrate 5870-93-9 Heptyl butyrate 58748-27-9 Fatty acids, C8-10, propylene esters

58748-38-2 Neodecanoic acid, ethenyl ester, polymer with 2-butenoic acid and ethenyl acetate

587-65-5 2-Chloroacetanilide 587-98-4 Benzenesulfonic acid, 3-((4-(phenylamino)phenyl)azo)-, monosodium salt 58846-77-8 n-Decyl glucoside 58-85-5 Biotin

58855-61-1 Ethanol, 2,2',2''-nitrilotris-, compd. with alpha-tridecyl-omega-hydroxypoly(oxy-1,2-ethanediyl) phosphate

58855-63-3 Ethanol,2,2'-iminobis-,compd. with (9Z)-α-9-octadecenyl-ω-h ydroxypoly(oxy-1,2-ethanediyl)phosphate

58-86-6 D-Xylose 58-95-7 D-Vitamin E acetate 589-68-4 Tetradecanoic acid, 2,3-dihydroxypropyl ester 58985-18-5 Terpineol, dihydro-, acetate 590-00-1 2,4-Hexadienoic acid, potassium salt 59-02-9 (+)-[alpha] - Tocopherol 59029-17-3 9-Octadecenoic acid (9Z)-, ester with oxybis [propanediol] 5905-52-2 Ferrous lactate 59113-22-3 Varisoft 222 59139-23-0 Polyethylene glycol nonylphenyl ether phosphate ethanolamine salt 59189-82-1 4,4'-Isopropylidenediphenol alkyl(C12-C15) phosphites 59219-59-9 Butanoic acid, 4-(dodecylamino)-4-oxo-3-sulfo-, disodium salt 59227-89-3 2H-Azepin-2-one, 1-dodecylhexahydro-

59272-84-3 1-Propanaminium,N-(carboxymethyl)-N,N-dimethyl-3-[(1-oxotetradecyl)amino]-,inner salt

59-30-3 Folic acid 593-29-3 Octadecanoic acid, potassium salt 593-70-4 Fluorochloromethane 593-81-7 Trimethylamine hydrochloride 59-40-5 N-(2-Quinoxalinyl)sulfanilide

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59-43-8 Thiazolium, 3-[(4-amino-2-methyl-5-pyrimidinyl)methyl]-5-(2-hydroxyethyl)-4-methyl- chloride

59487-23-9

2-Naphthalenecarboxamide, 4-{{5-{{{4-(aminocarbonyl)phenyl}amino}carbonyl}-2-methoxyphenyl}azo}-N-(5-chloro-2,4-dimethoxyphenyl)-3-hydroxy-

5949-29-1 Citric acid monohydrate 59-51-8 Racemethionine 59572-10-0 1,3,6,8-Pyrenetetrasulfonic acid, tetrasodium salt 5961-18-2 D-Glucitol, 1-deoxy-1(methylamino)-, N-C18 acyl derivs. 5964-35-2 Ethylenediaminetetraacetic acid (EDTA) tetrapotassium salt 5964-35-2 Tetrapotassium ethylenediaminetetraacetate 59-67-6 Nicotinic acid Sodium carbonate 59720-42-2 1H,3H,5H-Oxazolo(3,4-c)oxazole, methanol deriv. 59766-31-3 Potassium titanium oxide (K2 Ti8 O17) 59766-35-7 Zinc oxide sulfate (Zn4O3(SO4)) 5979-28-2 C.I. Pigment Yellow 16

59800-21-4 Poly(oxy-1,2-ethanediyl), alpha-hydro-omega-hydroxy-, ether with D-glucitol (6:1), (z)-9-octadec

59862-22-5 4-Hexadecanol, hydrogen sulfate, ammonium salt 598-62-9 Carbonic acid, manganese(2+) salt (1:1) 5989-27-5 d-Limonene 59947-98-7 Triton X 193 59947-99-8 beta-D-Glucoside, decyl 59952-82-8 Benzenesulfonic acid, isododecyl-, sodium salt 60-00-4 Ethylenediaminetetraacetic acid 60092-15-1 Maleic anhydride-methylstyrene copolymer sodium salt 60-12-8 Phenyl ethyl alcohol 60177-39-1 Styrene-divinyl benzene copolymer resin matrix 6028-57-5 Octanoic acid, aluminum salt 60-29-7 Ethane, 1,1'-oxybis- 6031-02-3 Benzene,(1-methylpentyl)- 60-33-3 Linoleic acid 60381-61-5 2-Propenoic acid, 2-ethylhexyl ester, polymer with ethenylmethylbenzene 60676-86-0 Silica, vitreous 60684-13-1 Iron chloride (FeCl3), monohydrate 60789-81-3 Dimethylamine citrate

60789-83-5 1-Octadecanaminium, N-(2-(2-carboxyethoxy)ethyl)-N-(2-hydroxyethyl)-N-methyl-

60816-37-7 Dodecylbenzenesulfonic acid, compd. with 1,3-propanediamine 60816-39-9 N,N-Dimethyl-1,3-propanediamine dodecylbenzenesulfonate 60816-63-9 Triethylamine ethylenediaminetetraacetate 60828-78-6 Polyoxyethylene* trimethylnonyl ether *(6 moles) 60828-92-4 Isopropylamine sulfate 60840-85-9 Glycine, N,N-bis(carboxymethyl)-, compd. with N,N-diethylethanamine (1:3)

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CAS Reg. No. Chemical Name 60840-87-1 Ethanesulfonic acid, 2-(9-octadecenylamino)-, monosodium salt, (Z)- 60864-33-7 Benzyl ether of 1,1,3,3-tetramethylbutylphenoxypolyethoxy ethanol 60874-89-7 Polyoxyethylene* methylenebis(diamylphenol) *(18 moles) 60874-90-0 Sodium isopropyl isobutyl naphthalene sulfonate 60883-84-3 Sodium methylnonylnaphthalene sulfonate 60883-89-8 Tridecylbenzenesulfonic acid, dimethylamine salt 60883-90-1 Dimethylamine propylamine tridecylbenzenesulfonate 60933-42-8 Trimethylnaphthalenesulfonic acid sodium salt 609-54-1 Benzenesulfonic acid, 2,5-dimethyl- 6100-05-6 Citric acid, tripotassium salt, monohydrate 6104-30-9 Isobutylidenediurea 6104-58-1 C.I. Acid Blue 90 6104-59-2 C.I. Acid Blue 83 6107-56-8 Calcium octanoate

61181-29-1 2-Propenoic acid, 2-methyl-, dodecyl ester, polymer with 1,2-ethanediyl bis(2-methyl-2-propenoate)

6131-90-4 Acetic acid, sodium salt, trihydrate 6132-02-1 Carbonic acid, disodium salt, decahydrate 6132-04-3 Citric acid, trisodium salt, dihydrate 614-45-9 tert-Butyl perbenzoate 6152-33-6 [1,1'-Biphenyl]-2-ol, sodium salt, tetrahydrate 61524-98-9 Polyoxyethylene* hydroabietyl alcohol *(16 moles) 6153-56-6 Ethanedioic acid, dihydrate 61693-41-2 Ethanol, 2,2'-iminobis-, compd. with hexadecyl dihydrogen phosphate

61702-73-6 1H-Imidiazolium, 1,1-bis(carboxymethyl)-4,5-dihydro-2-undecyl-, hydroxide, disodium salt

61725-89-1 Tridecyloxypoly(ethyleneoxy)* poly(propyleneoxy)**-2-propanol *(9 moles) **(3 moles)

61-73-4 3,7-Bis(dimethylamino)-phenothiazin-5-ium chloride 61757-59-3 Poly(oxy-1,2-ethanediyl), α-(carboxymethyl)-ω-(tridecyloxy)-, sodium salt 61788-44-1 Styrenated phenol 61788-47-4 Fatty acids, coco 61788-48-5 Acetylated lanolin 61788-59-8 Fatty acids, coco, Me esters 61788-60-1 Methyl esters of cottonseed oil 61788-61-2 Fatty acid esters, tallow, Me ester 61788-65-6 Fattys acids, vegetable-oil, potassium salts 61788-66-7 Fatty acids, vegetable-oil 61788-67-8 Fatty acids, vegetable-oil, sulfated, sodium salts 61788-72-5 Octyl epoxytallate 61788-85-0 Castor oil, hydrogenated, ethoxylated 61788-89-4 Fatty acids, C18-unsatd., dimers 61788-92-9 Dimethyl soya alkyl ammonium chloride 61788-93-0 Coco dimethylamine 61789-01-3 Tall oil, epoxidized, 2-ethylhexyl esters

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CAS Reg. No. Chemical Name 61789-14-8 Glycerides, tallow sesqui-, hydrogenated 61789-18-2 Coco alkyltrimethyl quaternary ammonium chlorides 61789-23-9 Fatty acids, corn-oil, potassium salts 61789-24-0 Fatty acids, corn-oil, sodium salts 61789-30-8 Fatty acids, coco, potassium salts 61789-31-9 Fatty acids, coco, sodium salts 61789-36-4 Calcium naphthenate

61789-39-7 1-Propanaminium, 3-amino-N-(carboxymethyl)-N,N-dimethyl-, N-coco acyl derivs., chlorides, sodium salts

61789-40-0 Cocamidopropyl betaine 61789-51-3 Cobalt naphthenate 61789-56-8 Fatty acids, peanut-oil, potassium salts 61789-57-9 Fatty acids, peanut-oil, sodium salts 61789-60-4 Coal tar 61789-65-9 Resin acids and rosin acids, aluminum salts 61789-72-8 Dimethyl benzyl hydrogenated tallow ammonium cation 61789-73-9 Dialkyl(hydrogenated tallow)benzylmethylammonium chloride 61789-75-1 Benzyldimethyl-9-octadecenylammonium chloride 61789-76-2 Cocodiamine 61789-77-3 Dialkyl* dimethyl ammonium chloride *(as in fatty acids of coconut oil)

61789-80-8 Quaternary ammonium compounds, bis(hydrogenated tallow alkyl)dimethyl, chlorides

61789-86-4 Calcium petroleum sulfonates 61789-91-1 Jojoba seed oil 61789-97-7 Tallow 61789-98-8 Cork 61789-99-9 Lard 61790-12-3 Fatty acids, tall-oil 61790-24-7 Fatty acids, soya, potassium salts 61790-25-8 Fatty acids, soya, sodium salts 61790-31-6 Amides, tallow, hydrogenated 61790-33-8 Amines, tallow alkyl 61790-37-2 Fatty acids, tallow 61790-38-3 Fatty acids, tallow, hydrogenated 61790-41-8 Quaternary ammonium compounds,trimethylsoya alkyl, chlorides 61790-47-4 Amines, rosin alkyl 61790-50-9 Potassium salt of wood rosin acids 61790-51-0 Sodium salt of hydrocarbon insoluble fraction of rosin 61790-53-2 Kieselguhr (less than !% crystalline silica) 61790-59-8 Hydrogenated tallow alkyl amine acetate 61790-63-4 Diethanolamine cocoate 61790-66-7 Fatty acids, tall-oil, compds. with diethanolamine 61790-85-0 Ethoxylated N-tallow alkyltrimethylene diamines 61790-86-1 Fatty acids, tall-oil, monoesters with sorbitan, ethoxylated 61790-88-3 Fatty acids, tall-oil, triesters with sorbitan, ethoxylated

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CAS Reg. No. Chemical Name 61790-90-7 Polyoxyethylene* sorbitol hexa tall oil ester *(40 moles) 61790-92-9 Polyoxyethylene* sorbitol penta tall oil ester *(40 moles) 61791-00-2 Polyethylene glycol ester of tall oil fatty acids 61791-01-3 Fatty acids, tall-oil, diesters with polyethylene glycol 61791-06-8 Polyethylene glycol sesquiester of tallow acids 61791-07-9 Fatty acids, soya, ethoxylated 61791-08-0 Polyoxyethylene* monoethanolamide of coconut oil fatty acids *(2 moles)

61791-10-4 Quaternary ammonium compounds, coco alkylbis(hydroxyethyl)methyl, ethoxylated, chlorides

61791-12-6 Castor oil, ethoxylated 61791-14-8 Amines, cocoakyl, ethoxylated 61791-23-9 Soybean oil, ethoxylated 61791-24-0 Amines, soya alkyl, ethoxylated 61791-26-2 Polyoxyethylene* tallow amine *(20 moles) 61791-28-4 Alcohols, tallow, ethoxylated 61791-29-5 Fatty acids, coco, ethoxylated 61791-31-9 N,N-Bis(2-hydroxyethyl)(coconut oil alkyl)amine 61791-34-2 Onium compounds, morpholinium, 4-ethyl-4-soya alkyl, Et sulfates 61791-41-1 Sodium N-methyl-N-(tall-oil alkyl) taurate 61791-44-4 Alkyl* N,N-bis(2-hydroxyethyl)amine *(100% C12-C18) 61791-47-7 Bis(2-hydroxyethyl) cocoamine oxide 61791-48-8 Fatty acid, tall-oil, monoesters with sorbitan 61791-53-5 N-Tallow alkyltrimethylenediamines, oleates 61791-56-8 .beta.-Alanine, N-(2-carboxyethyl)-, N-tallow alkyl derivs., disodium salts 61791-59-1 Glycine, N-methyl-, N-coco acyl derivs., sodium salts 61792-31-2 Dodecanamide, N-[3-(dimethyloxidoamino) propyl]- 617-97-0 Benzenesulfonic acid, 3-methyl- 61814-79-7 C.I. Direct Blue 189

61824-34-8 Poly(oxy-1,2-ethanediyl), . alpha.-hydro-ω-hydroxy-, ether with D-glucitol (1:1), penta-9-octadecenoate, (all-Z)-

61827-84-7 (Octyloxy) poly(oxyethylene) poly(oxypropylene)

61847-48-1 Benzoic acid, 4-{{(2,5-dichlorophenyl)amino}carbonyl}-2-{{2-hydroxy-3-{{(2-methoxyphenyl)amino}carbonyl}-1-naphthalenyl}azo}-, methyl ester

61849-72-7 Polypropylene glycol beta-methyl glucoside ether (4:1) 61916-40-3 Disodium cupric ethylenediaminetetraacetate 61931-75-7 Benzenesulfonic acid, undecyl-, ammonium salt 6197-30-4 2-Ethylhexyl 2-cyano-3,3-diphenylacrylate

62073-57-8 Urea, N,N'bis(hydroxymethyl)-, polymer with formaldehyde and (hydroxymethyl)urea

62147-77-7

Poly(oxy-1,2-ethanediyl), α, α'-{{{4-{(2,5-disulfophenyl)azo}phenyl}imino}di-2,1-ethanediyl}bis{ω-hydroxy-, disodium salt

6227-14-1 C.I. Direct Violet 9, disodium salt 62-33-9 Calcium disodium ethylenediaminetetraacetate 62386-95-2 Methyl vinyl ether-maleic acid copolymer calcium sodium salt,minimum numb

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CAS Reg. No. Chemical Name 624-15-7 2,6-Octadien-1-ol, 3,7-dimethyl- 624-41-9 2-Methyl butyl acetate 62449-33-6 1-Heptadecenyl-2-(hydroxyethyl)imidazolinium chloride 6252-76-2 FD&C Red No. 3 62-54-4 Calcium acetate 62563-36-4 N-Coco beta-aminopropionic acid (No established approval) 62587-57-9 Disodium N-tallow beta-iminodipropionate (No established approval) 6259-76-3 Hexyl salicylate 6272-74-8 N-Lauroyl ester of colaminoformylmethylpyridinium chloride 627-83-8 Octadecanoic acid, 1,2-ethanediyl ester 627-93-0 Hexanedioic acid, dimethyl ester 6283-86-9 2-Ethylhexyl lactate 628-63-7 Amyl acetate 629-25-4 Dodecanoic acid, sodium salt 629-70-9 Cetyl acetate 6303-21-5 Hypophosphorus acid 63089-86-1 Polyoxyethylene sorbitol tetraoleate 63148-52-7 Siloxanes and silicones, di-Me, Me Ph 63148-55-0 Siloxanes and Silicones, di-Me, hydroxy-terminated, ethoxylated 63148-56-1 Siloxanes and silicones, Me 3,3,3-trifluoropropyl 63148-57-2 Poly(methylhydrosiloxane) 63148-62-9 Polydimethylsiloxane, methyl end-blocked 63148-65-2 Polyvinyl butyral 63148-69-6 Alkyd resins

63150-02-7 Butyl methacrylate styrene 2-hydroxyethyl acrylate methyl methacrylate polymer

63150-03-8

2-Propenoic acid, 2-methyl-, dodecyl ester, polymer with eicosyl 2-methyl-2-propenoate, hexadecyl 2-methyl-2-propenoate, octadecyl 2-methyl-2-propenoate, pentadecyl 2-methyl-2-propenoate, tetradecyl 2-methyl-2-propenoate and tridecyl 2-methyl-2-propenoate

631-61-8 Ammonium acetate 63182-08-1 Sodium vinylbenzenesulfonate, polymer with divinylbenzene 63231-60-7 Paraffin waxes and hydrocarbon waxes, microcryst 63231-67-4 Silica gel 63231-81-2 Poly(vinylpyrrolidone-1-hexadecene) 633-03-4 C.I. Basic Green 1 63393-89-5 Coumarone-indene resins 63393-93-1 Isopropyl lanolin 633-96-5 Benezenesulfonic acid, 4-((2-hydroxy-1-naphthalenyl)azo)-, monosodium salt 63-42-3 Lactose 63428-83-1 Polyamides 63428-91-1 Formaldehyde, polymer with p-tert-amylphenol, methyloxirane and oxirane 63428-93-3 Polyoxyethylene p-(tert-amyl)phenol-formaldehyde resin 63449-39-8 Chlorinated wax 63466-93-3 Oxirane, methyl-, polymer with oxirane, ether with oxybis(propanol) (2:1)

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CAS Reg. No. Chemical Name 6358-30-1 C.I. Pigment Violet 23 6358-31-2 Butanamide,2-?(2-methoxy-4-nitrophenyl)azoU-N-(2-methoxyphenyl)-3-oxo- 6358-69-6 1,3,6-Pyrenetrisulfonic acid, 8-hydroxy-, trisodium salt

63589-10-6 2-Anthracenesulfonic acid, 1-amino-9,10-dihydro-4-{(4-methoxyphenyl)amino}-9,10-dioxo-, monosod

6359-45-1 C.I. Basic Violet 16

6359-82-6 Benzenesulfonic acid, 4-(4,5-dihydro-3-methyl-5-oxo-4-(phenylazo)-1H-pyrazol-1-yl)-, sodium salt

6359-90-6 Benezenesulfonic acid, 4-chloro-3-(4,5-dihydro-3-methyl-5-oxo-4-(phenylazo)-1H-pyrazol-1-yl)-, sodium salt

6359-98-4 Benzenesulfonic acid, 2,5-dichloro-4-{4,5-dihydro-3-methyl-5-oxo-4{(4- sulfophenyl)azo}-1H-pyrazol-1-yl}-, disodium salt

63-68-3 L-Methionine 63705-03-3 1,2,3-Propanetriol, homopolymer, diisooctadecanoate 637-12-7 Octadecanoic acid, aluminum salt 637-39-8 Triethanolamine hydrochloride

63744-68-3 Butyl acrylate-ethyl acrylate-methacrylic acid-methyl methacrylate-styrene copolymer

63798-35-6 Starch acetate adipate 6381-77-7 D-erythro-Hex-2-enoic acid, gamma-lactone, monosodium salt 6381-92-6 Glycine, N,N'-1,2-ethanediylbis[N-(carboxymethyl)-, dispdium salt, dihydrate 64-02-8 EDTA tetrasodium salt 64044-51-5 Lactose, monohydrate

6408-63-5 Benzenesulfonic acid, 2,2'-{(9,10-dihydro-9,10-dioxo-1,5-anthracenediyl)diimino}bis{5-methyl-, disodium salt

6408-78-2 C.I. Acid Blue 25

6408-80-6 2-Anthracenesulfonic acid, 1-amino-9,10-dihydro-4-((4-methyl-2-sulfophenyl)amino)-9,10-dioxo-, disodium salt

6410-41-9 2-Naphthalenecarboxamide, N-(5-chloro-2,4-dimethoxyphenyl)-4-{{5-{(diethylamino)sulfonyl}-2-methoxyphenyl}azo}-3-hydroxy-

64114-42-7 Phosphoric acid, monobutyl ester, disodium salt 64116-22-9 Benzenesulfonic acid, 4-(1 -hexyldecyl)-, sodium salt 64130-91-2 Polyoxyethylene (tert-amyl)phenol-formaldehyde resin 1648615 1,3-Dioxolane-2-acetic acid, 2-methyl-, ethyl ester 64147-40-6 Dehydrated castor oil

6416-66-6 2,7-Naphthalenedisulfonic acid,3-[(5-chloro-2-phenoxyphenyl)azo]-4-hydroxy-5-[[(4-methylphenyl)

6416-68-8 Benzenesulfonic acid, 5-(2H-naphtho[1,2-d]triazol-2-yl)-2-(2-phenylethenyl)-, sodium salt

64-17-5 Ethanol 64175-88-8 Polyoxyethylene polyoxypropylene monoisopropanolamide of capric acid

64175-92-4 Polyoxyethylene* polyoxypropylene** monoisopropanolamide of mixed caprylic and capric acids *(5 moles) **(10 moles)

64175-94-6 Calcium chloride hydroxide hypochlorite, dihydrate 64-18-6 Formic acid

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CAS Reg. No. Chemical Name 6419-19-8 Phosphonic acid, {nitrilotris(methylene)}tris- 64-19-7 Acetic acid

6424-75-5 Benzenesulfonic acid, 2-[(4-amino-3-bromo-9,10-dihydro-9,10-dioxo-anthracenyl)amino]-5-methyl-, monosodium salt

6424-85-7 C.I. Acid Blue 40

64365-06-6 Isoparaffinic petroleum hydrocarbons, synthetic (conforming to 21 CFR 561.365)

64365-11-3 Charcoal, activated 64365-17-9 Pentaerythritol ester of maleic anhydride - modified wood rosin 64365-23-7 Siloxanes and silicones, di-Me, hydroxy-terminated, ethoxylated propoxylated

64382-04-3

1,3-Benzenedicarboxylic acid, polymer with 1,3-dihydro-1,3-dioxo-5-isobenzofurancarboxylic acid and 2-ethyl-2-(hydroxymethyl)-1,3-propanediol, (Z,Z)-9,12-octadecadienoate

64399-38-8

2-Propenoic acid, 2-methyl-, 2-(diethylamino)ethyl ester, polymer with dodecyl 2-methyl-2-propenoate, ethenylbenzene, hexadecyl 2-methyl-2-propenoate and tetradecyl 2-methyl-2-propenoate

6440-58-0 Dimethylol-5,5-dimethylhydantoin 64427-33-4 Hi-Sol 10

64519-82-0 D-Glucitol, 6-O-alpha-D-glucopyranosyl-, mixt. with 1-O-alpha-D-glucopyranosyl-D-mannitol

64665-10-7 Sodium tributylnaphthalenesulfonate 64665-57-2 Methyl-1H-benzotriazole, sodium salt

64683-40-5 2-Naphthalenesulfonic acid, 7-amino-4-hydroxy-3-??4-?(4-sulfophenyl)azoUphenylUazoU-, compd. with 2,2',2''-nitrilotris?ethanolU (1:2)

6471-49-4 C.I. Pigment Red No. 23 64741-41-9 Naphtha (petroleum), heavy straight run 64741-50-0 Distillates (petroleum), light paraffinic 64741-51-1 Distillates (petroleum), heavy paraffinic 64741-52-2 Distillates (petroleum), light naphthenic 64741-53-3 Distillates (petroleum), heavy naphthenic 64741-59-9 Distillates (petroleum), light catalytic cracked 64741-65-7 Naphtha (petroleum), heavy alkylate 64741-66-8 Naphtha, petroleum, light alkylate 64741-67-9 Residues (petroleum), catalytic reformer fractionator 64741-88-4 Distillates, petroleum, solvent-refined heavy paraffinic 64741-89-5 Distillates, petroleum, solvent-refined light paraffinic 64742-14-9 Distillates (petroleum), acid treated light 64742-16-1 Petroleum resins 64742-42-3 Petroleum wax, clay-treated, microcryst. 64742-43-4 Paraffin waxes (petroleum), clay-treated 64742-46-7 Distillates (petroleum) hydrotreated middle 64742-47-8 Distillates (petroleum), hydrotreated light 64742-48-9 Aliphatic oil 64742-51-4 Petroleum wax 64742-54-7 Distillates (petroleum), hydrotreated heavy paraffinic

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CAS Reg. No. Chemical Name 64742-55-8 Distillates (petroleum), hydrotreated light paraffinic 64742-56-9 Distillate (petroleum), solvent dewaxed light paraffinic distillate 64742-65-0 Distillates (petroleum), solvent-dewaxed heavy paraffinic 64742-69-4 Petrolatum 64742-81-0 Kerosene (petroleum) hydrodesulfurized 64742-88-7 Solvent naphtha (petroleum), medium aliphatic 64742-89-8 Solvent naphtha (petroleum), light aliph. 64742-94-5 Heavy aromatic solvent naphtha (petroleum) 64742-95-6 Solvent naphtha (petroleum), light aromatic 64742-96-7 Solvent naphtha (petroleum), heavy aliphatic 64743-02-8 Alkenes, α- 64754-90-1 Chlorinated polyethylene 64754-97-8 Fatty acids, coco, calcium salts 64755-04-0 Hydroxylated aminoethylamide

64755-05-1 Quaternary ammonium compounds, bis(hydroxyethyl)methyltallow alkyl, ethoxylated, chlorides

64771-72-8 Paraffins (petroleum), normal C5-20 6484-52-2 Ammonium nitrate 6485-40-1 2-Cyclohexen-1-one,2-methyl-5-(1-methylethenyl)-,(5R)- 64-86-8 Colchicine 6487-39-4 Lanthanum carbonate octahydrate (La2(CO3)3.8H2O) 65071-95-6 Polyoxyethylene tall-oil (Mol. Wt. 700-5000) 65072-00-6 Caseins, hydrolyzates 65087-00-5 1,3-Benzenediol, 2,4-bis[(4-dodecylphenyl)azo]- 65122-06-7 C.I. Basic Red 14 acetate 65138-84-3 1-Hexadecanol, dihydrogen phosphate, compd. with diethanolamine (1:2) 65143-89-7 Disodium hexadecyldiphenyloxide disulfonate 65212-77-3 C.I. Pigment Yellow 183 65-23-6 3,4-Pyridinedimethanol, 5-hydroxy-6-methyl- 6528-34-3 Butanamide, 2-[(4-methoxy-2-nitrophenyl)azo]-N-(2-methoxyphenyl}-3-oxo- 65330-59-8 1,2,3-propanetricarboxylic acid, 2-hydroxy-, copper(2+) sodium salt (1:1:2) 65381-09-1 Decanoic acid, ester with 1,2,3-propanetriol octanoate

65392-81-6 Xanthylium, 9-(2,4-dicarboxyphenyl)-3,6-bis(diethylamino)-, hydroxide, inner salt, sodium salt

65405-40-5

2-Propenoic acid, 2-methyl-, dodecyl ester, polymer with hexadecyl 2-methyl-2-propenoate, octadecyl 2-methyl-2-propenoate and tetradecyl 2-methyl-2-propenoate

6542-37-6 1H,3H,5H-Oxazolo(3,4-c)oxazole-7a(7H)-methanol

65447-77-0 Butanedioic acid, dimethyl ester, polymer with 4-hydroxy-2,2,6,6-tetramethyl-1-piperidineethanol (For colorant use only)

65530-66-7 Poly(difluoromethylene), α-fluoro-ω-[2-[(2-methyl-1-oxo-2- propenyl)oxy]ethyl]-

65530-85-0 alpha-(Cyclohexylmethyl)-omega-hydropoly(difluoromethylene)

65545-80-4 Poly(oxy-1,2-ethanediyl), alpha-hydro-omega-hydroxy-, ether with alpha-fluoro-omega-(2-hydroxyethyl)poly(difluoromethylene) (1:1)

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CAS Reg. No. Chemical Name 65573-03-7 9-Octadecenoic acid (9Z)- hexaester with decaglycerol 657-84-1 Benzenesulfonic acid, 4-methyl-, sodium salt 65-85-0 Benzoic acid 65996-61-4 Pulp, cellulose 65996-63-6 Starch, acid-hydrolyzed 65996-94-3 Phosphate rock and Phosphorite, calcined 65996-98-7 Terpenes and terpenoids, limonene fraction 65997-05-9 Rosin, partially dimerized 65997-06-0 Rosin, partially hydrogenated 65997-10-6 Rosin, fumarated, polymer with glycerol 65997-13-9 Resin acids and rosin acids, hydrogenated , esters with glycerol 65997-15-1 Cement, portland, chemicals 66068-84-6 Cyclohexanol, 4-(5,5,6-trimethylbicyclo{2.2.1}hept-2-yl)- 66070-58-4 Benzene, ethenyl-, polymer with 1,3-butadiene, hydrogenated 66070-60-8 Soybean oil,polymer with pentaerythritol and phthalic anhydride 66070-61-9 Soybean oil, polymer with glycerol and pentaerythritol

66070-62-0 Fatty acids, tall-oil, polymers with glycerol, pentaerythritol and phthalic anhydride

66070-64-2 Linseed oil, polymer with pentaerythritol and phthalic anhydride

66070-65-3 Soybean oil, polymer with glycerol, linseed oil, pentaerythritol and phthalic anhydride

66070-75-5 Fatty acids, tall-oil, polymers with bisphenol A and epichlorohydrin 66070-87-9 Polyglyceryl phthalate ester of coconut oil fatty acid (Mol. Wt. 1000-3000) 66070-93-7 Soybean oil, polymer with glycerol, pentaerythritol and phathalic anhydride 66071-03-2 Linseed oil, polymd.,oxidized 66071-16-7 Soybean oil, polymer with maleic anhydride

66071-79-2 Fatty acids, tall-oil, polymers with glycerol, pentaerythritol, phthalic anhydride and rosin

66071-86-1 Soybean oil, polymer with isophthalic acid and pentaerythritol 66071-93-0 Fatty acids, cottonseed-oil, potassium salts 66071-94-1 Corn, steep liquor 66071-95-2 Fatty acids, cottonseed-oil, sodium salts 66071-96-3 Glutens, corn 661-19-8 1-Docosanol

66197-78-2 3,6,9,12,15,18,21,24,-Octaoxahexacosan-1-ol, 26-(nonylphenoxy)-, dihydrogen phosphate

6623-40-1 Dimethylamine sulfonate

6625-46-3 2,7-Naphthalenedisulfonic acid, 5-(acetylamino)-4-hydroxy-3-((2-methoxyphenyl)azo)-, disodium salt

66402-68-4 Metakaolin 66455-14-9 Alcohols, C12-13, ethoxylated 66455-15-0 Alcohols, C10-14, ethoxylated

66507-71-9 2,2',2"-Nitrilotrisethanol polymer with 1,4-dichloro-2-butene and N,N,N',N'- tetramethyl-2-butene-1,4-diamine

66-71-7 1,10-Phenanthroline

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CAS Reg. No. Chemical Name 66733-21-9 Erionite

6683-19-8 Benzenepropanoic acid,3,5-bis(1,1-dimethylethyl)-4-hydroxy-,2,2-bis{{3-{3,5-bis(1,1-dimethylethyl

66988-04-3 Isooctadecanoic acid, 2-(1-carboxyethoxy)-1-methyl-2-oxoethyl ester, sodium salt

66988-47-4 Polyoxyethylene polyoxypropylene mono(4-nonylphenyl) ether

67-03-8 Thiazolium, 3-[(4-amino-2-methyl-5-pyrimidinyl)methyl]-5-(2-hydroxyethyl)-4-methyl-chlorode, monohydrochloride

6706-59-8 L-Gulitol 67254-73-3 Glycerides, mixed mono- and di- 67254-79-9 Fatty acids 67267-95-2 Benzenesulfonic acid, 4-(1 -heptylnonyl)-, sodium salt 6728-26-3 2-Hexenal, (2E)- 6737-68-4 1,4-Bis(2-methylanilino)anthraquinone 67401-50-7 Tetrasodium ethylenediaminetetraacetate trihydrate 67409-24-9 Sodium lauryl glyceryl ether sulfonate 67-43-6 Diethylene triamine pentaacetic acid 67-48-1 Choline chloride 67554-50-1 Phenol, octyl- 67-56-1 Methanol 67-63-0 Isopropyl alcohol 67633-86-7 Sulfuric acid, monooctyl ester, magnesium salt 67633-88-9 Sulfuric acid, monooctyl ester, ammonium salt 67-64-1 Acetone 67674-67-3 3-(Polyoxyethylene)propylheptamethyltrisiloxane 67-68-5 Dimethyl sulfoxide 67700-49-6 Rosin polymer with p-tert-butylphenol, formaldehyde and glycerol

67700-71-4 Fatty acids, tall-oil, polymer with maleic anhydride, pentaerythritol and phthalic anhydride

67700-73-6 Soya alkyd resin

67700-76-9 Soybean oil, polymer with ethylene glycol, pentaerythritol and phthalic anhydride

67700-81-6 Linseed oil, polymer with isophthalic acid and trimethylolpropane 67700-92-9 Fatty acids, tall-oil, polymers with pentaerythritol and phthalic anhydride 67701-05-7 Fatty acids, C8-18 and C18-unsatd. 67701-08-0 Fatty acids, C16-18 and C18-unsatd. 67701-09-1 Fatty acids, C8-18 and C18-unsatd., potassium salts 67701-10-4 Fatty acids, C8-18 and C18-unsatd., sodium salts 67701-31-9 Glycerides, C8-18 and C18-unsatd. mono- and di- 67701-33-1 Glycerides, C14-18 mono- and di- 67746-02-5 Fatty acids, coco, polymers with glycerol and phthalic anhydride 67746-05-8 Tall oil fatty acid isophthalic alkyd 67746-08-1 Linseed oil, polymd.

67761-98-2 Fatty acids, tall-oil, polymer with ethylene glycol, pentaerythritol, and phthalic anhydride

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67762-09-8 Soybean oil, polymer with ethylene glycol, glycerol, pentaerythritol and phthalic anhydride

67762-11-2 Soybean oil, polymer w. fumaric acid, pentaerythritol and phthalic anhydride

67762-12-3 Soybean oil, polymer w. glycerol, maleic acid, pentaerythritol, and phthalic anhydride

67762-15-6 Soybean oil, polymer with maleic anhydride, pentaerythritol and phthalic anhydride

67762-19-0 Poly(oxy-1,2-ethanediyl),alpha-sulfo-omega-hydroxy-, C10-16-alkyl ethers, ammonium salts

67762-27-0 Alcohols, C16-18 67762-38-3 Fatty acids, C16-18 & C18-unsatd., Me esters

67762-84-9 Silanes and siloxanes, 3-cyanopropyl Me, di-Me, 3-hydroxypropyl Me, ethers with polyethylene-polypropylene glycol mono-Me ether

67762-85-0 Siloxanes and silicones, di-Me, 3-hydroxypropyl Me, ethers with polyethylene-polypropylene glycol mono-Me ether

67762-85-0 Silicone - glycol copolymer

67762-87-2 Siloxanes and silicones, di-Me, 3-hydroxypropyl Me, ethers with polyethylene-polypropylene glyc

67762-90-7 Dimethyl siloxane polymer with silica 67762-94-1 Siloxanes and silicones, di-Me, Me vinyl

67762-96-3 Siloxanes and silicones, di-Me,hydroxy-terminated, ethers with polypropylene glycol mono-Bu eth

67762-97-4 Siloxanes and silicones, ethoxy Me 67763-08-0 Alcohols, C-20-28, ethoxlated 67774-59-8 Soybean oil, polymer with glycerol, isophthalic acid and pentaerythritol 67784-88-7 Glycerides, palm-oil mono- and di-, hydrogenated, ethoxylated 67785-93-7 Potassium sulfatoricinoleate

67785-94-8 9-Octadecenamide, N,N'-{iminobis(2,1-ethanediylimino-2,1-ethanediyl)}bis-, (Z,Z)-

67786-14-5 2-Naphthalenesulfonic acid, 6-amino-4-hydroxy-5-{{2-(trifluoromethyl)phenyl}azo}-, monosodium s

67806-10-4 Tetradecanamide, N-[3-(dimethyoxidoamino)propyl]- 67874-52-6 Barium methyl benzoate 67890-05-5 Benzenesulfonic acid, isodecyl-, calcium salt 67891-79-6 Heavy aromatic distillate (petroleum) 67891-80-9 Light aromatic distillate (petroleum)

67892-91-5 2-Propenoic acid, 2-methyl-, polymer with butyl 2-propenoate, ethene, ethenylbenzene, ethyl 2-propenoate and methyl 2-methyl-2-propenoate

67905-86-6 1,2-Ethanediamine, N-(2-aminoethyl)-, polymer with 1,2-dichloroethane and (Z)-9-octadecen-1-amine

67906-06-3 Polyethylene glycol ether with 2,2'-methylenebis(4,6-bis(tert-pentyl)phenol) (2:1)

67906-08-5 Polyethylene glycol monoeicosyl ether

67922-57-0 a-(p-Nonylphenyl)-omega-hydroxypolyoxyethylene, mixture of monohydrogen and dihydrogen phosphate esters, magnesium salt

67922-98-9 Linseed oil, polymer with maleic anhydride and pentaerythritol

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67923-65-3 Benzezesulfonic acid, 2,5-dichloro-4-{4,5-dihydro-3-methyl-4-{{4-{{(4-methylphenyl)sulfonyl}oxy

67924-20-3 Benzenesulfonic acid, 4-dodecyl-, compd. with 2-[(2-aminoethyl)amino]ethanol (2:1)

67952-66-3 Ethylenediamine dodecylbenzenesulfonate 67952-68-5 Bicyclo{2.2.1}heptan-2-ol, ethyl-1,3,3-trimethyl-

67953-82-6 Phenol, 4-dodecyl-, polymer with 1,2-ethanediamine and formaldehyde, compd. with (dibutylamino)methanol

67-97-0 Vitamin D3 6798-76-1 Zinc abietate 67989-28-0 Soybean oil, polymer with pentaerythritol, toluenediisocyanate and tung oil 67990-27-6 C.I. Solvent Yellow 107

67990-40-3 2-Propen-1-aminium, N,N-dimethyl-N-2-propenyl-, chloride, polymer with 2-hydroxypropyl 2-propenoate and 2-propenoic acid

67993-50-4 Dodecyl diphenyl ether disulfonic acid 68002-20-0 1,3,5-Triazine-2,4,6-triamine, polymer with formaldehyde, methylated 68002-63-1 Quaternary ammonium compound, C14-18-alkyl trimethyl, chloride 68002-70-0 Glycerides, C16-22 68002-73-3 Fatty acids, vegetable-oil, calcium salts 68002-96-0 Alcohols, C16-18, ethoxylated propoxylated 68002-97-1 Alcohols, C10-16, ethoxylated 68015-39-4 Fatty acids, tall-oil, polymers with glycerol, phthalic anhydride and rosin

68035-71-2

Cuprate(2-), (29H,31H-phthalocyaninedisulfonato(4-)-kappaN29,kappaN30,kappaN31,kappaN32)-, (SP-4-1)-, dihydrogen, compd. with 2,2',2''-nitrilotris(ethanol) (1:2)

68037-05-8 Ammonium C6-10-alkyl polyoxyethylene sulfate 68037-40-1 2,5-Furandione, polymer with ethylbenzene, sulfonated, sodium salt

68037-62-7 Siloxanes and silicones, di-Me, Me hydrogen,reaction products with polyethylene glycol monoacet

68037-64-9 Siloxanes and silicones, di-Me, Me hydrogen, reaction products with polyethylene-polypropylene glycol monoacetate allyl ether

68037-65-0 Siloxanes and Silicones, di-Me, di-Ph, Me Ph, polymers with Me Ph silsesquioxanes

68037-66-1 Siloxanes and Silicones, di-Me, Me Ph, polymers with Me Ph silsesquioxanes 68037-81-0 Siloxanes and Silicones, di-Ph, Me Ph, polymers with Me Ph silsesquioxanes 68038-31-3 Fatty acids, tall-oil, polymers with pentaerythritol, phthalic anhydride and rosin 68038-60-8 Bacillus amyloliquefaciens 68038-66-4 Bacillus licheniformis 68038-70-0 Bacillus subtilis 68038-71-1 Bacillus thuringiensis

68039-12-3 1H-Imidazolium, 1-ethyl-2-(8-heptadecenyl)-4,5-dihydro-3-(2-hydroxyethyl)-, ethyl sulfate (salt)

68-04-2 Citric acid, trisodium salt 68070-94-0 Dextrin, hydrogen 1-octenylbutanedioate 68071-17-0 Poly(oxy-1,2-ethanediyl), α-isodecyl-ω-hydroxy-,phosphate, potassium salt

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CAS Reg. No. Chemical Name 68071-29-4 Phenol, natural rubber resin

68071-54-5 Castor oil polymer with p-tert-butylbenzoic acid, glycerol and phthalic anhydride

68071-65-8 Fatty acids, C18-unsatd., dimers, polymers with tall-oil fatty acids, tetraethylenepentamine and triethylenetetramine

68081-81-2 Benzenesulfonic acid, C10-16-alkyl derivs., sodium salts 68081-96-9 Sulfuric acid, mono-C10-16-alkyl esters, ammonium salts 68081-97-0 Sulfuric acid, mono-C10-16-alkyl esters, magnesium salts 68082-28-0 Fatty acids, C18-unsatd., dimers, polymers with ethylene glycol 68082-64-4 Fatty acids, vegetable-oil, sodium salts 68083-14-7 Polydimethyldiphenyl siloxane copolymer 68083-64-7 Epichlorohydrin, polymer with hexamethylenetetramine 68084-55-9 2-((2-Aminoethyl)amino)ethanol dodecylbenzenesulfonate 68092-47-7 Benzoic acid, 3-methyl-, barium salt 68122-64-5 Soybean oil, polymerized

68122-86-1 1-Methyl-1-alkyl* amidoethyl-2-alkyl*-imidazolinimethosulfate *(30% C16, 70% C18)

68130-43-8 Sulfuric acid, mono-C8-18-alkyl esters, sodium salts

68130-47-2 Poly(oxy-1-ethanediyl), alpha-hydro-omega-hydroxy-mono-C8-10-alkyl ethers, phosphates

68131-04-4 Humic acids, sodium salt 68131-12-4 Meat, meal

68131-29-3 Soybean oil, polymer with phthalic anhydride, trimellitic anhydride and trimethylolpropane

68131-37-3 Corn syrup 68131-39-5 Alcohols, C10-14, ethoxylated 68131-40-8 Alkyl* poly(ethyleneoxy)ethanol *(100% C11-15)

68131-54-4 Caseins, potassium complexes (allergenic food commodity - use pattern is limited)

68131-65-7 Fatty acids, soya, calcium salts 68131-77-1 Distillates (petroleum), steam-cracked, polymd.

68131-89-5 Distillates (petroleum), steam-cracked, polymers with ethylene-manuf.-by-product piperylene-cut

68132-78-5 Tallow amine hydrochloride, ethoxylated

68132-96-7 Poly(oxy(methyl-1,2-ethanediyl)),α-(2-(diethylmethylammonio)ethyl)-ω-hydroxy-, chloride

68133-37-9 Diethanolamine ethylenediaminetetraacetate

68139-30-0 1-Propanaminium, N-(3-aminopropyl)-2-hydroxy-N,N-dimethyl-3-sulfo-,N-coco acyl derivs., hydroxides, inner salts

68139-80-0 Fatty acids, tall-oil, polymers with C18-unsatd fatty acid dimers and ethylenediamine

68139-89-9 Tall oil fatty acids-maleic anhydride resin 68139-91-3 Fatty acids, coco, diesters with polyethylene glycol 68140-00-1 Coco ethanolamides 68140-76-1 1,1'-(Methylimino)bis(3-chloro-2-propanol), polymer with N,N,N'N'-

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CAS Reg. No. Chemical Name tetra,ethyl-1,2-ethanediamine

68152-55-6 Fumarated rosin ethylene glycol polymer 68152-57-8 Rosin, fumarated, polymer with ethylene glycol and pentaerythritol 68152-62-5 Rosin, maleated, polymer with pentaerythritol, formaldehyde and nonylphenol 68153-10-6 Oils, lard, sulfated, sodium salts, 68153-22-0 Carboxypolymethylene resin

68153-30-0 Quaternary ammonium compounds, benzylbis (hydrogenated tallow alkyl)methyl, salts with bentonite

68153-76-4 Glycerides, C14-18 mono- and di-, ethoxylated 68153-88-8 Linseed oil bisphenol A p-tert-butylphenol formaldehyde tung oil polymer 68154-33-6 Fatty acids, coco, esters with sorbitan, ethoxylated- 68154-36-9 Sorbitan coconut oil ester 68154-96-1 Alcohols, C14-18, ethoxylated 68155-01-1 Polyoxyethylene* cetyl and oleyl alcohols *(2.5 moles) 68155-09-9 Cocoamidopropyl dimethylamine oxide 68155-20-4 Amides, tall-oil fatty, N,N-bis(hydroxyethyl) 68155-33-9 Ethoxylated C14-18-alkylamine 68155-40-8 Amines, C16-18 and C18 unsatd. alkyl, ethoxylated

68155-60-2 1,5-Naphthalenedisulfonic acid, 3,3'-[[6-[bis(2-hydroxyethyl)amino]-1,3,5-triazine-2,4-diyl]bis

68155-92-0

Cuprate(2-), {29H,31H-phthalocyanine-C,C-disulfonato(4-)-N29,N30,N31,N32}-, dihydrogen, compd. with 2-ethyl-N-(2-ethylhexyl)-1-hexanamine (1:2)

68171-29-9 Triethanolamine tris(dihydrogen phosphate) sodium salt

68186-36-7 Poly(oxy-1,2-ethanediyl), alpha-tridecyl-omega-hydroxy-, phosphate, potassium salt

68186-90-3 C. I. Pigment Brown 24 68187-17-7 Sulfuric acid, mono-C6-10-alkyl esters, ammonium salts 68187-51-9 C.I. Pigment Yellow 119

68187-69-9 Quaternary ammonium compounds, (hydrogenated tallow alkyl)bis(hydroxyethyl)methyl, ethoxylated, chlorides

68187-71-3 Calcium salts of tall-oil fatty acids 68187-76-8 Castor oil, sulfated, sodium salt 68187-84-8 Castor oil, epoxidized 68187-85-9 Fatty acids, tall-oil, esters with ethylene glycol 68188-27-2 Pentaerythritol ester of tall oil 68188-45-4 Sulfuric acid, mono-C>10-alkyl esters, sodium salts 68-19-9 Vitamin B12 68201-23-0 Lignin, alkali, oxidized, sodium salt 68201-46-7 Glycerides, coco mono- and di-, ethoxylated 68201-47-8 Glycerides, soya mono- 68201-51-4 Oils, menhaden, oxidized 682-01-9 Silicic acid (H4SiO4), tetrapropyl ester 68213-23-0 POE alkyl(C10-C18) alcohol 68213-57-0 Oils, menhaden, polymerized

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CAS Reg. No. Chemical Name 68227-33-8 6-Dodecyne-5,8-diol, 2,5,8,11-tetramethyl-

68239-42-9 Poly(oxy-1,2-ethanediyl), α-hydro-ω-hydroxy-, ether with methyl β-D-glucopyranoside (4:1)

68-26-8 Vitamin A 68299-17-2 Sulfuric acid, monoisodecyl ester, sodium salt 68308-36-1 Soybean meal 68308-50-9 Fatty acids, corn-oil 68308-51-0 Fatty acids, cottonseed-oil 68308-53-2 Fatty acids, soya 68308-74-7 N,N-Dimethyl tall-oil fatty amides 68309-24-0 Fatty acids, tall-oil, polymers with maleic anhydride 68309-27-3 Fatty acids, tall-oil, sulfonated, sodium salts 68309-36-4 Ethoxylated vegetable oils and animal fats 68309-49-9 Soybean oil, polymer with isophthalic acid, linseed oil and trimethylolpropane 68309-52-4 Linseed oil, polymer with maleic anhydride and tung oil 68310-04-3 1,3-Benzenediol, 4-[(2,4-dimethylphenyl)azo]-2-[(4-dodecylphenyl)azo]-

68311-23-9 Poly(oxy-1,2-ethanediyl), α-(carboxymethyl)-omega-(sec-pentadecyloxy)-, sodium salt

68332-64-9

α-(p-tert-Butylphenyl)-omega-hydroxypoly(oxyethylene) mixture of dihydrogen phosphate and monohydrogen phosphate esters:the poly(oxyethylene) content is 4-12 moles

68333-69-7 Rosin, maleated, polymer with pentaerythritol 68333-79-9 Polyphosphoric acids, ammonium salts 68334-00-9 Hydrogenated cottonseed oil 68334-30-5 Diesel fuel 68334-35-0 Resin acids and rosin acids, calcium zinc salts 6834-92-0 Silicic acid (H2SiO3), disodium salt 68390-56-7 Fatty acids, tallow, hydrogenated, dimers, diketene derivs.

68390-66-9 2-Cocyl-2-imidazolinium hydroxide-1-(2-hydroxyethyl)-1-carboxymethyl sodium salt, sodium alcoholate

68390-99-8 Amines, C14-18-alkyldimethyl, N-oxides 68391-01-5 Quaternary ammonium compounds, benzyl-C12-18-alkyldimethyl, chlorides 68409-75-6 Bone meal 68409-80-3 Fatty acids, C6-19-branched, calcium salts 68410-38-8 Fatty acids, tallow, hydrogenated, ethoxylated propoxylated 68410-46-8 Gelatins, reaction products with glutaraldehyde

68411-04-1 Copper, {29H, 31H-phthalocyaninato(2-)-N29,N30,N31,N32}-, {{3-(dimethylamino)propyl}amino}sulfonyl derivs.

68411-27-8 Benzoic acid, C12-15-alkyl esters 68411-30-3 Sodium alkylbenzene sulfonate 68411-32-5 Benzenesulfonic acid, dodecyl-, branched 68411-97-2 Glycine, N-methyl-, N-coco acyl derivs. 68412-53-3 Poly(oxy-1,2-ethanediyl), α-(nonylphenyl)-ω-hydroxy-, branched, phosphates 68412-54-4 Poly(oxy-1,2-ethanediyl), [alpha]-(nonylphenyl)-omega-hydroxy-, branched 68413-17-2 Fatty acids, tall-oil, polymers with isophthalic acid, pentaerythritol and walnut

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CAS Reg. No. Chemical Name oil

68422-69-5 Sulfated butyl oleate 68424-10-2 Cottonseed meal 68424-45-3 Fatty acids, linseed-oil 68424-50-0 Fatty acids, tall-oil, C12-15-alkyl esters, sulfated, sodium salts 68424-61-3 Glycerides, C16-18 and C18-unsatd. mono- and di- 68424-85-1 Alkyl* dimethyl benzyl ammonium chloride *(50% C14, 40% C12, 10% C16) 68424-94-2 Betaines, coco alkyldimethyl 68425-13-8 2-Methyl-1,3-butadiene, homopolymer (as latex) 68425-17-2 Syrups, hydrolyzed starch, hydrogenated 68425-57-0 Phosphoric acid, mixed decyl and octyl esters, compds. with diethanolamine

68425-58-1 Benzene, ethenylmethyl-, polymer with ethenylbenzene and (1-methylethenyl)benzene

68425-94-5 Residues (petroleum), catalytic reformer fractionator, sulfonated, polymers with formaldehyde, sodium salts

68427-35-0 5-Benzoxazolesulfonamide, 2-(7-(diethylamino)-2-oxo-2H-1-benzopyran-3-yl)-

68439-30-5 Oxirane, methyl-, polymer with oxirane, 8-methylnonyl ether 68439-45-2 Alcohols, C6-12, ethoxylated 68439-46-3 Alcohols, C9-11, ethoxylated 68439-48-5 Alcohols, C-20/30, ethoxylated 68439-49-6 Alcohols, C16-18, ethoxylated 68439-50-9 Alcohols, C12-14, ethoxylated 68439-51-0 Alcohols, C12-14, ethoxylated propoxylated 68439-56-5 Alkenes, C13-18 alpha-, sulfonated, sodium salts 68439-57-6 Mixed alkyl sulfates 68439-70-3 Amines, C12-16-alkyldimethyl 68439-72-5 Amines, C8-18 and C18-unsatd. alkyl, ethoxylated 68440-19-7 Fatty acids, safflower-oil, sodium salts

68440-66-4 Siloxanes and silicones, di-Me, 3-hydroxypropyl Me, ethers with polypropylene glycol mono-Bu et

68440-90-4 Siloxanes and silicones, Me octyl 68441-17-8 Oxidized polyethylene 68441-73-6 Ethene, homopolymer, oxidized, potassium salt 68441-84-9 Sodium salt of cresol sulfonic acid condensed with urea formaldehyde 68442-09-1 Naphthalenesulfonic acid, sodium salt, isopropylated 68442-82-0 Calcium carbonate dimethylhexanoate 68442-85-3 Cellulose, regenerated 68443-05-0 Sodium sulfonated oleate

6844-74-2 2,7-Naphthalenedisulfonic acid, 4-hydroxy-5-(((4-methylphenyl)sulfonyl)amino)-3-(phenylazo)-, disodium salt

68457-75-0 Butylated, styreneated cresols 68458-48-0 Decyl alcohol, ethoxylated, phosphated 68458-49-1 Polyphosphoric acids, esters with polyethylene glycol nonylphenyl ether 68458-88-8 Lanolin, ethoxylated propoxylated

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CAS Reg. No. Chemical Name 68459-31-4 C9-19-fatty acid ester phthalic alkyd

68459-87-0 Oxirane, methyl-, polymer with alpha-butyl-omega-hydroxypoly(oxy-1,2-ethanediyl) and oxirane

6846-50-0 2,2,4-Trimethyl-1,3-pentanediol diisobutyrate 68476-25-5 Feldspar 68476-30-2 Fuel oil, no. 2 68476-31-3 Fuel oil, no. 4 68476-33-5 Residual fuel oil 68476-37-9 Glue (as depolymd. animal collagen) 68476-40-4 Hydrocarbons, C3-4 68476-78-8 Cane syrup 68476-82-4 Peanut meal 68476-86-8 Petroleum gases, liquefied, sweetened 68477-30-5 Aromatic petroleum hydrocarbon solvent 68477-31-6 Aromatic petroleum derivative solvent 68477-33-8 Propane-isobutane mixture 68478-07-9 Naphtha 68478-54-6 Calcium, 2-ethylhexanoate isononanoate complexes 68478-65-9 N,N-Bis (2-hydroxyethyl) isodecyloxypropylamine oxide

68478-94-4 Poly(oxy-1,2-ethanediyl),alpha,alpha'-[[[3-(decyloxy)propyl]methylimino]di-2,1-ethanediyl]bis[omega-

68479-09-4 2-Propenoic acid, telomer with sodium hydrogen sulfite, sodium salt

68479-64-1 Butanedioic acid, sulfo-, mono{2-{(1-0xo-9-octadecenyl)amino}ethyl}ester, disodium salt,(Z)- (C

68511-11-5 Hexanedioic acid, polymer with 1,4-butanediol and 1,2-propanediol, didodecanoate

68511-39-7 Poly(oxy-1,2-ethanediyl), α-sulfo-ω-hydroxy-, C12-15-alkyl ethers 68511-70-6 Formaldehyde, polymer with 4-nonylphenol, propoxylated 68512-34-5 Lignosulfonic acid, sodium salt, sulfomethylated 68512-35-6 Lignin, alkali, reaction products with formaldehyde and sodium bisulfite 68512-79-8 Soybean oil, polymer with dicyclopentadiene 68513-95-1 Soybean, flour 68514-08-9 Sulfite liquors and cooking liquors, spent, alkali-treated, metal salts 68514-09-0 Sulfite liquors and cooking liquors, spent, oxidized 68514-28-3 Humic acids, potassium salts 68514-43-2 Linseed oil, maleated, ammonium salt 68514-61-4 Milk, skim, hydrolyzed 68514-74-9 Palm oil, hydrogenated 68514-75-0 Oils, orange-juice 68514-76-1 Citrus pulp 68515-42-4 1,2-Benzenedicarboxylic acid, di-C7-11-branched and linear alkyl esters 68515-49-1 Phthalic acid, di-C9-11-branched alkyl esters, C10-rich 68515-65-1 Disodium 1(or 4)-cocoamidoisopropyl sulfosuccinate 68515-73-1 D-Glucopyranose, oligomeric, decyl octyl glycosides 68516-16-5 Sulfuric acid, C6-10-alkyl esters

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CAS Reg. No. Chemical Name 68525-86-0 Corn, flour 68525-90-6 Sorbitan, poly(oxy-1,2-ethanediyl) derivs., hepta-9-octadecenoate, all-(Z)- 68526-82-9 Octyl alcohol bottoms 68526-86-3 Alcohols, C11-14-iso-, C13- rich 68526-94-3 Alcohols, C12-20, ethoxylated 68527-08-2 Alkenes, C>10 α-, polymd. 68527-23-1 Naphtha (petroleum), light steam-cracked aromatic

68527-99-1 Carboxymethylated 2-undecyl-1-hydroxyethyl-4,5-dihydroimidazoline, disodium salt

68551-07-5 Fatty alcohols (100% C4-C10) 68551-12-2 Alcohols, C12-16, ethoxylated 68551-13-3 Alcohols, C12-15, ethoxylated propoxylated 68551-18-8 Alkanes, C10-14-iso- 68551-41-7 Calcium salts of fatty acids (see 21 CFR 175.300 xxii) 68551-42-8 Fatty acids, C6-C19 branched, manganese salts 68551-90-6 Fatty acids, cottonseed-oil, calcium salts 68553-00-4 Fuel oil, no. 6 68553-02-6 Fatty acids, coco, esters with polyethylene glycol ether with glycerol (3:1) 68553-04-8 Glycerides, soya di- 68553-11-7 Glycerides, tallow mono- and di-, hydrogenated, ethoxylated 68553-81-1 Rice bran oil 68554-37-0 Pentaerythritol, phthalic anhydride and tall oil polymer with rosin

68554-64-3 Siloxanes and silicones, di-Me, polymers with Me silsesquioxanes and polypropylene glycol mono-

68554-65-4 Siloxanes and silicones, di-Me, polymers with Me silsesquioxanes and polyethylene-polypropylene glycol mono-Bu ether

68554-70-1 Silsesquioxanes, Me

68555-36-2 N,N'-Bis{3-(dimethylamino)propyl}urea, polymer with 1,1'-oxybis(2-chloroethane)

68583-49-3 Cyclotetrasiloxane, octamethyl-, reaction products with silica 68583-84-6 1,3-Butanediol adipate-laurate polyester

68584-15-6 1,3-Benzenedicarboxylic acid, polymer with 5-amino-1,3,3-trimethylcyclohexylamine and nonanedioic acid, cyclohexylamine modified

68584-22-5 Benzenesulfonic acid, C10-16-alkyl derivs 68584-23-6 Calcium alkyl(C8-C24)benzenesulfonate 68584-24-7 Benzenesulfonic acid, C10-16-alkyl derivs., compds. with 2-propanamine 68584-25-8 Benzenesulfonic acid, C10-16-alkyl derivs., compds. with triethanolamine 68584-26-9 Benzenesulfonic acid, C10-16-alkyl derivs., magnesium salts 68584-27-0 Benzenesulfonic acid, C10-16-alkyl derivs., potassium salts 6858-44-2 Citric acid, trisodium salt, pentahydrate

68584-47-4 Poly(oxy-1,2-ethanediyl), α-(nonylphenyl)-ω-hydroxy-, branched, phosphates, potassium salts

68585-15-9 Oxirane, methyl, polymer with oxirane, mono C6-C10 alkyl ethers, phosphates

68585-34-2 Poly(oxy-1,2-ethanediyl), alpha-sulfo-omega-hydroxy-, C10-16-alkyl ethers, sodium salts

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CAS Reg. No. Chemical Name 68585-36-4 Alkyl(C10-14)oxypoly(ethyleneoxy)ethyl phosphate 68585-47-7 Sulfuric acid, mono-C10-16-alkyl esters, sodium salts

68586-19-6 2-Propenoic acid, 2-methyl-, 2-((2,3,3a,4,7,7a(or 3a,4,5,6,7,7a)-hexahydro-4,7-methano-1H-indenyl)oxy)ethyl ester

68602-80-2 Distillates (petroleum), C12-30 aromatic 68603-15-6 Alcohols, C6-12 68603-16-7 Alcohols, C12-18, distn. residues 68603-17-8 Alcohols, C16-18, distn. residues 68603-18-9 C10-16 Alcohols distn. Residues

68603-23-6 Poly(oxy-1,2-ethanediyl),.alpha.-(carboxymethyl)-.omega.-hydroxy-, C11-15-sec-alkyl ethers, sodium salts

68603-42-9 Amides, coco, N,N-bis(2-hydroxyethyl)

68604-71-7 Imidazolium compounds, 1-{2-(2-carboxyethoxy)ethyl}-1(or 3)-(2-carboxyethyl)-4,5-dihydro-2-norc

68605-55-0 Fatty acids, tall-oil,polymers with bisphenol A,epichlorohydrin and tall oil

68605-57-2 Fatty acids, tall-oil, polymers with bisphenol A, epichlorohydrin, rosin and tung oil. (CA INDE

68606-06-4 Fatty acids, vegetable-oil, potassium sodium salts 68606-94-0 Oils, orange, sweet, terpene-free 68607-27-2 Dihydrogenated tallow hydroxyethyl methyl ammonium chloride

68607-29-4 Quaternary ammonium compounds, pentamethyltallow alkyltrimethylenedi-, dichlorides

68608-26-4 Sodium petroleum sulfonate

68608-66-2 Acetic acid, chloro-, sodium salt, reaction products with 4,5-dihydro-2-undecyl-1H-imidazole-1-ethanol and sodium hydroxide

68609-68-7 1-Hexanol, 2-ethyl-, manuf. of by-products from, distn. residues 68609-86-9 Manganese naphthanate 2-ethylhexanoate complex 68609-93-8 9-Octadecenoic acid (Z)-, sulfonated, Potassium salts

68610-19-5 Poly(oxy-1,2-ethanediyl), α,α'-[[methyl[3-(tridecyloxy)propyl]imino]di-2,1-ethanediyl

68610-44-6 Reaction products of methyl acrylate with 2-ethylhexylamine and sodium hydroxide

68610-92-4 Cellulose, omega-ether with alpha-?2-hydroxy-3-(trimethylammonio) propyl|-omega-hydroxypoly(oxy-1,2-ethanediyl) chloride

68611-14-3 Lignosulfonic acid, ethoxylated, sodium salts 68611-44-9 Silane, dichlorodimethyl-, reaction products with silica 68611-55-2 Sulfated mixed oxo alcohols (100% C10 and up) 68628-60-4 Benzenesulfonic acid, 4-sec-dodecyl-, sodium salt

68630-83-1 2-Propenoic acid, 2-methyl-, polymer with ethenylbenzene and alpha-hydro-omega-hydroxypoly(oxy-1,2-ethanediyl)-(Z)-2-butenedioate

68630-92-2 Disodium 3-(2-(2-carboxyethoxy)ethyl)-2-heptyl-2,3-dihydro-1H-imidazole-1-propanoate

68630-96-6 1H-Imidazolium, 1-(2-carboxyethyl)-4,5-dihydro-3-(2-hydroxyethyl)-2-isoheptadecyl-, hydroxide, inner salt

68647-71-2 Tall oil, potassium salt

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CAS Reg. No. Chemical Name 68647-72-3 Terpenes, orange oil 68647-73-4 Oils, tea-tree 68647-95-0 Fatty acids, C18-unsatd., dimers, compds. with coco alkylamines 68648-12-4 Fatty acids, tall-oil, diesters with polypropylene glycol 68648-20-4 Fatty acids, tall-oil, sesquiesters with sorbitol, ethoxylated 68648-20-4 Sorbitol tall oil fatty acid sesquiester, ethoxylated 68648-35-1 Sulfonated cod oil 68648-38-4 Polyoxyethylene lanolin alcohol 68648-44-2 Pyrethrum marc 68648-50-0 Resin acids and Rosin acids, dimers, calcium salts 68648-72-6 Sodium alpha-olefin (C12-C16) sulfonate

68648-89-5 Benzene, ethenyl-, polymer with 2-methyl-1,3-butadiene, hydrogenated (CA INDEX NSME)

68648-98-6 Benzenesulfonic acid, mono-C7-17-branched alkyl derivs.

68649-00-3 Benzenesulfonic acid, mono-C9-17-branched alkyl derivs., compds. with 2-propanamine

68649-29-6 Polyethylene-polypropylene glycol, mono-C10-16-alkyl ethers, phosphates

68649-55-8 Poly(oxy-1,2-ethanediyl), [alpha]-sulfo-[omega]-(nonylphenoxy)-, branched, ammonium salt

68649-89-8 Resin acids and rosin acids, ammonium salts 68650-09-9 Polyoxyethylene* glycerol tall oil ester *(25 moles) (Mol. wt. 1490)

68650-28-2 Fatty acids, tall-oil, polymers with pentaerythritol, polyethylene glycol and trimellitic anhydride

68650-39-5 Imidazolium compounds, 1-(2-(carboxymethoxy)ethyl)-1-(carboxymethyl)-4,5-dihydro-2-norcoco alkyl, hydroxides, inner salts, disodium salts

68650-50-0 Fatty acids, C18-unsatd., dimers, polymers with ethylenediamine 687-47-8 Propanoic acid, 2-hydroxy-, ethyl ester (S) 68783-43-7 Fatty acids, linseed-oil, calcium salts 68783-78-8 Ditallow dimethyl ammonium chloride 68784-79-2 Sulfuric acid, mono-C15-18-alkyl esters, sodium salts 68813-94-5 Sulfuric acid, zinc salt, basic 68813-94-5 Zinc sulfate, basic 68814-56-2 Rhizobium japonicum 68814-57-3 Rhizobium leguminosarum 68814-58-4 Rhizobium lupini 68814-59-5 Rhizobium meliloti 68814-60-8 Rhizobium phaseoli 68814-61-9 Rhizobium trifolii 68815-61-2 Sulfuric acid, mono-C12-15-alkyl esters, ammonium salts 688-37-9 9-Octadecenoic acid, (Z)-, aluminum salt 68855-41-4 Lignosulfonic acid, sodium salt, oxidized 68855-54-9 Kieselguhr, soda ash flux-calcined 68855-99-2 Litsea cubeba oil 68876-77-7 Yeast 68890-70-0 Sulfuric acid, mono-C12-15-alkyl esters, sodium salts

of 93


68890-80-2 Benzene, ethenyl-, polymer with 2,5-furandione, 2-butoxyethyl ester, ammonium salt

68891-11-2 Oxirane, methyl-, polymer with oxirane, mono(nonylphenyl) ether, branched

68891-13-4 Oxirane, methyl-, polymer with oxirane, mono-C10-16-alkyl ethers, phosphates, potassium salts

68891-21-4 Poly(oxy-1,2-ethanediyl),α-(dinonylphenyl)-ω-hydroxy-branched 68891-29-2 alpha-Alkyl(C8-C10)-omega-hydroxypoly(oxyethylene) ammonium sulfate 68891-33-8 Nonylphenol polyoxyethylene sulfate 68891-38-3 Alcohols, (C12-14), ethoxylated, monoethers with sulfuric acid, sodium salts 68908-46-3 Sulfuric acid, mono-C10-16-alkyl esters, potassium salts 68908-63-4 Ethoxylated C12-15 alcohols

68908-64-5 Poly(oxy-1,2-ethanediyl), α-hydro-. omega.-hydroxy-, mono-C10-12-alkyl ethers, phosphates

68909-20-6 Silanamine, 1,1,1-trimethyl-N-(trimethylsilyl)-, hydrolysis products with silica 68909-59-1 Phosphoric acid, mono-C8-10-alkyl esters, monosodium salts 68909-82-0 Naphthalenesulfonic acid, bis(1-methylethyl)-, Me derivs, sodium salts 68909-83-1 Naphthalenesulfonic acid, butyl-, Me derivs, sodium salts 68909-84-2 Naphthalenesulfonic acid, dibutyl-, Me derivs, sodium salts 68911-49-9 Dried blood 68911-87-5 Bis(hydrogenated tallow alkyl) dimethyl ammonium salts with montmorillonite68915-31-1 Sodium hexametaphosphate ((NaPO3)6) 68915-32-2 Quassia extract 68916-18-7 Coffee grounds 68916-91-6 Licorice extract 68917-18-0 Cornmint oil 68917-19-1 Magnolia flower 68917-32-8 Terpenes and terpenoids, grapefruit-oil 68917-60-2 Terpenes and terpenoids, pennyroyal-oil 68917-71-5 Terpenes and terpenoids, lime-oil 68917-73-7 Oils, wheat 68917-75-9 Wintergreen oil

68918-78-5 Quaternary ammonium compounds, bis(C8-18 and C18-unsatd. alkyl)dimethyl, chlorides

68919-53-9 Fatty acids, soya, Me esters 68919-54-0 Sunflower-oil fatty acids, Me ester 68919-76-6 Fatty acids, tall-oil, reaction products with 2-{(2-aminoethyl)amino}ethanol 68920-66-1 Alcohols, C16-18 and C18-unsatd., ethoxylated 68920-69-4 Alcohols, C9-11, propoxylated

68921-42-6

Benzenemethanaminium, N-ethyl-N-(4-((4-(ethyl((3-sulfophenyl)methyl)amino)phenyl)(2-sulfophenyl)methylene)-2,5-cyclohexadien-1-ylidene)-3-sulfo-, hydroxide, inner salt, aluminum salt (3:2)

68928-85-8 Vinyl acetate, crotonic acid, vinyl neodecanoate, glycidyl methacrylate polymer

68937-10-0 Hydrogenated polyisobutene 68937-41-7 Phenol, isopropylated, phosphate (3:1)

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CAS Reg. No. Chemical Name 68937-54-2 Siloxanes and silicones, di-Me, 3-hydroxypropyl Me, ethoxylated 68937-55-3 Siloxanes and silicones, di-Me, 3-hydroxypropyl Me, ethoxylated propoxylated

68937-56-4 Siloxanes and silicones, di-Me,[(methylsilylidyne)tris(oxy)tris-, hydroxy terminated, ethers with polyethylene-polypropylene glycol monobutyl ether

68937-83-7 Fatty acids, C6-10, methyl esters 68937-84-8 Fatty acids, C12-18, methyl esters 68937-99-5 Sunflower seeds 68938-15-8 Fatty acids, coco, hydrogenated

68938-54-5 Siloxanes and silicones, di-Me, 3-hydroxypropyl Me, ethers with polyethylene glycol mono-Me eth

68951-67-7 Alcohols, C14-15, ethoxylated 68952-63-6 Linseed oil, tung oil, di-tert-butylphenol, bisphenol A, formaldehyde polymer 68953-01-5 Fatty acids, tall-oil, esters with ethoxylated sorbitol 68953-36-6 Tall oil fatty acids, reaction products with tetraethylene pentamine 68953-91-3 Benzenesulfonic acid, mono-C7-17-alkyl derivs., calcium salts 68953-96-8 Benzenesulfonic acid, mono-C11-13-branched alkyl derivs., calcium salts 6895-43-8 Ethyl bixin

68954-84-7 Poly(oxy-1,2-ethanediyl), alpha-(nonylphenyl)-omega-hydroxy-, branched, phosphates, sodium salts

68955-55-5 Amines, C12-14-alkyldimethyl, N-oxides 68955-64-6 Hexanedinitrile, hydrogenated, high-boiling fraction, phosphonomethylated 68956-56-9 Hydrocarbons, terpene processing by-products

68957-00-6 Siloxanes and Silicones, di-Me, Me hydrogen, reaction products with polypropylene glycol monoallyl ether

68959-25-1 3-Pentanol, 1-(2-hydroxyethoxy)-2,2,4-trimethyl- 68964-56-7 Octadecanoic acid, 9(or 10)-(sulfooxy)-, monosodium salt 689-82-7 2-Butenedioic acid (Z)-, monopotassium salt 68987-29-1 1-Octadecanol, phosphate, potassium salt 68987-63-3 Copper, [29H,31H-phthalocyaninato(2-)-N29,N30,N31,N32]-, chlorinated 68987-81-5 Ethoxylated propoxylated C6-10 alcohols-

68988-26-1

2-Butenedioic acid (2E)-,mixed esters with polyethylene glycol and polyethylene glycol mono(nonylphenyl) ether, polymer with methacrylic acid and styrene

68988-56-7 Polytrimethylhydrosilylsilicone 68988-76-1 9-Octadecenoic acid (Z)-, sulfonated

68989-01-5 Quaternary ammonium compounds, benzyl-C12-18-alkyldimethyl, salts with 1,2-benzisothiazol-3(2H)

68989-22-0 Zeolites, NaA 68990-15-8 Oils, fenugreek 68990-20-5 Penta cosolvent 68990-53-4 Glycerides, C14-22 mono- 68990-54-5 Glycerides, C14-22 mono-,acetates 68991-42-4 Oils, red pepper, paprika 68991-48-0 Alcohols, C7-21, ethoxylated 69009-90-1 1,1'-Biphenyl, bis(1-methylethyl)-

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CAS Reg. No. Chemical Name 69011-04-7 n-Butyl acid phosphate, manganese salt

69011-15-0 Benzene, diethenyl-, polymer with ethenylbenzene and ethenylethylbenzene, chloromethylated, 2-(dimethylamino)ethanol-quaternized

69011-22-9 Benzene, diethenyl-, polymer with etenylbenzene and ethenylethylbenzene, sulfonated, sodium salts

69011-36-5 Polyoxyethylene tridecyl (branched) alcohol

69011-37-6 Poly(oxy-1,2-ethanediyl), alpha-sulfo-omega-hydroxy-, C8-14-alkyl ethers, ammonium salts

69011-84-3 Poly(oxy-1,2-ethanediyl),α-sulfo-ω-(octylphenoxy)-,branched,sodium salt (CA INDEX NA

69012-32-4 Calcium silicate slag

69013-18-9

α-Alkyl(C8-C14)-omega-hydroxypoly(oxypropylene) block copolymer withpolyoxethylene; polyoxpropylene content averages 2 moles; polyoxyethylene content averages 7 moles

69029-39-6 Polyoxyethylene polyoxypropylene mono(di-sec-butylphenyl) ether 6915-15-7 Malic acid

69227-22-1 alpha-Alkyl*-omega-hydroxy-polyoxyethylene** polyoxypropylene*** polyoxyethylene** *(100% C10-C16) **(4 moles) ***(1.5 moles)

69278-92-8 Tall oil, calcium zinc salt 692-86-4 10-Undecenoic acid, ethyl ester 693-33-4 1-Hexadecanaminium, N-(carboxymethyl)-N.N-dimethyl-, inner salt 69364-63-2 Poly(oxy-1,2-ethanediyl), alpha-isohexadecyl-omega-hydroxy- 6938-94-9 Diisopropyl adipate 69430-24-6 Cyclosiloxanes, di-Me 69430-36-0 Hydrolyzed keratins 695-06-7 4-Hexanolide 69-65-8 Mannitol 69669-25-6 Fatty acids, C12-20, potassium salts

69669-36-9

Siloxanes and silicones, di-Me, 3-hydroxypropyl Me, Me 2-(7-oxabicyclo[4.1.0]hept-3-yl )ethyl, ethers with polyethylene-polypropylene glycol mono-Me ether

69671-09-6 Propylene-ethylene thioether 6969-49-9 Octyl salicylate 69-72-7 Salicylic acid 69-79-4 D-Glucose, 4-O-alpha-D-glucopyranosyl-

69808-32-8 3-Pyridinecarbonitrile, 1-butyl-5-[(4-chlorophenyl)azo]-1,2-dihydro-6-hydroxy-4-methyl-2-oxo-

69867-71-6 Phosphoric acid, monopentyl monophenyl ester 69898-00-6 alpha-Olefins 69-93-2 Uric acid 6994-46-3 C.I. Solvent Blue 59 70084-87-6 Glutens, enzyme-modified 7011-83-8 Decanoic acid, 4-hydroxy-4-methyl-,.gamma.-lactone 70131-50-9 Acid-leached bentonite 70131-67-8 Dimethyl siloxane, hydroxy-terminated

of 93


70131-70-3 Soybean oil, polymer w. benzoic acid, pentaerythritol, phthalic anhydride, TDI and trimethylolpropane

70142-34-6 12-Hydroxystearic acid-polyethylene glycol copolymer 70146-13-3 Benzenesulfonic acid, oxybis(decyl-, disodium salt 70161-44-3 Glycine, N-(hydroxymethyl)-, monosodium salt 70191-76-3 Disodium dihexadecyldiphenyloxide disulfonate 70206-24-5 Alkyl imidazolinium methyl sulfate (derived from oleic acid)

7023-61-2 2 Naphthalenecarboxylic acid, 4-((5-chloro-4-methyl-2-sulfophenyl)azo)-3-hydroxy-, calcium salt (1:1)

70267-73-1 1H-Benzimidazolesulfonic acid, 2-(7-(diethylamino)-2-oxo-2H-1-benzopyran-3-yl)-, monosodium salt

70425-89-7 2-Propenoic acid, 2-methyl-, octadecyl ester, polymer with isooctyl 2-propenoate and 2-propenoic acid

70495-37-3 Sulfuric acid, mono(2-ethylhexyl) ester, ammonium salt (1:1) 70528-83-5 Benzenesulfonic acid, dodecyl-, branched, calcium salts

70549-17-6 Butyl acrylate-2-ethylhexyl acrylate-2-hydroxyethyl acrylate-styrene copolymer

70559-25-0 Poly(oxy-1,2-ethanediyl), α-[2,4,6-tris(1-phenylethyl)phenyl]-ω-hydroxy-

70571-81-2 2-Anthracenesulfonic acid, 4-[[3-(acetylamino)phenyl]amino]-1-amino-9,10-dihydro-9,10-dioxo-, m

70592-80-2 Alkyl(C10-16) dimethylamine oxide 706-14-9 2(3H-Furanone, 5-hexyldihydro-

70632-06-3 Poly(oxy-1,2-ethanediyl), α-(carboxymethyl)-ω-hydroxy, C12- 15-alkyl ethers, sodium salts

7065-13-6 1-Hexadecanol, hydrogen sulfate, potassium salt 70657-70-4 Propylene glycol monomethyl ether acetate 70693-62-8 Potassium peroxymonosulfate sulfate (K5(HSO5)2(HSO4)(SO4)) 707-19-7 Propargyl alcohol 70750-46-8 Betaines,bis(hydroxyethyl)tallow alkyl 70750-47-9 Quternary ammonium compounds, coco alkylbis(hydroxyethyl)methyl chloride 70750-53-7 Terpenes and terpenoids, limonene fraction, polymd. 70750-57-1 Terpenes and Terpoids, turpentine oil, alpha-pinen fraction, polymd. 70788-30-6 Cyclohexanepropanol, 2,2,6-trimethyl-,α-propyl-

70879-75-3 Oils, walnut, polymers with maleic anhydride, pentaerythritol, phthalic anhydride, sunflower oil and trimethylolethane

70892-46-5 Benzenesulfonic acid, C12-18-alkyl derivs. sodium salts 70903-62-7 o,p-Dinonylphenol, ethoxylated, phosphated, sodium salt

70914-12-4 Siloxanes and silicones, di-Me,3-hydroxypropyl Me,ethers with polyethylene glycol acetate

70955-37-2 Dodecyl and higher aliphatic ketones 71010-52-1 Gellan gum

71011-24-0 Quaternary ammonium compounds, benzyl(hydrogenated tallow alkyl)dimethyl, salts with bentonite

71011-27-3 Quaternary ammonium compounds, bis(hydrogenated tallow alkyl)dimethyl, chorides, compds. with hectorite

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CAS Reg. No. Chemical Name 71012-10-7 9-Octadecenoic acid (9Z)-, monoester with tetraglycerol 71-23-8 1-Propanol 71243-46-4 Polyoxyethylene linear primary alcohols 71243-86-2 Nonene, hydroformylation products, high-boiling, sulfated, sodium salts 7128-64-5 2,2'-(2,5-Thiophenediyl)bis(5-tert-butylbenzoxazole) 7128-91-8 1-Hexadecanamine, N,N-dimethyl-, N-oxide 71317-43-6 1-Tridecanol, hydrogen sulfate, potassium salt 71317-56-1 1-Tridecanol, hydrogen sulfate, magnesium salt 71-36-3 1-Butanol

71394-17-7 2-Propenoic acid, 2-methyl-, polymer with butyl 2-methyl-2-propenoate, ethenylbenzene, 2-ethylh

71-41-0 1-Pentanol 71526-07-3 1-Oxa-4-azaspiro{4.5}decane, 4-(dichloroacetyl)- 71-55-6 1,1,1-Trichloroethane

71608-70-3 Benzenesulfonic acid, 4-hydroxy-, polymer with formaldehyde and urea, sodium salt

71662-60-7 Stearamine oxide 7173-51-5 1-Decanaminium, N-decyl-N,N-dimethyl-, chloride 7173-62-8 N-Oleyl-1,3-propylenediamine 71750-79-3 Siloxanes and silicones, 3-[(2-aminoethyl)amino]propyl Me, di-Me 717-74-8 Benzene, 1,3,5-tris(1-methylethyl)- 71786-60-2 N,N-Bis(2-hydroxyethyl)-C12-18-alkylamine 71819-49-3 C.I. Solvent Blue 98 71819-51-7 C.I. Solvent Red 164

71820-36-5 Copolymer of castor oil, maleic anhydride, and polyethylene glycol 600 (Mol. Wt. 3150)

71839-88-8 Cobaltate(1-),bis{2,4-dihydro-4-{(2-hydroxy-5-nitrophenyl)azo}-5-methyl-2-phenyl-3H-pyrazol-3-o

71872-84-9 9,10-Anthracenedione, 1,4-bis((2,4,6-trimethylphenyl)amino)-

71873-51-3 Benzenesulfonic acid, 2,5-dichloro-4-(4-((5-(((dodecyloxy)carbonyl)amino)-2-sulfophenyl)azo)-4,5-dihydro-3-methyl-5-oxo-1H-pyrazol-1-yl)-, disodium salt

71927-89-4 Benzenesulfonic acid, 2(or 5)-butyl-5(or 2)-{{4-{{4-butylsulfophenyl)amino}-9,10-dihydro-5,8-dihydroxy-9,10-dioxo-1-anthracenyl}amino}, disodium salt

72067-21-1

alpha-(o,p-Dinonylphenyl)-omega-hydroxypoly(oxyethylene) mixture of dihydrogen phosphate and monohydrogen phosphate esters and the corresponding ammonium, calcium, monomethanolamine, potassium, sodium and zinc salts of the phosphate ester.

72102-55-7 Methylium, [4-(dimethylamino)phenyl]bis[4-(ethylamino)-3-methylphenyl]-,acetate (CA INDE

72139-15-2

2,7-Naphthalenedisulfonic acid, 4-hydroxy-5-((4-(methylamino)-6-((3-((2,5,6-trichloro-4-pyrimidinyl)amino)phenyl)amino)-1,3,5-triazin-2-yl)amino)-3-((2-sulfophenyl)azo)-, trisodium salt

72152-45-5 C.I. Reactive Green 12

72152-54-6 2-Anthracenesulfonic acid, 4-((4-(acetylmethylamino)-2-sulfophenyl)amino)-1-amino-9,10-dihydro-9,10-dioxo-, disodium salt

72162-23-3 (C10-C12) Dibasic acid, diethanolamine salts

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72207-82-0 Phosphoric acid, C12-15-alkyl esters, compds. with polyethylene glycol mono[2-(diethylamino)ethyl] ether

72208-21-0 C.I. Basic Red 14 (phosphate) 72214-01-8 2-Ethylhexyl sulfate

72245-05-7 Coconut oil, polymer with isophthalic acid, trimellitic anhydride and trimethylolpropane

7230-93-5 Dodecanoic acid, aluminum salt

72749-55-4 Imidazolium compounds, 2-(C17 and C17-unsatd. alkyl)-1-[2-(C18 and C18-unsatd. amido)ethyl]-4,5-d

72749-59-8 Tri-C6-12-alkylmethyl ammonium chlorides 72827-81-7 C.I. Acid Red 388

72828-83-2 2,7,-Naphthalenedisulfonic acid, 5-(benzoylamino)-3-{{2-(2-cyclohexylphenoxy)phenyl}azo}-4-hydr

72854-21-8 Zirconium naphthenate 72869-69-3 Oils, apricot 72906-11-7 Sulfuric acid, mono-C9-13-alkyl esters, sodium salts 73018-51-6 1,6-Octadien-3-ol, 3,7-dimethyl-, acid-isomerized 73038-25-2 Poly(oxy-1,2-ethanediyl), alpha-isotridecyl-omega-hydroxy-, phosphate 73049-73-7 Peptone type IV from soybean

73050-07-4 Poly(oxy-1,2-ethanediyl),α-(butoxyhydroxyphosphinyl)-ω-hydroxy-,C13-15-alkyl ethers,s

73050-08-5 Poly(oxy-1,2-ethanediyl),α,α-phosphinicobis{ω-hydroxy-,di-C13-15-alkyl ethers,

73050-09-6 Poly(oxy-1,2-ethanediyl),α-phosphono-ω-hydroxy-,C13-15-alkyl ethers, disodium salts

73138-28-0 Dimethyl dioctadecyl ammonium bentonite 7320-34-5 Diphosphoric acid, tetrapotassium salt 73-22-3 L-Tryptophan 73227-23-3 Neodymium tris(2-ethylhexanoate) 73246-96-5 Ethanol, 2.2'-iminobis-, N-soya alkyl derivs. 73248-92-7 Sulfuric acid, iron(2+) salt (1:1), nonahydrate () 73296-89-6 Sulfuric acid, mono-C12-16-alkyl esters, sodium salts 73296-90-9 Sulfuric acid, mono-C12-16-alkyl esters, potassium salts

73297-09-3 Cobaltate(1-),bis{1-{(2-hydroxy-5-nitrophenyl)azo}-2-naphthalenolato(2-)}-, sodium

73398-61-5 Glycerides, mixed decanoyl and octanoyl

73398-64-8 Dialkyl* dimethyl ammonium chloride (47%C12, 18%C14, 10%C18, 9%C10, 8%C16, 8%C8)

73398-89-7 Xanthylium, 3,6-bis(diethylamino)-9-(2-(methoxycarbonyl)phenyl)-, (T-4)-tetrachlorozincate(2-) (2:1)

73455-30-8 Dimethylamine ethylenediaminetetraacetate 7346-80-7 Sodium N-cis-9-octadecenyl-N-methyltaurine 7347-29-7 Oleoyl imidazoline

73507-66-1 Cobaltate(1-),{2,4-dihydro -4-{(2-hydroxy-5-nitrophenyl)azo}-5-methyl-2-phenyl-3H-pyrazol-3-onato(2-)}{1-{(2-hydroxy-5-nitrophenyl)azo}-2-

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CAS Reg. No. Chemical Name naphthalenolato(2-)}-, sodium

73513-47-0 Disodium zinc ethylenediaminetetraacetate 73637-19-1 Disodium cupric ethylenediaminegtetraacetate trihydrate 73637-20-4 Disodium manganese ethylenediaminetetraacetate 73728-37-7 Rubber, cyclized 7373-11-7 2-Hydroxypropylamine nitrite

73772-32-4 1-Propanesulfonic acid, 3-{{-(dimethylamino)propyl}{(tridecafluorohexyl)sulfonyl}amino}-2-hydro

7378-99-6 1-Octanamine, N,N-dimethyl- 7379-27-3 Potassium ethylenediaminetetraacetate 7379-28-4 Glycine, N,N'-1,2-ethanediylbis(N-(carboxymethyl)-, sodium salt

73807-20-2 Fatty acids, tall-oil, polymers with bisphenol A, diethylenetriamine, epichlorohydrin and triethylenetetramine

73891-88-0 Tannic acid 73891-99-3 Rape oil, Me ester

74204-30-1 Benzoic acid, 2-{{2-hydroxy-5-sulfo-3-{(2,5,6-trichloro-4-pyrimidinyl) amino}phenyl}imino}-1-phenylethyl}azo}-5-sulfo-, copper complex

7429-90-5 Aluminum (metal) 7439-89-6 Iron (Fe) 7440-37-1 Argon 7440-44-0 Carbon 7440-50-8 Copper 7440-59-7 Helium 7440-66-6 Zinc (metallic) 7443-25-6 Propanedioic acid, {(4-methoxyphenyl)methylene}-, dimethyl ester 7446-19-7 Zinc sulfate monohydrate 7446-20-0 Sulfuric acid, zinc salt (1:1) , heptahydrate 7446-26-6 Zinc pyrophosphate 7446-70-0 Aluminum chloride 7447-40-7 Potassium chloride (KCl) 7447-41-8 Lithium chloride 74499-22-2 Methyl tallate 74504-64-6 1,2,3-Propanetriol, homopolymer, dodecanoate 74775-06-7 Poly{oxy(methyl-1,2-ethanediyl)},α-(1-oxopropyl)-ω-(tetradecyloxy)- 74811-65-7 Croscarmellose sodium 74-84-0 Ethane 74-86-2 Acetylene 7487-79-8 Diethanolamine laurate 7487-88-9 Magnesium sulfate 7492-30-0 9-Octadecenoic acid, 12-hydroxy-, monopotassium salt, (9Z, 12R)- 74-98-6 Propane 75-01-4 Ethene, chloro- 75-05-8 Acetonitrile 75-28-5 Isobutane

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CAS Reg. No. Chemical Name 75-31-0 2-Propanamine 75319-63-0 beta-D-Glucopyranoside, hexadecyl (approval pending & tolerance pending) 75-37-6 1,1-Difluoroethane 7540-51-4 6-Octen-1-ol, 3,7-dimethyl-, (3S)- 75-43-4 Dichloromonofluoromethane 7543-51-3 Phosphoric acid, zinc salt (2:3), tetrahydrate 75-45-6 Chlorodifluoromethane 75499-50-2 Hypophosphoric acid, calcium salt 75-52-5 Nitromethane B2779 7553-56-2 Iodine 7558-79-4 Disodium phosphate 7558-80-7 Phosphoric acid, monosodium salt 75-65-0 2-Methyl-2-propanol 75673-43-7 Oxazolidine, 3,4,4-trimethyl- 75-68-3 1-Chloro-1,1-difluoroethane 7575-62-4 Disodium 4-dodecyl-2,4'-oxydibenzenesulfonate

75768-93-3 2-Naphthalenesulfonic acid, 7-(benzoylamino)-4-hydroxy-3-((4-((4-sulfophenyl)azo)phenyl)azo)-, compd. with 2,2',2"-nitrilotris(ethanol) (1:2)

7580-31-6 Nickel 2-ethylcaproate

75832-50-7 2-Propenoic acid, 2-methyl-, polymer with ethyl 2-propenoate and alpha-(2-methyl-1-oxo-2-propenyl)-omega-(hexadecyloxy) poly (oxy-1,2-ethanediyl)

7585-39-9 beta-Cyclodextrin 7601-54-9 Trisodium phosphate 76-06-2 Chloropicrin 76-13-1 1,1,2-Trichloro-1,2,2-trifluoroethane

762-04-9 Diethyl Phosphite (Limited to use as a stabilizer in a non-food use formulation at quantities less than or equal to .1%)

76-22-2 Camphor 7631-86-9 Silica (crystalline free) 7631-90-5 Sodium bisulfite (NaHSO3) 7631-95-0 Sodium molybdate 7631-99-4 Sodium nitrate 7632-00-0 Sodium nitrite 7632-04-4 Sodium perborate 7732-05-5 Sodium phosphate 763-69-9 Propanoic acid, 3-ethoxy-, ethyl ester 7646-85-7 Zinc chloride (ZnCl2) 7646-93-7 Sulfuric acid, monopotassium salt 7647-01-0 Hydrochloric acid 7647-14-5 Sodium chloride 764-71-6 Octanoic acid, potassium salt 76-49-3 endo-Bornyl acetate 76-59-5 Bromothymol blue 7664-38-2 Metaphosphoric acid 7664-93-9 Sulfuric acid

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CAS Reg. No. Chemical Name 7673-09-8 1,3,5-Triazine-2,4,6-triamine, N,N',N''-trichloro- 7681-11-0 Potassium iodide (KI) 7681-38-1 Sodium hydrogen sulfate 7681-49-4 Sodium fluoride 7681-52-9 Sodium hypochlorite 7681-53-0 Sodium hypophosphite 7681-57-4 Disulfurous acid, disodium salt 7681-82-5 Sodium iodide 7693-13-2 Calcium citrate 7695-91-2 DL-Vitamine E acetate 7697-37-2 Nitric acid 7699-41-4 Silicic acid (H2SiO3) 770-35-4 2-Propanol, 1-phenoxy- 7704-34-9 Sulfur 7705-08-0 Ferric chloride 77-06-5 Gibberellic acid 7720-78-7 Ferrous sulfate 7722-64-7 Potassium permanganate 7722-71-6 Oleyl dihydrogen phosphate 7722-76-1 Ammonium phosphate 7722-84-1 Hydrogen peroxide 7722-88-5 Diphosphoric acid, tetrasodium salt 7727-37-9 Nitrogen 7727-43-7 Barium sulfate 7727-54-0 Ammonium persulfate 7727-73-3 Disodium sulfate decahydrate 7732-18-5 Water 7733-02-0 Sulfuric acid, zinc salt (1:1)

77348-43-7 1,6-Hexamethylene diamine, polymer with poly-methylene polyphenylisocyanate

7739-63-1 Sulfuric acid, monodecyl ester, potassium salt 7747-35-5 7a- Ethyldihydro-1H,3H,5H-oxazolo(3,4-c) oxazole

77-53-2 1H-3a,7-Methanoazulen-6-ol, octahydro-3,6,8,8-tetramethyl-,[3R-(3α,3a.beta.,6α,7.beta,8aalpha)]

7757-79-1 Potassium nitrate 7757-82-6 Sodium sulfate 7757-83-7 Sodium sulfite 7757-86-0 Magnesium phosphate, dibasic 7757-87-1 Magnesium phosphate anhydrous 7757-93-9 Calcium phosphate, dibasic [JAN] 7758-02-3 Potassium bromide 7758-05-6 Iodic acid (HIO3), potassium salt 7758-09-0 Potassium nitrite 7758-11-4 Phosphoric acid, dipotassium salt 7758-16-9 Sodium acid pyrophosphate

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CAS Reg. No. Chemical Name 7758-23-8 Calcium phosphate, monobasic 7758-29-4 Sodium tripolyphosphate 77-58-7 Stannane, dibutylbis[(1-oxododecyl) oxy]- 7758-87-4 Tricalcium phosphate (Ca3(PO4)2) 7758-98-7 Copper(II) sulfate anhydrous (CuSO4) 7758-99-8 Copper sulfate perntahydrate 77-71-4 5,5-Dimethylhydantoin 7772-98-7 Thiosulfuric acid (H2S2O3), disodium salt 7774-34-7 Calcium chloride (CaCl2), hexahydrate 7775-09-9 Sodium chlorate 7775-11-3 Sodium chromate 7775-19-1 Sodium metaborate 7775-27-1 Peroxydisulfuric acid ([(HO)S(O)2]2O2), disodium salt 7778-18-9 Calcium sulfate 7778-49-6 Citric acid, potassium salt 7778-53-2 Tripotassium phosphate 7778-54-3 Calcium hypochlorite 7778-66-7 Hypochlorous acid, potassium salt 7778-77-0 Potassium phosphate monobasic (KH2PO4) 7778-80-5 Potassium sulfate 7779-88-6 Zinc nitrate 7779-90-0 Phosphoriccid, zinc salt (2:3) 7782-42-5 Graphite 7782-44-7 Oxygen 7782-50-5 Chlorine 7782-63-0 Ferrous sulfate heptahydrate 7782-99-2 Sulfurous acid 7783-18-8 Thiosulfuric acid (H2S2O3), diammonium salt 7783-20-2 Ammonium sulfate {(NH4)2SO4} 7783-28-0 Diammonium phosphate 7784-25-0 Ammonium alum

77847-18-8 2-Anthracenesulfonic acid, 1-amino-9,10-dihydro-4-{(4-methyl-3-sulfophenyl)amino}-9,10-dioxo-,

7785-26-4 2-Pinene, (1S,5S)-(-)- 7785-87-7 Manganese sulfate 7785-88-8 Sodium aluminum phosphate 77-86-1 1,3-Propanediol, 2-amino-2-hydroxymethyl- 7786-30-3 Magnesium chloride 7789-80-2 Calcium iodate 77-90-7 1,2,3-Propanetricarboxylic acid, 2-(acetyloxy)-, tributyl ester 7790-76-3 Calcium pyrophosphate 7790-86-5 Cerous chloride 7790-92-3 Hypochlorous acid 7791-13-1 Cobalt chloride (CoCl2), hexahydrate 7791-18-6 Magnesium chloride

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CAS Reg. No. Chemical Name 7791-20-0 Nickel chloride (NiCl2), hexahydrate 77-92-9 Citric acid 77-93-0 Triethyl citrate 77-99-6 Trimethylolpropane 7803-63-6 Ammonium bisulfate 78-07-9 Ethyl triethoxysilane 78-23-9 Octadecanoic acid, 3-hydroxy-2,2-bis(hydroxymethyl)propyl ester

78266-09-8 1-Propanesulfonic acid, 2-hydroxy-3-(2-propenyloxy)-,monosodium salt, polymer with 2-propenoic

78330-24-2 Poly(oxy-1,2-ethanediyl),α-hydro-ω-hydroxy-, mono-C11-14-isoalkyl ethers, C13-rich, p

78330-30-0 Sodium alpha-sulfo-omega-hydroxy-poly(oxy-1,2-ethanediyl) C11-14-isoalkyl ethers, C13 rich

78-40-0 Tri-ethyl phosphate 78-42-2 Tris(2-ethylhexyl) phosphate 78491-02-8 Diazolidinyl urea 78-51-3 Tributoxyethyl phosphate 78-59-1 Isophorone 78-66-0 3,6-Dimethyl-4-octyne-3,6-diol 78-69-3 3-Octanol, 3,7-dimethyl- 78-70-6 3,7-Dimethyl-1,6-octadien-3-ol 78-78-4 Isopentane 78-83-1 Isobutyl alcohol 78-92-2 sec-Butanol 78-93-3 Methyl ethyl ketone 78-96-6 Monoisopropanolamine 79070-11-4 Poly(difluoromethylene), α-chloro-ω-(2,2-dichloro-1,1,2-trifluoroethyl)- 79-09-4 Propanoic acid 79-11-8 Monochloroacetic acid 79-14-1 Hydroxyacetic acid 79-21-0 Peracetic acid

79234-36-9 2,7-Naphthalenedisulfinic acid, 5-(benzoylamino)-3-{{2-(4-cyclohexylphenoxylphenoxy)phenyl}azo}

79-24-3 Nitroethane

79255-97-3 1,3-Naphthalenedisulfonic acid, 7-[[4-[(6-amino-hydroxy-3-sulfo-2-naphthalenyl)azo]-5-methoxy-2-m

79255-98-4 1,5-Naphthalenedisulfonic acid, 3-[[4-[(6-amino-hydroxy-3-sulfo-2-naphthalenyl)azo]-5-methoxy-2-m

79-33-4 L-Lactic acid 79-34-5 1,1,2,2-Tetrachloroethane 79-41-4 Methacrylic acid 79620-91-0 Diacetyl tartaric acid esters of mono and diglycerides of edible fats 79-83-4 D-Pantothenic acid 79-92-5 Camphene 8000-25-7 Oils, rosemary

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CAS Reg. No. Chemical Name 8000-27-9 Oils, cedarwood 8000-28-0 Oils, lavender 8000-29-1 Oil of citronella 8000-34-8 Oils, clove 8000-41-7 Terpineol 8000-46-2 Oils, geranium 8000-48-4 Eucalyptus oil 8001-20-5 Tung oil 8001-22-7 Soybean oil 8001-23-8 Safflower oil 8001-25-0 Olive oil 8001-26-1 Linseed oil 8001-29-4 Cottonseed oil 8001-30-7 Corn oil 8001-31-8 Coconut oil 8001-54-5 Benzalkonium chloride [BAN:INN:JAN] 8001-69-2 Cod-liver oil 8001-75-0 Ceresin wax 8001-78-3 Hydrogenated castor oil 8001-79-4 Castor oil 8001-97-6 Aloe vera gel 8002-03-7 Peanut oil 8002-09-3 Pine oil 8002-13-9 Rapeseeds 8002-26-4 Tall oil 8002-31-1 Cocoa 8002-33-3 Sulfonated castor oil 8002-43-5 Lecithins 8002-48-0 Malt extract 8002-50-4 Menhaden oil 8002-72-0 Onion oil 8002-74-2 Paraffin wax 8002-75-3 Palm oil 8003-22-3 C.I. Solvent Yellow 33 8004-87-3 C.I. Basic Violet 1 8004-92-0 C.I. Acid Yellow 3 8005-03-6 C.I. Acid Black 2 8005-44-5 Fatty alcohols 8005-72-9 C.I. Direct Yellow 28 8006-54-0 Lanolin 8006-64-2 Turpentine, oil 8006-90-4 Oils, peppermint 8006-95-9 Wheat germ oil 8007-02-1 Oil of lemongrass 8007-08-7 Oils, ginger

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CAS Reg. No. Chemical Name 8007-11-2 Origanum oil 8007-20-3 Oils, cedar leaf 8007-24-7 Cashew, nutshell liq. 8007-43-0 Sorbitan sesquioleate 8007-44-1 Oils, pennyroyal, hedeoma pulegioides 8007-46-3 Oils, thyme 8007-69-0 Oils, almond 8007-70-3 Oil of anise 8007-75-8 Oil of Bergamot 8007-93-0 Belladonna leaf 8008-20-6 Kerosene (deodorized) 8008-26-2 Oils, lime 8008-51-3 Oil of camphor 8008-56-8 Oil of lemon 8008-57-9 Oil of orange 8008-74-0 Fats and glyceridic oils, sesame 8008-79-5 Spearmint oil 8008-80-8 Oils, spruce 8009-03-8 Petrolatum 8011-48-1 Pine tar 8011-63-0 Bordeaux mixture 8012-89-3 Beeswax 8012-95-1 Paraffin oils 8013-01-2 Yeast, ext. 8013-07-8 Epoxidized soybean oil 8013-10-3 Juniper tar oil 8013-17-0 Invert sugar 8013-76-1 Oil of bitter almond 8014-09-3 Oils, patchouli 8014-19-5 Oils, palmarosa 8015-73-4 Oils, basil 8015-80-3 Candlenut oil 8015-80-3 Kukui nut oil 8015-86-9 Carnauba wax 8016-11-3 Epoxidized linseed oil 8016-13-5 Fish oil 8016-20-4 Oils, grapefruit 8016-35-1 Oiticica oil 8016-70-4 Hydrogenated soybean oil 8016-85-1 Oils, tangerine 8016-96-4 Oils, vetiver 8020-83-5 Hydrocarbon oils 8021-29-2 Oils, Fir 8021-99-6 Charcoal,bone 8022-15-9 Oils, lavandin

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CAS Reg. No. Chemical Name 8022-37-5 Armoise Oil 8022-56-8 Oils, sage 8023-74-3 Mink oil 8023-77-6 Resins, oleo-, capsicum 8024-32-6 Fats and glyceridic oils, avocado 80-26-2 3-Cyclohexene-1-methanol, α,α,4-trimethyl-, acetate 80-27-3 α-Terpinyl propionate 8027-33-6 Alcohols, lanolin 8028-48-6 Sweet orange peel tincture 8028-52-2 Vinegar (maximum 8% acetic acid in solution) 8028-66-8 Honey 8028-89-5 Caramel 8029-31-0 Beer 8029-76-3 Hydroxylated lecithin 8030-12-4 Tallow hydrogenated 8030-30-6 Petroleum Naphtha 8030-76-0 Lecithins, soya 8030-78-2 Tallow trimethyl ammonium chloride 8031-18-3 Fuller's earth 8039-09-6 Ethoxylated lanolin 80-39-7 N-Ethyl-p-tolylsulfonamide 8042-47-5 Mineral Oil U.S.P. 8042-47-5 White mineral oil (petroleum) 80-46-6 p-tert-Amylphenol 8046-71-7 Soaps 8046-74-0 Soaps, potassium 8047-99-2 Ethyl toluene sulfonamide 8049-98-7 Milk 8049-99-8 Milorganite 8050-07-5 Olibanum 8050-09-7 Rosin ( wood ) 8050-13-3 Methyl hydrogenated rosinate 8050-15-5 Methyl ester of rosin, partially hydrogenated 8050-26-8 Resin acids and Rosin acids, esters with pentaerythritol 8050-31-5 Resin acids and rosin acids, esters with glycerol 8050-33-7 Polyoxyethylene* ester of rosin *(10-15 moles) 8050-81-5 Simethicone 8052-10-6 Tall oil rosin 8052-35-5 Molasses 8052-41-3 Stoddard solvent 8052-42-4 Asphalt 8052-48-0 Fatty acids, tallow, sodium salts 8052-50-4 Tallow, sulfated, sodium salt 80-54-6 Benzenepropanal, 4-(1,1-dimethylethyl)-α-methyl- 80-56-8 alpha-Pinene

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80570-62-3 2-Propenoic acid, polymer with ethyl 2-methyl-2-propenoate and 2-methylpropyl 2-methyl-2-propenoate

80584-98-1 Ethoxylated adduct of dehydroabietylamine

80584-99-2 Linseed oil acids, formaldehyde and 2-amino-2-(hydroxymethyl)-1,3-propanediol reaction product

8061-51-6 Lignosulfonic acid, sodium salt 8061-52-7 Lignosulfonic acid, calcium salt 8061-53-8 Lignosulfonic acid, ammonium salt 8061-54-9 Lignosulfonic acid, magnesium salt 8062-15-5 Lignosulfonic acid 80-62-6 Methyl methacrylate

8064-49-1 1,2,3-Propanetricarboxylic acid, 2-hydroxy-, mixt. with(1,1-dimethylethyl)-4-methoxyphenol and pr

8066-83-9 Lauric diethanolamide 8068-05-1 Lignin, alkali 80762-96-5 Propylene glycol di-tert-butyl ether 81-07-2 Saccharin 81-13-0 D-Panthenol

81190-38-7 1-Propanaminium, N-(2-hydroxyethyl)-3-{(2-hydroxy-3-sulfopropyl){(tridecafluorohexyl)sulfonyl}a

811-97-2 1,1,1,2-Tetrafluoroethane 813-94-5 Calcium citrate

81457-65-0 Copper, (29H,31H-phthalocyaninato(2-)-N29,N30,N31,N32)-, ((3-(methylethoxy)propyl)amino)sulfonyl derivs.

81-48-1 1-Hydroxy-4-(p-toluidino)anthraquinone 81-77-6 C.I. Pigment Blue 60 818-08-6 Dibutylin oxide 81-88-9 Xanthylium, 9-(2-carboxyphenyl)-3,6-bis(diethylamino)-, chloride 822-16-2 Octadecanoic acid, sodium salt 822-16-2 Octadecanoic acid, sodium salt 822-17-3 9,12-Octadecadienoic acid (9Z, 12Z)-, sodium salt 82385-42-0 Saccharin, sodium salt hydrate 827-19-0 Benzenesulfonic acid, 2,5-dimethyl-, sodium salt 827-21-4 Benzenesulfonic acid, 2,4-dimethyl-, sodium salt 828-00-2 Dimethoxane

82833-23-6 Benzenesulfonic acid, 2,2'-(1,2-ethenediyl)bis[5-[[4-[(2-hydroxypropyl) amino]-6-(phenylamino)-1,

82919-37-7 Decanedioic acid, methyl 1,2,2,6,6-pentamethyl-4-piperidinyl ester 82980-39-0 Glycerides, wheat germ-oil 83137-86-4 Acrysol RM 5 83-66-9 2,6-Dinitro-3-methoxy-4-tert-butyltoluene 83-88-5 Riboflavin 842-07-9 2-Naphthalenol, 1-(phenylazo)-

84268-33-7 Benzenepropanoic acid, 3-(2H-benzotriazol-2-yl)-5-(1,1-dimethylethyl)-4-hydroxy-, methyl ester (

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CAS Reg. No. Chemical Name 84501-72-4 Sodium isononanoate 84540-57-8 Propylene glycol monomethyl ether acetate 84604-14-8 Extract of rosemary 84-66-2 Diethyl phthalate 846-70-8 2-Naphthalenesulfonic acid, 8-hydroxy-5,7-dinitro-, disodium salt 84681-71-0 Hydrogenated rapeseed oil 84696-51-5 Spearmint, ext. 84-74-2 Dibutyl phthalate 84775-78-0 Kelp 84-88-8 5-Quinolinesulfonic acid, 8-hydroxy- 84929-31-7 Lemon extract 84961-66-0 Tobacco dust 85049-30-5 Bentonite, sodian 85116-93-4 Fatty acids, C16-18, esters with pentaerythritol 85261-20-7 D-Glucitol, 1-deoxy-1(methylamino)-, N-C10 acyl derivs. 85-40-5 4-Cyclohexene-1,2-dicarboximide 85-41-6 Phthalimide 85-44-9 Phthalic anhydride 85536-14-7 Benzenesulfonic acid, 4-C10-13-sec-alkyl derivs. 85585-93-9 Carbonic acid, aluminum magnesium salt, basic 85637-75-8 Oxirane, methyl-, polymer with oxirane, mono[2-(2-butoxyethoxy)ethyl] ether

85665-95-8 7-Benzothiazolesulfonic acid, 2-{4-{{4-{{3-{{5-(aminocarbonyl)-1- ethyl- 1,6-dihydro-2-hydroxy-4-m

85-68-7 Butyl benzyl phthalate 85711-55-3 Fatty acids, tall-oil, compds. with oleylamines 85763-69-5 Iron, C3-13-carboxylate naphthenate complexes

85828-89-3 Chromium, 2-[(4,5-dihydro-3-methyl-5-oxo-1-phenyl-1H-pyrazol-4-yl)azo]benzoate 2-[4,5-dihydro-3

85-83-6 C.I. Solvent Red 24 85-86-9 2-Naphthalenol, 1-((4-(phenylazo)phenyl)azo)- 860-22-0 FD&C Blue No. 2 86352-09-2 Naphthalenesulfonic acids, polymers with formaldehyde, sodium salts

86356-61-8 1-(2',5'-Dichloro-4'-sulfophenyl)-3-methyl-4-((4"-(N-polyoxyalkylene sulfonamide)phenyl)azo)pyrazol-5-one, sodium salt

864277-75-8 Lignoflex 866-83-1 Potassium citrate, monobasic 866-84-2 Potassium citrate 868-18-8 Sodium tartrate

86864-96-2 2-Propenoic acid, polymer with 2-hydroxypropyl 2-propenoate and sodium 2-propenoate

868662-38-8 Poly(oxy-1,2-ethanediyl), alpha-methyl-omega-[2-methyl-3-[1,3,3,3-tetramethyl-1-[(trimethylsilyl) oxy] disiloxanyl]) propoxy]

86893-19-8 Ethoxylated methyl glucoside dioleate 87-01-4 7-(Dimethylamino)-4-methylcoumarin 87157-58-2 D-Glucitol, 1-deoxy-1(methylamino)-, N-C14 acyl derivs.

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CAS Reg. No. Chemical Name 87-20-7 Isoamyl salicylate 87244-72-2 Siloxanes and Silicones, polyoxyalkylene- 87246-72-8 D-Glucitol, 1-deoxy-1(methylamino)-, N-C12 acyl derivs. 872-50-4 N-Methyl-2-pyrrolidone 87-25-2 Ethyl anthranilate

87315-51-3 Polyoxyethylene* amylphenol - formaldehyde resin *(10 moles) (Mol. Wt. 1500-3000)

87-69-4 Tartaric acid 877-24-7 1,2-Benzenedicarboxylic acid, monopotassium salt

87823-33-4 2H-1,3,5-Oxadiazine-2,4,6(3H,5H)-trione, 3,5-bis(6-isocyanatohexyl)-, polymer with N-(2-aminoethyl)-1,2-ethanediamine

87-90-1 Symclosene 88-04-0 p-Chloro-m-xylenol 88-12-0 N-Vinyl-2-pyrrolidone

881689-05-0 Poly(oxy-1,2-ethanediyl), alpha-[3-[dimethyl[2-(trimethylsilyl) ethyl] silyl] propyl]-omega-methoxy-

88230-35-7 Hexanol, acetate, branched and linear 88-24-4 2,2'-Methylenebis(4-ethyl-6-tert-butylphenol) 88349-88-6 Acetic acid, [(5-chloro-8-quinolinyl)oxy]- (metabolite of inert safener) 88-41-5 Cyclohexanol, 2-(1,1-dimethylethyl)-, acetate 88-61-9 Benzenesulfonic acid, 2,4-dimethyl-

886993-11-9 2-Propenoic acid, methyl ester, polymer with ethenyl acetate, hydrolyzed, sodium salts

88795-12-4 1-Butanol, 4-(ethenyloxy)-, polymer with chlorotrifluoroethene, (ethenyloxy)cyclohexane and ethoxyethene

88-89-1 2,4,6-Trinitrophenol

888969-14-0 2-Propenoic acid, 2-methyl-, polymers with Et acrylate and polyethylene glycol methacrylate C18-22-alkyl ethers

88923-95-9 Isocyanic acid, polymethylenepolyphenylene ester, polymer with N-(2-aminoethyl)-N'-[2-[(2-aminoethyl)amino]ethyl]-1,2-ethanediamine

89-04-3 Trioctyl trimellitate

893427-80-0 Oxirane, hexadecyl-, reaction products with polyethylene-polypropylene glycol ether with trimethylolpropane (3:1)

89511-79-5 2-Propenoic acid, 2-methyl-.polymer with ethyl 2-propenoate and methyl 2-methyl-2-propenoate, s

89595-41-5 Phosphate, dihydrogen, monopotassium salt 89-65-6 D-Isoascorbic acid

89678-90-0 2-Propenoic acid, polymer with ethenylbenzene and (1-methylethenyl)benzene, ammonium salt

89-78-1 Menthol 89-83-8 Thymol 89960-16-7 Butanedioic acid, sulfo-, 1,4-di-sec-octyl ester, sodium salt 9000-01-5 Gum arabic 9000-07-1 Carrageenan 9000-11-7 Cellulose, carboxymethyl ether

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CAS Reg. No. Chemical Name 9000-21-9 Furcellaran 9000-28-6 Gum ghatti 9000-30-0 Guar gum 9000-40-2 Locust bean gum 9000-50-4 Oils, oakmoss-resinoid 9000-59-3 Shellac 9000-65-1 Gum tragacanth 9000-69-5 Pectin 9000-70-8 Gelatins 9000-71-9 Caseins 9000-90-2 Amylase, alpha- 9001-45-0 beta-D-glucuronidase 9001-45-0 beta-Glucuronidase 9001-73-4 Papain 9002-18-0 Agar 9002-81-7 Poly(oxymethylene) 90028-20-9 Echinacea purpurea, ext. 9002-84-0 Ethene, 1,1,2,2-tetrafluoro-, homopolymer 9002-86-2 Polyvinyl chloride resin 9002-88-4 Polyethylene 9002-89-5 Polyvinyl alcohol 9002-92-0 Poly(oxy-1,2-ethanediyl), alpha-dodecyl-omega-hydroxy-

9002-93-1 Poly(oxy-1,2-ethanediyl), alpha-[4-(1,1,3,3-tetramethylbutyl}phenyl]- omega-hydroxy-

9003-01-4 Carboxy vinyl polymer 9003-04-7 Sodium polyacrylate 9003-05-8 Polyacrylamide 9003-06-9 Acrylamide acrylic acid polymer 9003-07-0 Polypropylene 9003-08-1 2,4,6-Triamino-s-triazine-formaldehyde polymer 9003-09-2 2-Ethene, methoxy-, homopolymer 9003-11-6 Oxirane, methyl-, polymer with oxirane 9003-13-8 Butoxypolypropylene glycol 9003-17-2 Butadiene resin 9003-18-3 2-Propenenitrile, polymer with 1,3-butadiene 9003-20-7 Acetic acid ethenyl ester, homopolymer 9003-22-9 Vinyl chloride vinyl acetate copolymer 9003-27-4 Polyisobutylene 9003-28-5 Butene, homopolymer 9003-29-6 Polybutene 9003-32-1 Ethyl acrylate polymer 9003-35-4 Phenol, polymer with formaldehyde 9003-39-8 2-Pyrrolidinone, 1-ethenyl-, homopolymer 9003-49-0 Polymerized butyl acrylate 9003-53-6 Polystyrene resin

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CAS Reg. No. Chemical Name 9003-55-8 Butadiene-styrene copolymer 9003-56-9 2-Propenenitrile, polymer with 1,3-butadiene and ethenylbenzene 9003-63-8 n-Butyl methacrylate, polymerized 9003-68-3 Pegoterate 9004-32-4 Cellulose, carboxymethyl ether, sodium salt 9004-34-6 Cellulose 9004-35-7 Cellulose, acetate 9004-36-8 Cellulose acetate butyrate 9004-53-9 Dextrin 9004-57-3 Cellulose, ethyl ether 9004-58-4 Cellulose, ethyl 2-hydroxyethyl ether 9004-62-0 Cellulose, 2-hydroxyethyl ether 9004-64-2 Cellulose, 2-hydroxypropyl ether 9004-65-3 Cellulose, 2-hydroxypropyl methyl ester 9004-67-5 Cellulose, methyl ether 9004-74-4 Poly(oxy-1,2-ethanediyl),.alpha.-methyl-.omega.-hydroxy- 9004-77-7 Butoxypoly(ethyleneoxy) ethanol 9004-81-3 Polyoxyethylene monolaurate (Mol. Wt. 780) 9004-82-4 Poly(oxy-1,2-ethanediyl), alpha-sulfo-omega-(dodecyloxy)-, sodium salt 9004-83-5 Poly(oxy-1,2-ethanediyl), [alpha]-[2(tert-dodecylthio)ethyl]-[omega] hydroxy- 9004-87-9 Ethoxylated isooctylphenol 9004-94-8 Polyethyleneglycol palmitate 9004-95-9 Polyoxyethylene* cetyl alcohol *(2.5 moles) 9004-96-0 Poly(oxy-1,2-ethanediyl), alpha-(1-oxo-9-octadecenyl)-omega-hydroxy-(Z)-

9004-97-1 Poly(oxy-1,2-ethanediyl), alpha-[(9Z,12R)-12-hydroxy-1-oxo-9-octadecenyl]-omega-hydroxy-

9004-98-2 Poly(oxy-1,2-ethanediyl), alapha-(9Z)-9-octadecenyl-omega-hydroxy- 9004-99-3 Polyoxyethylene stearate (Mol. Wt. 600-2000) 9005-00-9 Poly(oxy-1,2-ethanediyl), alpha-octadecyl-omega-hydroxy-

9005-02-1 Poly(oxy-1,2-ethanediyl), α-(1-oxododecyl)-ω-[(1- oxododecyl)oxy]-

9005-07-6 Polyoxyethylene dioleate 9005-08-7 Poly(oxy-1,2-ethanediyl), α-(1-oxooctadecyl)-ω-((1-oxooctadecyl)oxy)- 9005-25-8 Starch 9005-27-0 Starch , 2-hydroxyethyl ether 9005-32-7 Alginic acid 9005-35-0 Calcium alginate 9005-37-2 Propylene glycol alginate 9005-38-3 Sodium alginate

9005-42-9 Caseins, ammonium complexes (food commodity allergen - use pattern is limited)

9005-46-3 Caseins, sodium complexes 9005-53-2 Lignin 9005-64-5 Sorbitan, monododecanoate, poly(oxy-1,2-ethanediyl) derivs. 9005-65-6 Sorbitan, mono-9-octadecenoate, poly(oxy-1,2-ethanediyl) derivs., (Z)-

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CAS Reg. No. Chemical Name 9005-66-7 Polyoxyethylene* sorbitan monopalmitate *(20 moles) 9005-67-8 Polyoxyethylene sorbitan monostearate 9005-70-3 Polyoxyethylene* sorbitan trioleate *(20 moles) 9005-71-4 Polyoxyethylene* sorbitan tristearate *(20 moles) 9005-90-7 Turpentine 9006-03-5 Chlorinated rubber 9006-26-2 2,5-Furanedione, polymer with ethene 9006-27-3 Poly(oxy-1,2-ethanediyl), alpha-(1-oxododecyl)-omega-methoxy- 90063-37-9 Lavender, Lavandula angustifolia, ext. 9006-50-2 Egg white 9006-65-9 Dimethicone 9007-13-0 Resin acids and rosin acids, calcium salts 9007-48-1 Polyglyceryl oleate 9008-34-8 Resin acids and rosin acids, manganese salts 9008-63-3 Naphthalenesulfonic acid, sodium salt, polymer with formaldehyde 9009-32-9 Polyglyceryl stearate

90093-37-1 Ethanol, 2,2',2''-nitrilotris-, compd. with α-(2,4,6-tris(1-phenylethyl)phenyl)-ω-hydroxypoly(oxy-1,2-ethanediyl)phosphate

9010-66-6 Zein 9010-77-9 Ethylene acrylic acid 9010-79-1 Ethylene-propylene copolymer 9010-88-2 2-Propenoic acid, 2-methyl-, methyl ester, polymer with ethyl 2-propanoate 9010-89-3 Poly(diethylene glycol adipate) 9011-05-6 Cross linked protein urea-formaldehyde copolymer 9011-06-2 Ethene, 1,1-dichloro-, polymer with chloroethene 9011-09-0 2-Propenoic acid, butyl ester, polymer with 1,1-dichloroethene 9011-11-4 Styrene, alpha-methyl-, polymer with styrene 9011-13-6 Styrene - maleic anhydride resin 9011-14-7 Poly(methyl methacrylate) 9011-16-9 Methoxyethylene-maleic anhydride copolymer 9011-29-4 Sorbitol sesquioleate ethoxylated(30 moles) 9012-54-8 Cellulase 9012-76-4 Chitosan 9014-01-1 Subtilisin 90147-57-2 Yucca extractives (from Yucca, Agavaceae) 90147-58-3 Yucca, extract 9014-85-1 Polyoxyethylene* 2,4,7,9-tetramethyl-5-decyne-4,7-diol *(3.5-30 moles) 9014-90-8 Sodium nonylphenyl polyoxyethylene* sulfate *(4-5 moles) 9014-92-0 alpha-(Dodecylphenyl)-omega-hydroxypoly(oxy-1,2-ethanediyl) 9014-93-1 Polyoxyethylene* dinonylphenol *(2-50 moles) 9015-54-7 Protein hydrolyzates 9016-00-6 Poly(oxy(dimethylsilylene)) 9016-45-9 Poly(oxy-1,2-ethanediyl), α-(nonylphenyl)-ω-hydroxy- 9016-87-9 Polymethylenepolyphenylene isocyanate

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9016-88-0 1,4-Benzenedicarboxylic acid, polymer with 1,2-ethanediol and alpha-hydro-omega-hydroxypoly(oxy-1,2-ethanediyl)

9017-33-8 Naphthalenesulfonic acid-formaldehyde condensate 9017-68-9 Acrylic acid, polymer with isooctyl acrylate

9017-79-2 Benzenemethanaminium, ar-ethenyl-N,N,N-trimethyl-, hydroxide, polymer with diethenylbenzene

9017-80-5 Benzenemethanaminium, ar-ethenyl-N,N,N-trimethyl-, chloride, homopolymer

9018-04-6 Poly(oxy-1,4-butanediyl), α-hydro-ω-hydroxy-, polymer with 1,4-butanediol and 1,1'-methylenebis(4-isocyanatobenzene)

9019-29-8 Butene, polymer with ethene 90194-45-9 Benzenesulfonic acid, mono-C10-13-alkyl derivs., sodium salts

9020-13-7 2-Propenoic acid, 2-methyl-, polymer with diethenylbenzene and ethenylbenzene

9032-42-2 Methyl hydroxyethyl cellulose 9033-79-8 2-Propenoic acid, polymer with sodium 2-propenoate 9036-19-5 Poly(oxy-1,2-ethanediyl), α-((1,1,3,3-tetramethylbutyl)phenyl)-ω-hydroxy- 9036-66-2 D-Galacto-L-arabinan

90371-20-3

2-Propenoic acid, monoester with 1,2-propanediol, polymer with chloroethene and ethenyl acetate, ester with ethenylbenzene polymer with 2,5-furandione 2-butoxyethyl ester

9038-29-3 Propylene oxide ethylene oxide polymer decyl ether

903890-89-1 Oxirane, decyl-, reaction products with polyethylene-polypropylene glycol ether with trimethylopropane (3:1).

903890-90-4 Oxirane, methyl-, polymer with oxirane ether with 2-ethyl-2-(hydroxymethyl)-1,3-propanediol (3:1), reaction products with tetradecyloxirane.

9038-95-3 Oxirane, methyl-, polymer with oxirane, monobutyl ether 9041-04-7 Benzenesulfonic acid, hydroxy-, polymer with formaldehyde and urea 9041-33-2 Oxirane, methyl-, polymer with oxirane, mono-2-propenyl ether 9042-19-7 Poly[oxy(methyl-1,2-ethanediyl)], alpha-2-propenyl-omega-hydroxy- 9043-30-5 Polyoxyethylene isotridecyl ether 90438-79-2 Acetic acid, C6-8-branched alkyl esters 9044-17-1 Butene, polymer with 2-methyl-1-propene 9046-01-9 Poly(oxy-1,2-ethanediyl), alpha-tridecyl-omega-hydroxy-, phosphate 9046-09-7 Poly(oxy-1,2-ethanediyl), α-(tributylphenyl)-ω-hydroxy-

9046-10-0 Poly(oxy(methyl-1,2-ethanediyl)), α-(2-aminomethylethyl)-ω-(2-aminomethylethoxy)-

9049-05-2 Carrageenan calcium salt 9050-36-6 Maltodextrin 90506-18-6 Phosphoric acid, C8-16-alkyl esters, compds. with diethanolamine 9051-57-4 Ammonium nonylphenyl polyoxyethylene sulfate *(4-5 moles) 9063-38-1 Starch, carboxymethyl ether, sodium salt 9063-89-2 Poly(oxy-1,2-ethanediyl), alpha-(octylphenyl)-omega-hydroxy- 9064-13-5 Poly{oxy(methyl-1,2-ethanediyl)}, alpha-(methylphenyl)-omega-hydroxy- 9069-79-8 Potassium salt of naphthalenesulfonic acid - formaldehyde condensate 9069-80-1 Formaldehyde-naphthalenesulfonic acid polymer, ammonium salt

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9069-94-7 Dimethyl 5-sodiosulfoisophthalate-dimethyl terephthalate-ethylene glycol-polyethylene glycol copolymer

9071-85-6 Poly(oxy-1,2-ethanediyl), α,α'-phosphinicobis(ω-(nonylphenoxy)- 90-72-2 Phenol, 2,4,6-tris{(dimethylamino)methyl}-

9079-33-8

Poly(oxy-1,2-ethanediyl), .alpha.,.alpha.',.alpha.'',.alpha.'''-[[(2-sulfophenyl)methyliumylidene]bis(4,1-phenylenenitrilodi-2,1-ethanediyl)]tetrakis[.omega.-hydroxy-, chloride, monosodium salt

9079-34-9

Poly(oxy-1,2-ethanediyl), .alpha.,.alpha.',.alpha.'',.alpha.'''-[[(2-sulfophenyl)methyliumylidene]bis[(3-methyl-4,1-phenylene)nitrilodi-2,1-ethanediyl]]tetrakis[.omega.-hydroxy-, chloride, monosodium salt

90-80-2 Glucono-delta-lactone 9081-17-8 Nonylphenol, ethoxylated, monoether with sulfuric acid 9082-00-2 Oxirane, methyl-, polymer with oxirane, ether with 1,2,3-propanetriol (3:1) 9084-06-4 Naphthalenesulfonic acid, polymer with formaldehyde, sodium salt

9086-75-3 Poly(oxy-1,2-ethanediyl), alpha-(phenylmethyl)-omega-((1,1,3,3-tetramethylbutyl)phenoxy)-

9087-53-0 Polyethylene-polypropylend glycol hexadecyl ether 91031-95-7 Mannitan coconut oil ester 91051-70-6 Propylene glycol tall oil ester 91078-64-7 Naphthalenesulfonic acids, branched and linear Bu derivs., sodium salts 91-20-3 Naphthalene 91-53-2 Ethoxyquin

915-67-3 2,7-Naphthalenedisulfonic acid, 3-hyroxy-4-((4-sulfo-1-naphthyl)azo)-, trisodium salt

91697-98-2 Glycerides, C8-18 and C18-unsatd. mono- 91994-94-4 Acetylated lanolin alcohol 92129-90-3 Whey 92257-31-3 2-Naphthalenol ((phenylazo) phenyl) azo alkyl derivatives. 928-72-3 Glycine, N-(carboxymethyl)-, disodium salt 928-96-1 3-Hexen-1-ol, (3Z)- 93-08-3 2'-Acetonaphthone 93385-02-5 1-Propanol, 2-(tetradecyloxy)-,acetate 93385-03-6 3,6,9,12-Tetraoxaoctacosan-1-ol, 11-methyl, acetate 93-56-1 Phenyl glycol 93763-70-3 Perlite, expanded 93-83-4 9-Octadecenamide, N,N-bis(2-hydroxyethyl)-, (Z)- 93858-51-6 Benzenesulfonic acid, dodecyl-, compd. with 3-methoxy-1-propanamine (1:1) 93-89-0 Benzoic acid, ethyl ester 93918-16-2 Manganese neononoate 93-92-5 Benzenemethanol,α-methyl-,acetate 94-09-7 Ethyl p-aminobenzoate 94-13-3 Propyl p-hydroxybenzoate

94133-90-1 1-Propanesulfonic acid, 3-{{3-(dimethylamino)propyl}{(heptadecafluorooctyl)sulfonyl}amino}-2-hy

94133-91-2 1-Propanaminium, 3-{{(heptadecafluorooctyl)sulfonyl}(2-hydroxy-3-

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CAS Reg. No. Chemical Name sulfopropyl)amino}-N-(2-hydrox

94248-66-5 Isohexadecanoic acid, monoester with glycerol 94266-47-4 Citrus, ext. 94-26-8 Butyl p-hydroxybenzoate 94313-89-0 Ammonium diisodecyl sulfosuccinate 94349-62-9 Aloe barbadensis, ext. 94-36-0 Benzoyl peroxide 94-91-7 N,N'-Disalicylidene-1,2-propanediamine 95-14-7 1,2,3-Benzotriazole 95-19-2 1-(2-Hydroxyethyl)-2-(heptadecyl)imidazoline 95-38-5 1-(2-Hydroxyethyl)-2-(heptadecenyl)imidazoline 95-47-6 2-Xylene 95-48-7 o-Cresol 95-49-8 o-Chlorotoluene 95-63-6 Trimethylbenzene

95913-20-5 1H-Imidazoledipropanoic acid, 4,5-dihydro-1-(2-hydroxyethyl)-2-norcoco alkyl derivs., di-me esters, phosphates (esters), sodium salts

959-55-7 Benzenemethanaminium, N,N-dimethyl-N-octyl-, chloride 96-29-7 Methyl ethyl ketoxime 96-48-0 gamma-Butyrolactone 96949-21-2 Rhamsan gum 97043-91-9 Alcohols, C9-16, ethoxylated 97-23-4 Dichlorophene 97298-48-1 Bis(1-methylheptyl) 2-butenedioate 97-53-0 Phenol, 2-methoxy-4-(2-propenyl)- 97-56-3 Benzenamine, 2-methyl-4-{(2-methylphenyl)azo}- 97-59-6 Allantoin 97-63-2 2-Propenoic acid, 2-methyl-, ethyl ester 97-64-3 Lactic acid, ethyl ester 97675-81-5 Fish, meal 97676-23-8 Oils, licorice 97766-30-8 Orange, sweet, valencia, ext. 97-78-9 Glycine, N-methyl-N-(1-oxododecyl)- 97-85-8 Isobutyl isobutyrate 97-88-1 Butyl methacrylate

97953-25-8 Acrylic acid-sodium acrylate-sodium-2-methylpropanesulfonate copolymer(minimum average molecular

97-99-4 Tetrahydrofurfuryl alcohol 980-26-7 C.I. Pigment Red 122 98-52-2 Cyclohexanol, 4-(1,1-dimethylethyl)- 98-54-4 p-tert-Butylphenol 98-55-5 alpha-Terpineol 98730-04-2 Benoxacor 98824-28-3 Casamid 362 98-82-8 Benzene, (1-methylethyl)-

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CAS Reg. No. Chemical Name 98-86-2 Acetophenone 98-92-0 Nicotinamide

989-38-8 Xanthylium, 9-(2-(ethoxycarbonyl)phenyl)-3,6-bis(ethylamino)-2,7-dimethyl-, chloride

98-94-2 N,N-Dimethylcyclohexylamine 99-07-0 DMP (dimethylaminomethylphenols) - epoxy curing agents (hardeners) 994-36-5 Citric acid, sodium salt 99607-70-2 Acetic acid, {(5-chloro-8-quinolinyl)oxy}-, 1-methylhexyl ester 99734-09-5 Poly(oxy-1,2-ethanediyl), α-{tris(1-phenylethyl)phenyl}-ω-hydroxy- 99-76-3 Benzoic acid, 4-hydroxy-, methyl ester 99-85-4 .gamma.-Terpinene 99-86-5 α-Terpinene 99-87-6 p-Cymene 999-97-3 Silanamine, 1,1,1-trimethyl-N-(trimethylsilyl)- N/A 1-Benzyl-2-stearylbenzimidazol-6,3'-disulfonic acid, sodium salt

N/A

5-Enolpyruvylshikimate-3-phosphate synthase as produced in potato by the CTP2-CP4syn gene and its controlling sequences and found in the following construct: PV-STMT01

N/A a-Alkyl*-omega-hydroxypoly(oxyethylene) poly(oxypropylene) condensate with monostearyl acid phosphate *(30% C14, 30% C13, 20% C12, 20% C10)

N/A Alfalfa meal N/A Almond hulls N/A Almond shells N/A Aluminum - magnesium stearate N/A Apple pomace N/A Bacillus megaterium NRRL #B-3254,ATCC #11561 N/A Bacillus megaterium, BM 458 N/A Bacillus subtilis, CH201 N/A Beef fat N/A Beet powder N/A Bran N/A Bread crumbs N/A Calcareous shale N/A Canary seed N/A Cardboard N/A Cat food N/A Cheese N/A Cinnamon N/A Citrus pectin N/A Clam shells N/A Cloves N/A Cocoa shell flour N/A Cocoa shells N/A Cookies N/A Cornstarch

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CAS Reg. No. Chemical Name N/A Cotton N/A Diethanolamide of methyl laurate N/A Dog or cat collar N/A Douglas fir bark N/A Egg Shells

N/A Fatty acids, sunflower-oil, conjugated, polymers with maleic anhydride, and tall-oil fatty acids

N/A Feldspathoid (alkali aluminosilicate mimeral) N/A Flavoring

N/A Fumaric acid-isophthalic acid-styrene-ethylene/propylene glycol copolymer (minimum average mole

N/A Granite

N/A Imidazolium compds, 2-heptadecyl-4,5-dihydro-1-methyl-1-(2-tallow amidoethyl), Me sulfates

N/A Iron humate N/A Malt flavor N/A Meat meal N/A Meat scraps N/A Medicated feed N/A Millet seed N/A Mineral wool (tile) N/A Mixed Phytosterols (consisting of campesterol, sitosterol) N/A N-(Soya alkyl)-N-methylmorpholinium sulfate N/A N,N'-1,3-xylyl bis(12-hydroxystearamide) N/A N,N-Dimethyl oleyl-linoleylamine salt of benzoic acid N/A Naphthalenesulfonic acid, isopropylisohexyl-, sodium salt N/A Nutria meat N/A Nylon N/A Oyster shells N/A Paper N/A Paprika N/A Paraffin wax N/A Peanut butter N/A Peanut shells N/A Peat moss N/A Propylene glycol isobutyl ether and higher homologs N/A Pumice

N/A Red cabbage color, expressed from edible red cabbage heads via a pressing process using only acidified water

N/A Red cedar chips N/A Rubber N/A Sawdust N/A Seaweed, edible N/A Soy protein N/A Soybean hulls

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CAS Reg. No. Chemical Name N/A Sulfur coated urea N/A Walnut flour N/A Walnut shells N/A Wheat N/A Wool

Inert (other) Ingredients in Pesticide Products

Pesticide products contain both "active" and "inert" ingredients. The terms "active ingredient"

and "inert ingredient" have been defined by Federal law, the Federal Insecticide, Fungicide,

and Rodenticide Act (FIFRA), since 1947.

An active ingredient is one that prevents, destroys, repels or mitigates a pest, or is a plant regulator, defoliant, desiccant or nitrogen stabilizer. By law, the active

ingredient must be identified by name on the label together with its percentage by

weight. An inert ingredient means any substance (or group of structurally similar substances if

designated by the Agency), other than an active ingredient, which is intentionally included in a pesticide product. Inert ingredients play a key role in the effectiveness

of a pesticidal product. For example, inert ingredients may serve as a solvent, allowing the pesticide's active ingredient to penetrate a plant's outer surface. In

some instances, inert ingredients are added to extend the pesticide product's shelf-

life or to protect the pesticide from degradation due to exposure to sunlight. Pesticide products can contain more than one inert ingredient, but federal law does

not require that these ingredients be identified by name or percentage on the label. Only the total percentage of inert ingredients is required to be on the pesticide product label.

Name Change: From Inert to Other Ingredients

In September 1997, the Environmental Protection Agency (EPA) issued Pesticide Regulation

Notice 97-6 which encourages manufacturers, formulators, producers, and registrants of

pesticide products to voluntarily substitute the term "other ingredients" as a heading for the

"inert" ingredients in the ingredient statement on the label of the pesticide product. EPA made

this change after learning the results of a consumer survey on the use of household pesticides.

Many comments from the public and the consumer interviews prompted EPA to discontinue

the use of the term "inert." Many consumers are mislead by the term "inert ingredient",

believing it to mean "harmless." Since neither federal law nor the regulations define the term

"inert" on the basis of toxicity, hazard or risk to humans, non-target species, or the

environment, it should not be assumed that all inert ingredients are non-toxic.

Last updated on Thursday, August 28th, 2008. http://www.epa.gov/opprd001/inerts/

Fluoride: The Ultimate Cluster Flux Folder 3A

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