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Possible Control of EU Priority Substances in Danish Waters

9 Assessment of nonylphenol

• 9.1 Definition of the reference state
  • 9.1.1 Introduction
  • 9.1.2 Main uses and pollution sources
  • 9.1.3 Releases to and state of the aquatic environment
  • 9.1.4 Existing legislation/regulation and their impact
  • 9.1.5 Conclusion on the need for further regulation
  9.2 Possible reduction/elimination measures
  • 9.2.1 Technical measures to reduce/eliminate nonylphenol
  • 9.2.2 Possible synergies with other (priority) substances
  • 9.2.3 Summary and assessment of technical possibilities
• 9.3 Economic Assessment
• 9.4 Conclusion on Nonylphenol
• 9.5 References

9.1 Definition of the reference state

9.1.1 Introduction

The name "nonylphenol" is used for a number of isomer substances having a phenol ring structure and alkyl chain of C₉H₁₉. The variations include the location of the nonyl group (C₉H₁₉) on the phenyl molecule, the number and the location of branching of the alkyl chain. The CAS no. 25154-52-3 originally covered all nonylphenols but later only the linear molecule while the branched ones have received a CAS no. of their own (90481-04-2: nonylphenol, branched).

Nonylphenol is a starting material for the production of a number of surfactants (cleaning agents) used in household and commercial products. It is also used directly to assist in keeping other slightly soluble or insoluble materials in solution. The surfactant products produced from nonylphenol are called "nonylphenol ethoxylates" (also NPE). They are produced by adding one or more ethoxy groups to the parent nonylphenol. NPE have been used for decades in a wide variety of consumer products (e.g., personal care, laundry products and cleaners), commercial products (e.g., floor and surface cleaners), and in many industrial cleaning processes (e.g., textile scouring). NPE are very relevant when discussing nonylphenol in the environment, as the NPE relatively quickly breaks down to nonylphenol when released to the environment.

Environmentally, nonylphenol is lipophilic (i.e. fat-soluble), has low water solubility (around 10 mg/l) and sorbs to particulate (organic) matter. The volatility of the substance is low. Nonylphenol is very low degradable in the environment, with the highest degradation seen under aerobic conditions /12/. NP has been reported to cause a number of estrogenic responses in a variety of aquatic organisms.

9.1.2 Main uses and pollution sources

Based on registrations in the Danish Product Registry (autumn 2004), the primary use of nonylphenol in Denmark is as hardeners in for instance concrete, epoxy and PUR products. An example of the use of nonylphenol as hardener is when laying out an epoxy floor where nonylphenol is used for accelerating the epoxy hardening process. The registered total consumption of nonylphenol for use in hardeners was around 70 tonnes when the data run was performed in the autumn of 2004 /3/.

Other main uses of nonylphenol are in paints and lacquers (11 tonnes) and in filling products (9 tonnes) /3/. Nonylphenol and nonylphenol ethoxylates are not used as additives for the production of paints and lacquers in Denmark /4/ but is present in imported products or semi-manufactured articles. Nonylphenol is further used in binders, construction materials, floorings etc.

Nonylphenol is used for the production of nonylphenol ethoxylates, which belong to the group of non-ionic tensides, used in cleaning materials and detergents for cleaning, as vehicle cleaners, anti-static cleaners and metal cleaning. This application has historically been the most dominant use of nonylphenol ethoxylates in Denmark, but since January 2005 it has been prohibited except for some specific industrial applications where the cleaning material is recovered or burned under controlled conditions /1/.

Nonylphenol ethoxylates and other alkylphenol ethoxylates accounted for around 20 % of the tensides used for cleaning materials in 1998, but this percentage is probably lower today due to regulatory actions including legislation and a voluntary agreement with industry /2/.

Nonylphenol and its ethoxylates have been used in cosmetics, cooling/lubricating oils and stain removers, but has been prohibited since January 2005  /9/.

A very rough estimate of the use of the total consumption of alkylphenol and alkylphenol ethoxylates in Denmark is 300-800 tonnes/year /3/.

9.1.3 Releases to and state of the aquatic environment

Monitoring data for nonylphenol in the environment are shown in table 9-1. The monitoring data show the concentrations of nonylphenols without its ethoxylates. The two small ethoxylates, nonylphenol ethoxylate (NP1EO) and nonylphenol diethoxylate (NP2EO), are often included to express the nonylphenol potential as these two ethoxylates are easily degraded into nonylphenol.

The monitoring data are all from before the new legislation on the use of nonylphenolethoxylates and related substances (see section 9.1.4) entered into force (in January 2005).

Table 9-1 Monitoring data for nonylphenol (mean values). Numbers in brackets are 95 % percentiles. Numbers in italic exceed the proposed EQS. Refs. /3/ /7/ /8/

*             Combined concentration of NP + NP1EO and NP2EO
**          Ref. /3/:   Median of 7 measurements in Damhusåen (Hvidovre), max value in brackets
               Ref. /13/: Median of 7 measurements in selected water courses (LOOP catchments). A total
               of 43 samples were analysed but only 7 were >LOD and the median value is only for these 7.
***        Combined system

Based on the median values from the screening project in sewage and in stormwater runoff presented in table 9-1, the total Danish releases of nonylphenol to the aquatic environment can be estimated as having been at about 180 kg/year and 860 kg/year respectively at the time when the present legislation entered into force.

Table 9-2 Monitoring data (mean values) for nonylphenol potential (sum of NP, NP1E and NP2E). Numbers in brackets are 95 %-percentiles. Numbers in italic exceed the proposed EQS. Refs. /3/ /7/ /8/

EQS proposal

The proposed EQS for nonylphenol are AA-EQS = 0.3 μg/l and MAC-EQS = 2.0 μμg/l respectively. Monitoring data, which exceed the proposed EQS, are marked in bold in the table above.

9.1.3.1 Point sources

Important point sources are discharge of nonylphenol-containing wastewater as this go directly to the surface water environment (following passage of a WWTP) and sewage overflow in case of heavy rain events.

Relevant wastewater discharges are from production facilities for nonylphenol (ethoxylates) containing products, e.g. paints, lacquers, PUR products and filling materials. The use of nonylphenol (ethoxylate)-containing products can further lead to release of nonylphenol (ethoxylate)-containing wastewater. Especially cleaning of nonylphenol-containing materials can produce nonyl-phenol wastewater, e.g. wet cleaning (washing) of epoxy floors, washing of paint brushes etc.

Discharge of cleaning products containing other alkylphenol ethoxylates could further constitute a source of pollution of the aquatic environment following partial degradation of the alkylphenol ethoxylates. According to information from SPT (the Association of Danish Cosmetics, Toiletries, Soap and Detergent Industries),  the use of other alkylphenol ethoxylates in cleaning products in Denmark is probably limited /5/ as only concentrations below 0.1% ww are allowed.

9.1.3.2 Diffuse sources

Due to the use of nonylphenol (ethoxylates) in construction materials as concrete and filling products runoffs from buildings etc. are believed to constitute an important diffuse source for release of nonylphenol to the water environment.

Another diffuse source for release of nonylphenol to the water environment is leaching from soil where sludge from wastewater treatment plants (WWTP) has been spread out. This source is, however, found to be of minor importance due to the relatively small part of the farm land receiving sludge and the strong binding properties of nonylphenol to organic matter in the soil.

Around 85,000 tonnes/year of WWTP sludge are applied to agricultural soils or in forests /6/). The maximum permitted load of WWTP sludge to farm land is 7 tonnes dw/ha as an average over 10 years /7/, and the total area receiving sludge can thus be estimated to 0.5-1 % of the total farm land in Denmark annually. The maximum allowable concentration of NPE in the sludge is 10 mg/kg sludge (dry weight basis).

9.1.4 Existing legislation/regulation and their impact

Statutory Order no 1006 of 12 October 2004 from the Ministry of the Environment

The order came into force in January 2005 and includes a ban on the use of nonylphenol and nonylphenol ethoxylates for/in:

• industrial cleaning with few exceptions
• cleaning in private homes
• manufacture of textiles and leather with few exceptions
• emulsifier in agricultural teat dips
• metal manufacturing with few exceptions
• production of paper and paper pulp
• cosmetic products and other personal care products except in spermicides
• pesticides

The three main uses of nonylphenol in Denmark according to the Product Registry (hardener, in paints and lacquers and in filling products) are not covered by the new regulation. However, since the mid 1990's there has been a voluntary agreement among the Danish paint and lacquer producers and importers not to use nonylphenol as an additive. As a rule of thumb, raw materials and semi-manufactured products with nonylpehol are not used either. Further, the regulation does not include alkylphenol ethoxylates other than nonylphenol ethoxylates, which can degrade into nonylphenol, and thus are relevant in this context.

Assessment:

It is assessed that the full effect of the Order has not been seen yet. The environmental monitoring data included above are further dates back to before the Order went into force.

The regulation prohibits some of the problematic uses of nonylphenol and its ethoxylates in relation to direct release to the aquatic environment. Especially the ban of nonylphenol (ethoxylates) in cleaning materials will result in a drop in the concentration of nonylphenol in wastewater.

The magnitude of the drop in concentrations is difficult to estimate as the use of nonylphenol and its ethoxylates in cleaning materials has been on the decline for a number of years as a result of a voluntary agreement from 1987 between the Association of Danish Cosmetics, Toiletries, Soap and Detergent Industries (SPT) and the Danish Environmental Protection Agency. This agreement included elimination of nonylphenol (ethoxylates) in the products of the companies organised in SPT (around 60-80 % of companies supplying household cleaning materials, but much less for industrial cleaning materials as for instance car shampoos /5/).

Separate wastewater discharges from industries producing or using nonylphenol-containing products can possibly include higher concentrations of nonylphenol and possibly exceed the AA-EQS. The number of such discharges is, however, believed to be relatively low.

It is expected that the reduction in the level of nonylphenol in surface runoff as a result of the Order will only be limited as the quality of runoff with regard to the chemical in question is probably mainly affected by general atmospheric deposition and by impacts of the use of car-care and maintenance products of which many are imported/marketed by companies not being members of SPT.

9.1.5 Conclusion on the need for further regulation

The concentration of nonylphenol in wastewater, both inlet and outlet, have dropped by around a factor 2 from 2003 to 2004. The decline in the wastewater concentrations of nonylphenol is a result of the voluntary agreement between SPT and DEPA from 1987 and the Executive Order No. 1006 of 12 October 2004. The full effect of this Order is not reflected in the environmental data above. Further reductions in the concentrations of nonylphenol in wastewater discharges can thus be expected in the coming two to three years (but hardly much longer).

The mean concentration of nonylphenol (NP) in sewage effluents is at the same level as the AA-EQS while the 95 % percentile concentration is about a factor 2 above this value. Hence, only a modest, normally obtainable initial dilution of sewage discharges is required to comply with the AA-EQS.

If instead the nonylphenol potential (NP + NP1EO + NP2EO) is being considered as the relevant parameter for evaluating discharges, emissions and losses of NP to the aquatic environment, then the required reduction of the concentration in the wastewater discharges will be moderately higher. A 1.4 times reduction of the average "nonylphenol potential" concentration is required to comply with the AA-EQS while a reduction factor of 3 is required for the 95 % percentile concentrations.

In stormwater from separate systems an initial dilution factor of about 3 is required for nonylphenol to comply with the MAC-EQS (based on the average concentration of 5.7 μg/L from the screening project, Table 9-1), which mainly in the eastern parts of Denmark is difficult to achieve in the streams in the summer season (at median minimum flow conditions).

The study from which this figure originates covers samples representing a wide range of situations including runoff after long periods of dry weather prior to the rain event sampled. Such conditions are known to result in elevated concentrations of pollutants. The samples were taken during the first 5 mm of rain in each event, which represent about 80-85 % of the rain events in Denmark. In the following, the 5.7 μg/L value will be used in this study as a conservative, but realistic value for nonylphenol in stormwater from separate systems.

Thus, there appears to be some need for further national measures in order to comply with the MAC-EQS value for nonylphenol at summer minimum flow conditions, primarily in the eastern part of Denmark. A proposal for common measures to reduce PS in separate stormwater is presented in Chapter 13.

However, other studies indicate that the average concentrations of nonylphenol in separate stormwater could be lower than the values used in the assessment. As the latter data are from the mid 1990's, after which new regulation of NPE has been implemented, a more in-depth analysis of the issue is recommended before deciding finally on implementation of the measures described in Chapter 13.

Nonylphenol is classified as a priority hazardous substance, which implies that despite the compliance with the EQS the "discharges, emissions and losses" to the aquatic environment in Scenario B must cease/be phased out within 20 years from the date of entry into force of the Directive. In Scenario A/C there is an obligation to consider all technical reduction measures that can lead to this goal, but no timeframe is specified.

9.2 Possible reduction/elimination measures

9.2.1 Technical measures to reduce/eliminate nonylphenol

To eliminate discharges, emissions and losses of nonylphenol to the aquatic environment, nonylphenol for all of the uses discussed above should be investigated to look for further possibilities of substitution.

A Canadian study (based on available foreign data^[17]) indicates that the substitution of NP/NPE is feasible from a technical point of view in most products for consumer, institutional and industrial use /11/. A Danish study has explored the possibilities of substituting nonylphenol ethoxylates in paints, which is still permitted and constitutes one of the largest sources for use of nonylphenol ethoxylates in Denmark /10/. The study identified a number of possible substitutes for nonylphenol in paints such as styrene/maleic anhydride polymer, secondary ethoxylated alcohol (C₁₂-C₁₄) and ethoxylated acetylenic alcohol. All of the alkylphenol ethoxylates (APEOs) investigated could in principle be substituted by alternative substances, but in some cases it would be a time-consuming process /10/.

Thus, it is technically possible to replace nonylphenol ethoxylates in paints etc. It is, however, not clear whether these possibilities are presently so well developed for all uses that they can be termed "best available techniques" and thereby should be included among "all technical reduction measures" that need to be considered in Scenario A. It is assessed that the overall regulation of the use nonylphenol ethoxylates in paints and other products must take place at EU level to become effective.

The primary use of nonylphenol ethoxylates in Denmark is as hardeners in for instance concrete, epoxy and PUR products, which constituted 70 tonnes/year in 2004, according to the Danish Product Registry. No regulation or voluntary agreements are targeted at this use of the substance, and an option could therefore be to consider measures in this respect to reduce emissions/discharges of nonylphenol.

The use of NPE is almost completely phased out in Denmark. The Danish market for paints and lacquers is almost exclusively served by Danish producers and importers that according to voluntary agreements have refrained from using NPE as an additive since the mid 1990's /4/. Imported raw material used in the production is checked for the presence of NPE using the CAS Registry System. If an exporter circumvents the system or incomplete information is available to the importer, NPE may end up in Danish paints and lacquers.^[18] In some cases, economic considerations may also account for less stringent adherence to the voluntary agreement. Together, these two factors probably account for the use of 11 tonnes registered by the Danish Product Register. As REACH will become effective within the next 11 years, importers will get more information about the substances contained in the raw materials they use in their production. This should help eliminate any remaining unintended uses caused by the gaps due to the CAS Registry System, which is complicated regarding NPE.

With regard to cleaning products, uses are also limited due to Statutory Order No. 1006 and a voluntary agreement among Danish producers not to use the substances as an additive. A small number of products are exempted from the statutory order, and not all producers and importers adhere to the voluntary agreement. However, there is not sufficient knowledge available to suggest technical or policy options that may address this aspect.

Stormwater runoff

The estimate made in section 9.1.3 shows stormwater runoff from roads, other paved surfaces and roofs can be considered the presently main source of release of nonylphenol into the aquatic environment. Therefore, technological measures that can reduce this input should be considered though it appears unrealistic to introduce measures specifically aimed at eliminating nonylphenol.

The majority of the PS/PHS including nonylphenol are characterised by properties such as lipophilicity and significant sorption onto particulate (organic) matter. Therefore, it is assessed that technological measures that generally aim at retaining suspended particles in surface runoff will substantially reduce the loads of nonylphenol and many other PS/PHS on the aquatic environment. This option is described and assessed in more detail in Chapter 13.

9.2.2 Possible synergies with other (priority) substances

A possible overall action against suspended matter/pollutants in stormwater runoff will not only lead to a significant reduction in NP/NPE inputs to the aquatic environment but also in most of the other PS/PHS.

9.2.3 Summary and assessment of technical possibilities

Nonylphenol is classified as a priority hazardous substance, PHS, for which Scenario B requires that the discharges, emissions and losses into the aquatic environment must cease within 20 years after the date when the Daughter Directive enters into force.

Considering the already implemented regulations on the use of nonylphenol containing products, the future dominant source type of nonylphenol release into the aquatic environment in Denmark is assessed to be the discharge of stormwater runoff from paved surfaces and roofs.

To meet the requirements to cessation of "discharges, emissions and losses" of nonylphenols within 20 years in Scenario B, action must be taken against the stormwater-mediated releases. The most obvious way of doing this is by introducing detention basins and similar technological arrangements by which particulate matter in the effluent is retained prior to the discharge into fresh or coastal surface waters (see Chapter 13).

With regard to Scenario A, it is assessed, based on the interpretation of the obligations in the WFD, that such measures, due to very high costs, are probably not realistic if aimed exclusively at eliminating nonylphenol.

9.3 Economic Assessment

It was concluded in the technical assessment of available options that there are technical possibilities of replacing nonylphenolethoxylates used as hardeners in for instance concrete, epoxy and PUR products, and in paints and fillers. Voluntary agreements are already in place with regard to paints, but the Product Register still shows a use of 11 tonnes, so there appears to be scope for further substitution. It should be noted that REACH would improve the product data information for Danish producers so that NPE used as an additive in imported raw materials can increasingly be avoided rendering voluntary agreements even more effective.

The overall regulation of the use of nonylphenol ethoxylates in products must take place at EU level to be effective. No national programmes should be implemented unless community action is taken to substitute the remaining uses of nonylphenol ethoxylates.

The technical assessment concluded that the "discharges, emissions and losses" to the aquatic environment must cease/be phased out in Scenario A, but only to the extent that it can be reached by considering all technical options. Further, nationally enforced substitution is therefore not likely in Scenario A as this is not a domestic, technical problem, but rather lends itself to Community-level action. For the purpose of an economic estimation, in Scenario B it is assumed that substitution is enforced in Denmark in order to meet the 2025 deadline of the Daughter Directive.

What would be the cost if all remaining uses of nonylphenol, which are not already banned in Denmark, must be substituted? The alternatives to nonylphenol are more expensive to use, but the above-mentioned studies indicate that the substitution of NP/NPE is feasible from a technical point of view in most products. The current use of NP/NPE in hardeners, paints, lacquers, and filling products was estimated to be 90 tonnes a year.^[19]

If we assume that the use is constant over the next 30 years, this is considered the status quo assumption. In Scenario A, no Danish programme of substitution will be initiated because such a measure will only be effective if implemented by common action at Community level. Therefore, there is no cost associated with this scenario. In Scenario B it could be deemed necessary to initiate and finance a national programme of phasing-out NP/NPE as a hazardous substance in accordance with the 20-year deadline.

The two scenarios' deadlines are illustrated in the figure below.

Figure 9-1 National Phase-out of total use of NP/NPE in products

By far the most common replacements for NPE are alcohol ethoxylates. The cost of the alternatives fluctuates with the price of raw materials e.g. the cost of ethoxylates fluctuates with the price of ethylene. In the Canadian report it is stated that in recent years, the prices of alternatives to NPE have been, on average, around 20-40 % higher than NPE /11/. This is the main conclusion of the report, and the fact that no actual total cost has been calculated is a clear indication of the uncertainty regarding the prices. However, if the prices from the study on NP/NPE and the alternative substances are used, the extra financial cost per tonne of the latter is roughly 2-4 DKK/kg. The lower and higher values are both used in the following estimation.

*             If a discount rate of 6% is used the result are: Scenario B = 1.4 to 2.5

The table illustrates the very uncertain estimate of the cost of gradually substituting the 90 tonnes of NP/NPE a year. Both a minimum and a maximum value are shown. The values are given in net present value (NPV) which is an expression of the discounted value today of future investments. The discount rate used is 3 % in the welfare economic calculation and 6 % in the financial cost estimation. There is no cost associated with Scenario A as there will be no national programme and no phase-out measures aimed exclusively at NP (stormwater in general, see Chapter 13). Scenario B is estimated to cost industry and consumers between DKK 1 and 2 million in total financial cost. This represents the extra cost of implementing the Daughter Directive. In welfare-economic terms, the cost is estimated to between DKK 2.5 and 4.3 million.

It should also be noted that total substitution might imply that some uses of the substance in question will probably have a unit cost considerable higher than the average viewpoint of this kind of calculation. As a rule of thumb, the marginal cost of substance substitution in many uses gets higher and higher the closer to 100 % substitution we wish to go. However, for NP/NPE there, seem to be alternatives readily available for all or most uses, which will tend to keep the cost of substitution down.

The policy instruments available to implement substance substitution are discussed in the general concluding economic chapter of the report.

In this case there are no data available that document the proportion of the substance used in products produced for the home market and in imported goods respectively. The cost of the substitution will be borne by the manufacturing sector, but given the data available it is impossible to assess the share of costs to be borne specifically by the Danish manufacturing industry. Finally, the proportion of the cost that will be passed on to consumers or to downstream manufactures using the products as input factors is not known. Since the 90 tonnes a year cover the total Danish consumption of NP/NPE in various products, it can, however, be assumed that the majority of the cost will accrue nationally.

On a final note, it should be repeated that in order to assess this cost in more detail, a more thorough analysis and data gathering for specific product types should be made.

9.4 Conclusion on Nonylphenol

The concentrations of nonylphenol in treated sewage effluent are so low (95% percentile level) that they need to be reduced by only a factor 2 to comply with the AA-EQS. This will be possible in almost all cases under normal circumstances. However, in stormwater from separate systems an initial dilution factor of almost 3 is required to comply with the MAC-EQS (based on the data from the screening project presented in Table 9-1), which mainly in the eastern part of Denmark is difficult to achieve in the streams in the summer season (at median minimum flow conditions).

Thus, there appears to be some need for further national measures in order to comply with the MAC-EQS value for nonylphenol at summer minimum flow conditions, primarily in the eastern part of Denmark, see proposal for a common measure to reduce PS in separate stormwater in Chapter 13.

However, other studies indicate that the average concentrations of nonylphenol in separate stormwater could be lower than the values used in the assessment. As the latter are from the mid 1990's, after which new regulation of NPE has been implemented, a more in-depth analysis of the issue is recommended before deciding finally on implementation of the measures described in Chapter 13.

Further, in Scenario B it is an obligation to continue the progressive reduction beyond the EQS compliance level. To fulfil this requirement it will probably be necessary to introduce additional measures such as substitution for some of the uses that are not banned already.

Nonylphenol ethoxylates are still being used in a number of products in Denmark, mainly for industrial/professional uses, but it appears that there are alternatives to all applications. If the total consumption of NP/NPE in various products of 90 tonnes per year is to be substituted, it will impose a cost on the Danish manufacturing sector and consumers. In order to assess this cost in detail, a number of detailed cost-benefit comparisons for specific product types should be made in order to consider the relative cost of relevant substitutions.

A Canadian study have estimated the price of the alternative substances are 20-40 % higher than NP/NPE, but with some variation. Using these figures as a basis, it can be calculated that the financial cost of implementing the proposed Daughter Directive in Scenario B could be approximately 1 to 2 million DKK in financial terms higher than implementing the WFD without an agreement on a Daughter Directive in Scenario A. The extra cost associated with Scenario B in welfare-economic terms is 2.3 to 1.4 million DKK. It is assessed that there will be no additional cost associated with Scenario A in this calculation as a national programme of substitution is not considered a "technical option", but rather a matter of community regulation. The costs estimated here are those associated with Scenario B, where it is assumed that national action towards substitution must be taken and phase-out achieved by 2025, though community regulation is recommended.

Nonylphenol is classified as a priority hazardous substance, which implies that despite compliance with the EQS "discharges, emissions and losses" to the aquatic environment must eventually cease/be phased out. In Scenario A, Denmark is only obliged to pursue the aim to the extent it can be achieved by considering "all technical options" and without a fixed time frame. In Scenario B the cessation/phase-out must be achieved within 20 years from the date of entry into force of the Directive. The gradual implementation of the proposed technical measures aimed at ceasing/phasing out nonylphenol emissions and discharges is considered also to cover the progressive reduction obligation in Scenario B.

To meet the requirements to cease nonylphenol releases in Scenario B, action must, however, be taken against the stormwater-mediated releases. The most obvious way of doing this is by introducing detention basins and similar technological arrangements by which particulate matter in the effluent is retained prior to the discharge into fresh or coastal surface waters (see Chapter 13).

9.5 References

/1/ Bekendtgørelse nr. 1006 af 12/10/2004: Import, salg og anvendelse samt mærkning af nonylphenol, nonylphenolethoxylat eller cement.

/2/ Anvendelse og udbredelse af østrogenlignende stoffer. Virkning på mennesker og miljø. Bodil M. Jacobsen, Dansk Toksikologi Center og Torben Madsen, VKI. Økonomisk støttet af Dansk Planteværn. Februar 1998.

/3/ Kjølholt J, Winther Ringgaard K, Skårup S (2006). Kilder og miljøtilstand for prioriterede stoffer under Vandrammedirektivet. Miljøprojekt nr. XXXX (in press). Danish Environmental Protection Agency.

/4/ Personal communication with the Danish "Brancheforening for Farve- og Lakindustrien". October 2005

/5/ Personal communication with the Association of Danish Cosmetics, Toiletries, Soap and Detergent Industries, SPT. October 2005

/6/ Spildevandsslam fra kommunale og private renseanlæg i 2000 og 2001. Orientering fra Miljøstyrelsen nr. 9 2003.

/7/ Miljøstyrelsen (2005). Punktkilder 2004. Orientering nr. 9 fra MST.

/8/ Miljøstyrelsen (2006). Målinger af forureningsindhold i regnbetingede udledninger. Arbejdsrapport fra Miljøstyrelsen Nr. 10, 2006.

/9/ Mapping of chemicals in dry-cleaned textiles from Rynex and hydrocarbon dry-cleaning shops. Survey of chemicals in consumer products. Survey no. 21, 2003. Dorte Glensvig, COWI A/S and Peter Mortensen, Eurofins Danmark A/S for DEPA

/10/       Substitution af alkylphenolethoxylater (APEO). Arbejdsrapport fra Miljøstyrelsen nr. 45 2003

/11/       Report on Alternatives to Nonylphenol Ethoxylates Review of Toxicity, Biodegradation, & Technical-Economic Aspects. Final Report - March 2002. Environment Canada.

/12/       Nonylphenol og nonylphenolethoxylater i spildevand og slam. Miljøprojekt nr. 704, 2002.

/13/       DMU (2003). Vandmiljø 2003. Bilag 12 (4.3). Faglig rapport fra DMU, nr. 471, 2003.

/14/       Århus Amt (2001). Miljøfremmede stoffer i Århus Amt 1998-2001. Teknisk Rapport, Århus Amt - Natur og miljø. Nov. 2001.

Footnotes

^[17] Based on the examples of phase-out from household and I&I cleaning products in the European Union (EU), and other substitution initiatives.

^[18] Cas no.: 25154-52-3 is on the list of hazardous substances but cas. no. 90481-04-2 is not.

^[19] 70 tonnes plus 11 tonnes plus 9 tonnes.

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