Emerging compounds are much like illicit drugs – manufacturers are continually creating new “designer” versions to make our lives a little better and to get an advantage on the competition while enforcement agencies struggle to keep up with the proliferation of new products. Some manufacturers are focused on creating new compounds that are within the law and some manufacturers are committed to staying one step ahead of the law. The time it takes to identify, evaluate, and regulate new compounds is much longer than the time it takes to create new ones.
Emerging contaminants, more properly called “contaminants of emerging concern,” can refer to many different kinds of chemicals, including medicines and everyday products related to personal care, household cleaning, and lawn care and agricultural products. Chemicals in these products and their byproducts have a detrimental effect on fish and other aquatic species in our surface waters. The impact on humans is not well known because of the growing list of tens of thousands of these compounds, the time it takes to do technical evaluations and risk analysis, and the limited research that funded to examine these compounds at lower detection levels – both for the individual contaminants and the contaminants as they co-exist in surface water.
Contaminates of emerging concern is the more proper name because some old compounds are now of merging concern. Laboratories can now detect them at lower levels – parts per trillion (ppt) now versus parts per million (ppm) or parts per billion (ppb) on a decade ago. Communities who for generations thought they were drinking clean water now wonder whether the water is safe to drink.
1,4-dioxane is an example of an old compound with an emerging concern. According to USEPA, 1,4-dioxane is used as a solvent in a variety of commercial and industrial applications such as in the manufacture of other chemicals, a processing aid, functional fluid, a laboratory chemical, in adhesives and sealants, in spray polyurethane foam, in printing inks, and as a dry film lubricant. 1,4-dioxane may be found as a contaminant in consumer products such as soaps and detergents. Information from the 2016 Chemical Data Reporting (CDR) for 1,4-dioxane indicates reported production volume in more than 1.1 million pounds per year (manufacture and import).
1,4-Dioxane has been the subject of numerous human health reviews including EPA's Integrated Risk Information System (IRIS) Toxicological Review, Agency for Toxic Substances and Disease Registry's (ATSDR's) Toxicological Profile, Health Canada Screening Assessment, and Interim Acute Exposure Guideline Levels (AEGL). Many targets of toxicity from exposures to 1,4-dioxane have been identified in animal and human studies for both oral and inhalation exposures. EPA plans to evaluate all potential hazards for 1,4-dioxane, including any found in recent literature. Hazard endpoints identified in previous assessments include acute toxicity, non-cancer effects, and cancer. Non-cancer effects include irritation of the eyes and respiratory tract, liver toxicity, and kidney toxicity. Animals exposed to 1,4-dioxane by inhalation and oral exposure have also developed multiple types of cancer.
USEPA also completed a final risk evaluation for 1,4-dioxane under the Toxic Substances Control Act (TSCA). In the final risk evaluation, USEPA reviewed twenty-four conditions of use, primarily as a solvent, a processing aid, functional fluid, laboratory chemical, adhesive, sealant, spray polyurethane foam, printing, and dry film lubricant. USEPA concluded that 1,4-dioxane will “not likely to present an unreasonable risk” cases,” and thus producers may commence manufacture upon completion of applications and notification by USEPA.
To simplify, 1,4 dioxane is acceptable to produce and use if it is handled and disposed of properly. Historically we have not been concerned about human ingestion enough to be on the list of drinking water contaminants but we are re-thinking it. There are costs in our communities of not protecting public health and there are costs associated with over-regulation. And so it goes for a growing list of thousands of contaminants of emerging concern.
What does this mean for new projects or renewing existing facilities? First, where emerging contaminants exist, it is a significant drain on resources. That does not always result in higher rates because state and federal governments usually help with the most severe problems. Second, all communities will experience an issue with contaminants of emerging concern, either now or in the near future. Third, contaminants of emerging concern need to be factored into decision making for capital projects. The associated issues with contaminants of emerging concern will continue to increase.
JD Solomon Inc provides services at the nexus of the built and natural environment. Contact us for more information related to project development, business case analysis, third-party reviews, and stakeholder facilitation.
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