Are The Times A Changin’? Roots and Shoots
In The Regulation of PCP’s
Jane Maslow Cohen
University of Texas School of Law
This paper will trace, analyze, and robustly applaud one, but only one, of
two very recent developments in the regulation of personal care products
(PCP’s) in the United States—two shoots—against a quad of background
conditions—four roots. The shoots are (1) the single-target microbead bans
first enacted in some bellwether states and in a subsequent federal
prohibition, effective this year; and (2) the efforts in Congress to pass the
narrowly-drawn Personal Care Products Safety Act. The roots are: (1) the
science-driven campaign to arouse consumer hostility toward microbeads
and to steer the campaign into legislative forums; (2) the market-driven
campaign to intensify consumer distrust of chemical pollutants; (3)
lobbyist push-back within the PCP industry; and (4) taproot federal
legislation, the 1976 Toxic Substances Control Act, practice norms under it,
and its recent revisions. Food for critical thought, but not treated as a U.S.
root or shoot, is E.U. PCP regulation, its structure and content.
The purpose of this project is to explore these yet-oncoming
developments within the U.S. regulatory environment, motivated as they are
by advances in scientific understandings that are making the harmful
effects of PCP’s on water sources as well as species-welfare increasingly
available to be understood. To implement this purpose, I will highlight the
relevant science. My further purpose is to hold up each type of
development—the highly-targeted (microbeads); the slow and narrow (The
PCP Safety Act); the woefully outdated (TSCA, even as revised); and (E.U.-
style) command-and-control--as a model of regulatory
behavior and to compare them according to process and outcome metrics I
will describe. My thesis—still subject to revision—is that only the single-
target anti-microbeads approach has satisfied its own strong ambitions so
as to deserve unqualified applause, whereas the other U.S. approaches are
too slow and compromised to effectuate critically-needed regulatory change.
But the single-target approach is unsuitable for an environment that is
polluted to the extent that U.S. water sources are. Therefore, with a
practical, if skeptical eye, we need to extract the best practices to be derived
from every approach within the skein (I’ll offer a few) and continue the hunt
for innovative institutional reform. (I may have a couple to suggest).
My methods of choice will lay importance on comparative legal and
institutional analysis within a familiar policy frame and the clear exposition
of published scientific research in lay-persons’ terms.
Endocrine disrupting compounds are of significant interest because of their catastrophic effects in ecosystem and human health. When they enter to body of a living being, they mimic the hormones or interfere with the endocrine system and cause severe health problems. These chemicals are mostly of synthetic origin. Moreover, most of them are very persistent in the environment and exist for many years after the emission. There are many scientific studies proving the adverse effects of endocrine disrupting compounds on both environment and human health and water is one of the most important route of exposure of endocrine disrupting compounds. Therefore, control of endocrine disrupting compounds in water resources is an urgent policy issue.
In Turkey, several endocrine disrupting compounds were listed in national legislation under specific pollutants and priority substances and their environmental quality standards were set. In addition to these, a project has been initiated in cooperation of universities and Ministry of Forestry and Water Affairs to develop a management perspective for endocrine disrupting compounds in water resources. Ministry of Health, Ministry of Environment and Urbanization, Ministry of Food, Agriculture and Livestock, industrial organizations and several research institutes were also supported the project.
In scope of the project, complete list of endocrine disrupting compounds which exist in water resources was prepared. For this purpose, literature and endocrine disrupting compounds identified by international organizations and other countries were reviewed and an inventory of chemicals used in industrial facilities and agricultural activities was taken. The listed chemicals were assessed according to their potential to exist in wastewater and environmental fate. Then, environmental quality standards were derived for these pollutants. Moreover, monitoring studies were conducted to detect the levels of these pollutants in both receiving water bodies and wastewater discharges.
In addition to these, the fate of these chemicals in the water environment was researched and removal of selected endocrine disrupting compounds via biological or advanced wastewater treatment technologies were investigated in lab scale systems.
As a result of this study, a roadmap and a perspective were developed for Turkey to manage the endocrine disrupting pollutants in water resources. The outputs of the study are planned to be integrated to the national legislation and necessary measures will be implemented by related institutions and organizations. With these features, the study exhibits a good example of harmonization of scientific efforts and policy making procedure. It also ensures the implementation of measures by involving all the stakeholders from the beginning of the process.
Mathematical Modelling of Uncertainty and Pharmaceutical Drug Processing in Wastewater Treatment
E. Acheampong1,2,3, I. Dryden1, J. Wattis1, J. Twycross4 and R. L. Gomes2
1School of Mathematical Sciences, University of Nottingham, University Park, Nottingham NG7 2RD, UK
2Bioprocess, Environmental & Chemical Technologies Research Group, Faculty of Engineering, University of Nottingham, University Park, Nottingham NG7 2RD, UK
3Department of Mathematical Sciences, Methodist University College Ghana, Box DC 940, Dansoman-Accra
4School of Computer Science, University of Nottingham, Jubilee Campus, Nottingham, NG8 1BB, UK
Email: Edward.Acheampong@nottingham.ac.uk / email@example.com
The Benchmark Simulation Model No. 1 (BSM1) is widely used to model family of Activated Sludge Models. It consists of a predefined plant layout, process models, sensor and actuator models, influent characteristics and evaluation criteria. The Activated Sludge Model No. 1 (ASM1) is commonly used within the BSM1 to model the activated sludge process (ASP). In the real-world, the ASP suffers from variabilities arising from process operational parameters, environmental factors, input loadings and model input parameters. These variabilities have both temporal and spatial effects on the ASP leading to uncertainties in the removal of pharmaceutically active compounds from wastewater. Consequently, there are strong Governmental drivers and evolving legislation that protect the aquatic environment. The aim being to promote water resilience which falls under the umbrella of building a sustainable society. Mathematical modelling and computer simulations are valuable tools in improving the current treatments technologies and developing new ones to remediate pharmaceutically active compounds since they will help to reduce the experimental workload in defining the system and the uncertainties surrounding it.
In the research presented here, we investigate how variability in the ASM1 model impacts behaviour of the BSM1 model. We perform a parameter sensitivity analysis of the existing ASM1, revealing that nitrite and nitrate nitrogen, and free and ionized ammonia, are the most sensitive state variables, and are sensitive to a large number of rate parameters. The implication is that changes in kinetic rates (e.g., yield for heterotrophic biomass and ammonification rate) can significantly impact these concentration variables. No sensitivities are greater than 10, indicating that the ASM1 is a relatively robust model. We then consider the effects of concentration perturbations of other concentrations by adding stochastic terms to the ASM1. Again, we find that nitrite and nitrate nitrogen and ammonia exhibit the largest fluctuations when the ASM1 is close to steady-state. In addition, the stochastic model shows large fluctuations in heterotrophic and autotrophic biomass, particulate inert organic matter, particulate product from biomass decay and alkalinity. We also report preliminary results of extensions to ASM1 which describe the removal of various pharmaceutically active compounds. From the wide range of pharmaceutically active compounds and conjugates, we select a few to mathematically model in detail. This is the first stage in the construction of a generalized ASM predicting and optimizing the removal efficiency of pharmaceutically active compounds.
Keywords: ASM1, ASP, BSM1, Conjugates, Evolving legislation, Governmental drivers, Pharmaceutically active compounds, Mathematical modelling and computer simulations, Sustainable society, Wastewater treatment, Water resilience
Emissions of pesticides from agricultural fields are threatening water quality of aquatic systems in large parts of the world. After their application, pesticides are to some extent retained and degraded in the environment, depending on the specific compound properties and application they are used for. However, a share is often incompletely mineralized resulting in transformation products (TPs). TPs are generated by biological and chemical processes in the environment and water treatment. The important parameters governing their properties, behavior and toxicity are often unknown. In contrast to the parent compounds (PCs), fate and effects of the single TPs as well as in mixture with PCs is poorly investigated. Even small fractions can be harmful to aquatic organisms, by long-term exposure at low concentrations and/or acute exposure at high peak concentrations, e.g. after a heavy rain event. The generation and presence of such TPs have increasingly gained interest in the aquatic cycle (incl. drinking water) only recently.
The research issue was to analyze the behavior of TP’s compared to its PC. Therefore, mecoprop (methylchlorophenoxypropionic acid) was chosen due to its widespread application in agricultural as well as in urban areas. Photolysis of mecoprop was simulated by exposure to a xenon arc lamp which represents the solar radiation. The biological breakdown was analyzed for both PC and photolytic TP-mixture (8 hour irradiation). The primary elimination of the pesticides was measured by HPLC-DAD/UV-Vis. The structural identification of transformation products was performed with LC-MS (Esquire Iontrap). Furthermore, the acute and chronic toxicity of both was investigated.
Mecoprop was degraded rapidly by exposure to a xenon arc lamp with a half-life of 0.6 hours. Five transformation products were detected. They were of higher polarity than the PC. Most TP’s were not eliminated during the photolytic treatment, which implies that they are persistent to photolytic transformation. In most cases a dehalogenation and hydroxylation of aromatic carbons of mecoprop took place. The potential of biological degradation of the total photolytic mixture compared to the initial substance increases by 30 percent. Likewise, there is an increase in acute and chronic toxicity to of the photolytic mixture by 20 percent.
The findings point out that the properties of mecoprop-TPs differ from the PC. Accordingly, these TPs have a changed behavior in the aquatic environment such as sorptivity and solubility and therefore to its temporal and spatial distribution in agricultural and urban catchments. This research demonstrates that new insights on the fate and behavior of TPs in aquatic environments are necessary for the development of water pollution control measures addressing the aims of SDG 6.3.