New Chemicals Program P2 Awards, 1996 - Union Carbide
William C. Kuryla, Ph.D.
Associate Director of Product Safety
Union Carbide Corporation
39 Old Ridgebury Road, Sec. P-2
Danbury, CT 06817-0001
Re: Recognition of Achievement in Pollution Prevention--PMN 95-681
Dear Dr. Kuryla:
I am very pleased to inform you that EPA's Office of Pollution Prevention and Toxics (OPPT) is hereby recognizing Union Carbide Corporation for an important achievement in pollution prevention (P2) via innovative chemical design. This achievement involves the new chemical substance described in premanufacture notice (PMN) 95-681, submitted to EPA pursuant to section 5 of the Toxic Substances Control Act (TSCA).
Development of your new chemical represents a significant innovation in surfactant chemistry, one that greatly reduces risk to the aquatic environment. As part of the New Chemicals Program's P2 Recognition Program, which is associated with the Agency's Environmental Technology Initiative (ETI) for Chemicals, I congratulate you for this technological innovation and for your environmental stewardship. I also commend you for your leadership in joining with the Agency under the ETI for Chemicals to form a partnership that governs the risk management of the PMN substance and any future chemicals you develop in the same class. The Agency's choice of a non-regulatory partnership in lieu of traditional risk management is a reflection of the innovative qualities of your new surfactants and their potential to benefit the environment.
EPA considers your PMN substance worthy of P2 recognition because of its unique chemistry and associated prevention benefits. Your new surfactant is a true P2 innovation because it can be chemically split and its surfactancy completely eliminated prior to environmental release; furthermore, the splitting process results in two essentially non-polluting fragments or byproducts. As a consequence, the PMN substance is significantly safer than the nonionic compounds for which it will substitute.
In addition, the new surfactant produces less solid byproduct and thus less sludge for landfill than similar substances and the sludge that is generated is higher in organic content and therefore more suitable for energy recovery as fuel. When industrial laundries use the PMN substance in lieu of detergents that cannot be chemically split, the Agency anticipates that the usage and discharge of phosphates will also be reduced. Of course, to realize these environmental benefits the PMN substance must be chemically split prior to release and thus careful stewardship practices, as described in the EPA-Union Carbide partnership and Memorandum of Understanding, are essential.
OPPT has instituted the P2 Recognition Program as a means to encourage innovation and further pollution prevention. In addition to formal notice by letter, EPA is considering publicly listing P2 Recognition recipients on the Internet and perhaps in other media as well. The Agency may also publish articles describing the pollution prevention benefits of specific chemicals which are the subject of a PMN. As always, confidential business information claims will limit our ability to communicate about these new chemicals and to announce, describe and promote these P2 innovations. The Agency welcomes your ideas and comments on how best to recognize and spread the word about your and other noteworthy P2 accomplishments. In this particular case, it would be helpful if you would drop the CBI claims concerning chemical identity.
Please realize that New Chemicals Program reviewers often rely heavily on information manufacturers supply on the P2 page of the Premanufacture Notice to identify recognition candidates. EPA urges all submitters to provide sufficient detail in a notice so that the Agency can perform a thorough analysis of P2 claims. In essence, pollution prevention means reducing or eliminating a potential pollutant before it is created. Ideally, P2 should be accomplished through innovative chemical design or redesign. EPA advocates P2 because it makes sense -- for the environment and the economy. By not creating a pollutant, one avoids the hazards and costs associated with controlling exposures to and releases of that pollutant. In-process recycling may provide benefits similar to P2. (For more information on P2, visit EPA's Pollution Prevention Homepage: http://www.epa.gov, select "Search" then type "p2home.")
Since EPA has only limited information on your P2 Recognition chemical, I ask that you keep the Agency informed of this substance's commercial success over time, any toxicity data that becomes available, and the uses you make of this P2 recognition, e.g., in product literature or advertising. Please note that under section 5 of the Federal Trade Commission Act any marketing claims based on this letter must be accurate and not misleading. (For additional information, see "Guides for the Use of Environmental Marketing Claims" issued by the Federal Trade Commission on July 28, 1992 at 57 FR 36363, codified at 16 CFR Part 260, and reissued in October 1996. Copies of the Guide are available by calling the FTC at (202) 326-2222 or on the Internet at http://www.ftc.gov under the heading "Consumer Protection Rules and Guides" and the subheading "Environmental Marketing Guides.")
When you have new information or if you have any questions regarding the P2 Recognition Program, please contact Roy Seidenstein (202-260-2252) or Kenneth Moss (202-260-3395). You can reach Mr. Seidenstein or Mr. Moss by fax at 202-260-0118; by mail at USEPA, Office of Pollution Prevention and Toxics, MC 7405, 401 M Street, SW, Washington, DC 20460; or via e-mail at firstname.lastname@example.org or email@example.com. Also, my office runs the President's Green Chemistry Challenge Awards program. I understand that you have nominated this PMN for a Green Chemistry award; good luck with your candidacy.
Again, congratulations on your pollution prevention achievement. The Agency wishes you continued success with future innovations.
William H. Sanders III, Dr. P.H., P.E.
Director, Office of Pollution Prevention and Toxics
cc: W.H. Joyce, Ph.D., Chief Executive Officer
Gordon D. Mounts, Vice President/General Manager,
Industrial Performance Chemicals
Ron Van Mynen, Vice President, Health, Safety &
David DiFiore, EPA