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Nonylphenol (NP) and Nonylphenol Ethoxylates (NPEs) 

Action Plan

I. Overview

 Nonylphenol (NP) and nonylphenol ethoxylates (NPEs) are produced in large volumes, with 

uses that lead to widespread release to the aquatic environment. NP is persistent in the aquatic 

environment, moderately bioaccumulative, and extremely toxic to aquatic organisms. NP’s main use is 

in the manufacture of NPEs. NPEs are nonionic surfactants that are used in a wide variety of industrial 

applications and consumer products. NPEs, though less toxic than NP, are also highly toxic to aquatic 

organisms, and in the environment degrade to more environmentally persistent NP. NP has also been 

detected in human breast milk, blood, and urine and is associated with reproductive and developmental 

effects in rodents. 

 NPEs were once commonly used in household laundry detergents. EPA and the detergent 

manufacturers have cooperated to eliminate this use. However, NPEs are still widely used in large 

quantities in industrial laundry detergents and have some additional uses that lead to releases to water. 

Therefore, EPA intends to initiate action to address its concerns about potential ecological effects due 

to the manufacturing, processing, distribution in commerce, and uses of NP and NPEs. Additionally, 

based on available exposure and health effects information, EPA continues to have some concern 

about potential risk to human health. EPA anticipates that the actions put forward in this Action Plan 

will further reduce human exposure thereby reducing risk concerns associated with NP and NPEs. 

II. Introduction 

 As part of EPA’s efforts to enhance the existing chemicals program under the Toxic Substances 

Control Act (TSCA; 15 U.S.C. §2601 et seq.), the Agency intends to identify chemicals for Action Plan 

development based on their presence in humans; persistent, bioaccumulative, and toxic (PBT)

characteristics; use in consumer products; production volume; or other similar factors. NP and certain 

oligomeric NPEs are highly toxic to aquatic organisms, are moderately bioaccumulative in mollusks, 

are persistent in the aquatic environment, and accumulate in soils and sediments (EPA, 2005). This 

Action Plan is based on EPA’s initial review of readily available use, exposure, and hazard information 

on NP and NPEs. In developing the Action Plan, EPA considered which of the various authorities 

provided under TSCA and other statutes might be appropriate to address potential concerns regarding 

NP and NPEs. The Action Plan is intended to describe the courses of action the Agency intends to 

pursue in the near term to address its concerns. It does not constitute a final Agency determination or 

other final Agency action. Regulatory proceedings indicated by the Action Plan will include 

appropriate opportunities for public and stakeholder input, including through notice-and-comment 

rulemaking processes. 
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III. Scope of Review

 This Action Plan addresses uses of nonylphenols and nonylphenol ethoxylates that fall into the 

general chemical categories of alkylphenols and alkylphenol ethoxylates (APEs), respectively. 

 Chemical Abstract Service registry names and numbers (CASRNs) routinely used to refer to 

nonylphenols or nonylphenol ethoxylates may not accurately reflect the identity of those substances. 

The nine carbon nonyl group may be branched or linear and bind at various locations around the 

phenol ring (“ortho”, “meta” or “para”). Many manufacturers incorrectly use the linear identity when 

referring to the branched nonylphenol. CASRN 84852-15-3 corresponds to the most widely produced 

nonylphenol, branched 4-nonylphenol (referred to herein as NP). Note that NP is not a single chemical 

structure. It is a complex mixture of highly branched nonylphenols, largely mono-substituted in the 

para- position, but with small amounts of ortho- and di-substituted nonylphenols. In addition it 

includes small amounts of branched C8 and C10 alkyl groups (Seidel 2004a). Much of the literature 

refers to the linear (or normal-) nonylphenol (CASRN 25152-52-3), often the specific pararegioisomer (i.e. 4-n-nonylphenol, CASRN 104-40-5). Many, but not all, references are inaccurate 

about the identity of the substances listed as nonylphenol. This is likely due to inaccurate identities in 

the source material. A supplier of nonylphenol may use CASRN 104-40-5, signifying 4-nnonylphenol, while actually supplying branched 4-nonylphenol (CASRN 84852-15-3). 

 The mono- and di-ethoxy NPEs (NP1EO, NP2EO) do not appear on the TSCA inventory, but 

are among the degradation products of the polymeric NPEs and may be present with NP in the 

environment in appreciable concentrations. 

 

Production

Nonylphenol 

 U.S. demand for NP (which includes both production and imports less exports) is estimated to 

be 380 million pounds in 2010 (ICIS, 2007). This is well within the range for the reported production 

volume (manufactured volume plus imports) reported under the TSCA Inventory Update Rule (IUR) in 

2006, which ranged from approximately 100 to 500 million pounds, based on reporting for the most 

widely produced branched and linear nonylphenol substances (i.e., CASRN 84852-15-3 and CASRN 

25154-52-3, respectively). 

Nonylphenol ethoxylates 

 NPEs are surface active agents (surfactants) that are part of the broader category of surfactants 

known as alkyphenol ethoxylates (APEs). NPEs represent approximately 80% to 85% of the volume of 

APEs. Surfactants are generally categorized based upon their electric charge in water. Categories of 

surfactants include anionic (negative), nonionic (no charge), cationic (positive), and amphoteric 

(positive and negative). NPEs are part of the nonionic category. 
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 U.S. demand for all surfactants in 2007 was 7.5 billion pounds (Rust and Wildes, 2008). U.S. 

and Canadian consumption of NPE surfactants has been estimated between 300 and 400 million 

pounds per year (EPA, 2008). In a study by ToxEcology in 2002, NPE surfactant consumption in 

Canada was estimated at approximately 29 million pounds. It is not clear if this estimate includes soap, 

so it may be an underestimate of total surfactant consumption by Canada. However, if Canadian 

consumption of NPEs is approximately 29 million pounds, then U.S. consumption of NPEs would 

range from approximately 270 to 370 million pounds. 

IV. Uses and Substitutes Summary

 The primary use of NP is as an intermediate in the manufacture of NPEs. NPEs are 

manufactured by reacting NP with ethylene oxide (EO) under basic conditions. The degree of 

ethoxylation depends on the molar ratio of NP to EO. All degrees of ethoxylation may be 

manufactured under the CASRN for the poly-ethoxylates (formally poly(oxy-1,2-ethanediyl), -(4-

nonylphenyl)--hydroxy-, branched, CASRN 127087-87-0), as long as they are synthesized via 

polymerization reaction between NP and EO. 

 NP may also be reacted to form tris(4-nonyl-phenyl) phosphite (TNPP, CASRN 26523-78-4) 

an antioxidant used to protect polymers such as rubber, vinyl, polyolefins, and polystyrenics (Seidel 

2004a). TNPP is also used as a stabilizer in plastic food packaging. Although it does contain residual 

NP, TNPP has been approved for this use by the Food and Drug Administration (FDA). FDA also lists 

NP as an indirect food contact substance (Vazquez-Duhalt, et al., 2005). Barium and calcium salts of 

NP are used as heat stabilizers for poly vinyl chloride (PVC) (Seidel 2004a). NP is also used as a 

catalytic diluent in epoxy resins (Seidel 2004a). 

 

 Non-ionic surfactants, including NPEs, are used in a wide variety of applications including 

detergents, cleaners, degreasers, dry cleaning aids, petroleum dispersants, emulsifiers, wetting agents, 

adhesives, agrochemicals, paper and textile processing formulations, prewash spotters, metalworking 

fluids, oilfield chemicals, paints and coatings, and dust control agents. NPEs are hydrophilic (“waterattracting”) at one end of the molecule and hydrophobic (“water-avoiding”) at the opposite end. The 

hydrophilic “head” attracts water and the hydrophobic “tail” attracts poorly soluble substances, such as 

oils and greases. This ability to simultaneously attract water and hydrophobic substances makes NPEs 

useful in the surfactant applications listed above, accounting for nearly 80% of consumption. 

Additional uses include: 1) phosphate antioxidants for rubber and plastics; and 2) miscellaneous uses, 

including lube oil additives. These uses each account for another 10% of total consumption (ICIS, 

2007). 

Alternatives to NPEs

 There is enormous variability in the structure of non-ionic surfactants. Most non-ionic 

surfactants rely on polyethoxylation to provide the hydrophilic moiety. Others rely on glycerol 

(glycerin), glucosides, or other sugars, either as monosaccharides (e.g. sorbitol) or disaccharides (e.g. 
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sucrose) (Seidel 2004c). The simplest substitution for NPEs is to use other APEs. NPEs are just one of 

many APEs available commercially, and other APEs are used for many of the same commercial 

purposes as emulsifiers, dispersants, and surfactants. The main alternatives for NPEs also include 

alcohol ethoxylates, both linear and branched, and glucose-based carbohydrate derivatives such as 

alkylpolyglucoside, glucamides, and glucamine oxides. Some surfactants may substitute for specific 

applications only, for instance, silicon surfactants are used in production of polyurethane foam while 

napthalene condensates are used in photofinishing solutions. In other cases, NPE can be replaced with 

a surfactant blend of alternative nonionics or a blend that include anionic or amphoteric surfactants. 

Market acceptance of these alternatives depends on a number of factors including cost and 

performance in the intended use. Many of these alternatives are less persistent and break down to 

chemicals which are less toxic than NP and may be deemed safer substitutes for NPEs by EPA (EPA 

2010). 

V. Hazard Identification Summary

 The Office of Pollution Prevention and Toxics (OPPT) assessed the human health and 

environmental effects hazards of NP, specifically CASRN 84852-15-3, which is branched, parasubstituted NP, as part of its Hazard Characterization (HC) of 18 alklyphenols 

(http://www.epa.gov/chemrtk/hpvis/hazchar/Category_Alkylphenols_Sept2009.pdf). This CASRN is 

one of two nonylphenol CASRNs included in this Action Plan. The other CASRN, 25154-52-3, is for 

straight chain nonylphenol. Since very little straight chain nonylphenol is produced, OPPT’s HC 

coverage of CASRN 84852-15-3 (and not of CASRN 25154-52-3) is used here. OPPT has evaluated 

the metabolism of NPEs in mammals [placeholder for future link] and has concluded that they are 

metabolized to NP. 

Human Health Effects 

 

 NP’s acute (oral and dermal) toxicity is low. NP is highly irritating and corrosive to the skin 

and eye, but does not have significant skin sensitizing potential. NOAELs (No Observed Adverse 

Effect Levels) and LOAELs (Lowest Observed Adverse Effect Levels) for systemic toxicity (based on 

body weight or body weight gain) in repeat dose rat oral toxicity studies range from 13 to 100 mg/kgbw/day and from 43 to 400 mg/kg-bw/day, respectively. NOAELs and LOAELs in rat for reproductive 

toxicity (based on decreases in epididymal sperm density or testicular sperm head counts, increases in 

estrous cycle length, and decreases in ovarian weights) range from 13 to19 mg/kg-bw/day, and from 43 

to 64 mg/kg-bw/day, respectively. Developmental rat NOAELs and LOAELs for offspring (based on 

accelerated vaginal opening in pups) range approximately from 13 to 19 mg/kg-bw/day and from 43 to 

64 mg/kg-bw/day, respectively. Developmental NOAELs and LOAELs for rat maternal toxicity (based 

on decreased terminal body weights) range from 13 to 19 mg/kg-bw/day and from 43 to 64 mg/kgbw/day, respectively. NP is not mutagenic in the Ames assay, in vitro chromosomal aberration assay, 

or in vivo micronucleus assay. There are no data on its carcinogenic potential. 
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Environmental Effects 

Aquatic Toxicity: 

 The available acute and chronic toxicity data of NP to aquatic organisms indicates NP is highly 

toxic to fish, aquatic invertebrates, and aquatic plants. The 28-day no observed effect concentration 

(NOEC) of CASRN 84852-15-3 for fish ranges from 0.05 to 0.07 mg/L and the 28-day lowest 

observed effect concentration (LOEC) ranges from 0.12 to 0.19 mg/L. A 33-day NOEC for fish is 

0.007 mg/L and the 33-day LOEC is 0.014 mg/L. The 21-day NOEC for aquatic invertebrates ranges 

from 0.10 to 0.24 mg/L (EU, 2002; Canada, 2002; EPA, 2005). 

 For NPEs, toxicity to aquatic organisms tends to decrease with increasing degree of 

ethoxylation. For example, acute toxicity to killifish was 1.4 mg/L, 3 mg/L, 5.4 mg/L, 12 mg/L and 

110 mg/L for NP, NP1EO (i.e., NPE with one ethoxylate group), NP6.4EO (i.e., NPE mixture with an 

average of 6.4 ethoxylate groups), NP9EO and NP16.6EO, respectively (Canada, 2002). Environment 

Canada, based on a comprehensive analysis of available toxicity data for NP and NPEs, developed 

Toxic Equivalency Factors (TEFs) for NP and NPEs, as follows: NP =1; NP1EO and NP2EO =0.5 

(i.e., half as toxic as NP); NP3EO to NP8EO also = 0.5 (a conservative estimate because of inadequate 

data); NP9EO and greater = 0.005 (i.e., 100 times less toxic than NP) (Canada 2002). 

Bioconcentration Factor (BCF) 

The measured BCF for fish is low, ranging from 87 to 344. However, the BCF for mussel ranges from 

14 (low) to 3,400 (moderate) (EPA, 1996). 

VI. Physical-Chemical Properties and Fate Characterization Summary

 NP is a clear to pale yellow viscous liquid at room temperature with moderate water solubility 

and moderate vapor pressure (Ahel and Geiger, 1993; EU, 2002; Seidel, 2004b). NP has moderate 

volatility, and, while air concentrations of NP are generally expected to be low (EU, 2002), research 

has shown that in some locations there may be water-to-air volatilization that results in significant 

atmospheric concentrations of NP substances (Canada, 2002). In the atmosphere, NP will be degraded 

rapidly by hydroxyl radicals and is not expected to be persistent in air (rated a P1, low) (EPA, 2009). 

NP is primarily found in the environment as a degradation product of NPEs. NPEs are released most 

often to sewage treatment plants, and are degraded to shorter-chain NPEs, including NP1EO and 

NP2EO in active sewage sludge; these short-chain NPEs are then further degraded to NP (EPA, 2005). 

NP is expected to adsorb strongly to soils and sediments. In sewage treatment plants, NP is expected to 

partition to sludge, and when released to the aquatic environment, is expected to partition mainly 

between water and sediment (EPA, 2005; Canada, 2002). NP and NPEs that are present in surface 

waters or landfills may also potentially leach into groundwater (Canada, 2002). NP undergoes 

biodegradation, but not readily, and is considered persistent in the aquatic environment (Canada, 

2002). 
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 NPEs show a gradual, linear increase in water solubility with greater degree of ethoxylation 

(for example the reported water solubility of NP5EO is 9.48 mg/L; of NP12EO, 42.5 mg/L) (Ahel and 

Giger 1993; Brix et al. 2001). There are conflicting reports in the literature on the biodegradability of 

NP and NPEs. They are not readily biodegradable using standard tests, but are inherently 

biodegradable (Canada, 2002; EU, 2002). After a period of acclimation, NPEs, in sewage sludge or the 

natural environment, can undergo biodegradation to shorter-chain NPEs involving stepwise loss of 

ethoxy groups to lower NPE congeners (Maguire, 1999). In the environment the long-chain NPEs 

biodegrade relatively quickly to short-chain NPEs and NP, which are much more resistant to further 

degradation (Canada, 2002; EU, 2002). When in water, NPEs can also undergo photo-induced 

degradation (Canada, 2002), and NP can also be photolyzed in the surface layer of natural waters with 

a half-life of 10-15 hours (Canada, 2002). 

VII. Exposure Characterization Summary

Releases 

 NPs and NPEs are not listed in the Toxic Release Inventory (TRI). No readily available, 

quantitative release data in the U.S. were found for NPs and NPEs. Based on information from the 

European Union (EU) and Canada (EU, 2002 and Environment Canada, 1999), there are 

environmental releases of NPs and NPEs to water during their manufacture and uses including: 

Release of NP 

 during production of NPEs 

 during production of nonylphenol/formaldehyde 

 during production of epoxy resins 

 during production of plastic 

Release of NP and NP

 in industrial and institutional cleaning products 

 during agricultural use 

Release of NPEs

 from emulsion polymerization processes 

 in textiles processes including wool scouring 

 from paper processes 

 from printed circuit boards manufacturing processes 

 from metal extraction, refining and processing industry 

 during paints, lacquers and varnishes manufacturing processes 

 from use in deicer formulations 
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Human Exposure

 There are no U.S. Occupational Health and Safety Administration (OSHA) Permissible 

Exposure Limits (PELs) or National Institute for Occupational Safety and Health (NIOSH) 

Recommended Exposure Limits (RELs) for NP or NPEs. No readily available, quantitative 

occupational exposure monitoring data in the U.S. were found for NP and NPEs. 

 Based on IUR data, the total number of workers reasonably likely to be exposed to NP or NPEs 

during manufacturing and industrial processing and use may be 1,000 or greater. There may be 

additional potentially exposed industrial workers who are not included in this estimate. This estimate 

also does not include potentially exposed commercial workers. 

 The National Occupational Exposure Survey (NOES), conducted from 1981 to 1983, estimated 

306, 211 workers were potentially exposed to NPs and 1,961,225 workers were potentially exposed to 

NPEs. The Survey lists the linear isomer, but EPA believes the branched isomer is more accurate. 

 

 The following exposure information is based on information obtained from the EU (EU, 2002). 

It is not known if the processes and associated exposures in the U.S. would be similar to those in the 

European countries. 

 The EU Risk Assessment indicated the manufacturing and use of NP as a chemical 

intermediate is carried out in closed systems. Occupational exposure may occur during sampling, 

maintenance and product filling to drums and tankers (EC, 2002). Occupational exposure was 

estimated at about 0.9 mg/m3

 (8-hour TWA) for both production and use of NP (EC, 2002). 

 

 During the manufacture of specialty paints, the EU identified two activities where potential 

exposure to NP may occur: during loading of the NP into the solvent, and during coupling and 

uncoupling of the pipe work during product loading into tins. The inhalation exposure was estimated to 

be 0.091 mg/m3

 (8-hour TWA), and the dermal exposure was estimated to be from 0 to 0.1 

mg/cm2

/day. During the use of these paints, the EU identified two exposure points: mixing of the paint, 

and spray application. Dermal exposure during mixing was estimated to range from 0.01 to 0.24 

mg/cm2

/day, and inhalation exposure during spraying was estimated to be 9.1 mg/m3 (8-hour TWA) 

(EC, 2002). 

 No quantitative worker exposure data were found during the production of epoxy resins using 

NP. However, NP is blended directly into the hardening component of the epoxy resin and filled into 

tubes for use (EC, 2002), indicating potential exposures may occur from adding the NP to the mixer. 

 No readily available quantitative information on exposure to NP or NPEs were found for use of 

NP in the manufacturing of NPEs or the processing or uses of NPEs in industrial and institutional 

cleaning products, emulsion polymerization, textiles, pulp and paper, electrical and electronic products, 

metal extraction, refining and processing industry or lacquers and varnishes industry. 
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 General population exposure to NP (either directly or as a metabolite of NPE) has been 

confirmed by biomonitoring data from breast milk (Ademollo et al., 2008), umbilical cord blood (Chen 

et al., 2008) and urine (Calafet et al., 2008). Exposure is a result of the presence of NP and NPEs in 

detergents, cleaners, agricultural and indoor pesticides, food packaging and cosmetics. These are 

potentially products of concern for women and children. For example, small children crawling on 

floors would be exposed to NPEs and NP in floor and carpet cleaners. 

 Estimates of human exposure are available for several of these sources. These include 

exposures from: diet_0.1 g/kg/day from a reported 7.5 g/day with the conversion done for a 70 kg 

person (Guenther et al. 2002); hair dye_0.1 g/kg/day; food containers_2 g/kg/day; and indoor 

pesticides_0.35 g/kg/day (EU, 2002). The EU report also estimates NP exposure due to 

environmental sources to be 5 g/kg/day, with 70% – 80 % of this due to fish and shellfish 

consumption (EU 2002). A biomonitoring study of breast milk also found a positive correlation 

between seafood consumption and levels of NP (Ademollo et al., 2008). Significant exposure could 

also result from hard surface cleaners and their residue. The largest estimated exposure (4.4 

mg/kg/day) was due to living near a textile factory that used NP and NPEs (EU, 2002). The 

appropriate exposure factors for drinking water ingestion of water across all ages ranges from a mean 

of 0.926 L/day to the 95th percentile factor of 2.544 L/day (EPA, 2009). If the measured value of 

1 g/L (EPA, 2001) for alkylphenols in drinking water is combined with the mean drinking water 

estimate of 0.926 L/day; the result is an estimated exposure of 0.01 g/kg/day. Based on this analysis, 

EPA believes that drinking water should not be the main source of exposure, a view shared by other 

sources (EU, 2002; Soares et al. 2008). 

Environmental Exposure

 Ecological receptors have the potential for significant exposure to NP and NPE for two reasons: 

1) facilities that manufacture products containing NP or NPEs are discharging them into surface waters 

(Ellis et al., 1982); and 2) NP and NPEs tend to partition to sediments and accumulate (Naylor et al., 

1992). Both freshwater and saltwater invertebrates, plants and fish are sensitive to this category of 

chemicals and have demonstrated toxicity to it in varying degrees. EPA’s Office of Water has derived 

freshwater and saltwater water quality criteria (WQC) for NP. The acute and chronic WQC for 

freshwater species are 28 μg/L and 6.6 μg/L, respectively. The acute and chronic WQC for saltwater 

species are 7 μg/L and 1.7 μg/L, respectively (USEPA, 2005). A range of surface water and sediment 

levels of NP and NPEs have been measured in US waters. Surface waters near 11 different industrial 

discharges ranged in concentration of NP from 2 to 1617 μg/L (Shackelford et al., 1983). Surface water 

and sediments measured in the Great Lakes contained NP concentrations from 0.01 to 0.92 μg/L for 

water and 37 μg/g to 300 μg/g for sediments (Bennett et al., 1997). Surface water samples collected 

along the Ohio River measured for total NPEs ranged from 0.13 to 1.0 μg/L for water, from 250 to 

1020 μg/g for sediments, and from 32 to 920 μg/g for carp, a bottom dwelling fish (Rice et al., 2003). 

Some of the measured surface water concentrations particularly those near industrial discharges exceed 

the WQC for freshwater species living in the water column. NP and NPEs in the freshwater and 
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saltwater ecosystems have the potential for ecological effects on all trophic levels of aquatic species 

exposed to them (USEPA, 2005). 

VIII. Risk Management Considerations

General Considerations 

 EPA has identified a number of issues that it has taken into consideration in the development of 

an Action Plan for NP and NPEs: 

1) NP and the short-chain NPEs (NP1EO and NP2EO) are persistent, moderately bioaccumulative, 

and extremely toxic to aquatic organisms. The long-chain NPEs, while less “PBT”, are also highly 

toxic and degrade to the more toxic and persistent short forms of NPEs and NP in the environment. 

Internationally, Canada and the EU have acted to regulate NP and NPEs, and the United Nations 

Environment Programme (UNEP) has identified NP as a chemical of global concern in its 

Regionally-based Assessment of Persistent Toxic Substances. 

2) NPEs are generally sold as mixtures; substances represented by CASRNs under the IUR cover a 

broad spectrum of these substances. There appear to be possible reporting inaccuracies regarding 

what is actually manufactured. Original TSCA inventory substances identified as straight-chain 

substances have often been found to be branched-chain forms. PMN submissions for straight-chain 

NPEs have also been found to be branched and are corrected during the PMN review process. 

3) NPEs frequently contain a mixture of substances with C6 to C12 (hexyl to dodecyl) alkylphenol 

ethoxylates; these “APEs” could also be sold as easily manufactured substitutes for NPEs. These 

substances are anticipated to have similar properties as NPEs. EPA notes, however, that for many 

uses of NPEs, safer substitutes are available and use of these substitute chemicals should be 

encouraged. 

4) It appears that a large proportion of use and subsequent environmental release is associated with 

industrial laundries; however, more analysis is needed to understand other TSCA (and non-TSCA) 

uses and releases. 

5) EPA’s Office of Pesticide Programs (OPP) also conducted an assessment of NPEs that was 

released shortly before publication of this document. OPPT and OPP have worked together to 

ensure that the toxicological conclusions in both documents are consistent. 

Potential Impacts on Children 

 There are potential children’s health concerns related to NP and NPEs. NP exposure over 

several generations has been observed to cause slight changes in the estrous cycle length, timing of 

vaginal opening, ovarian weight, and sperm/spermatid count in laboratory animals (EU, 2002), and 

more recently in vitro effects on human placenta (Bechi et al., 2006; Bechi et al., 2010). These findings 

are consistent with the observation that NP has estrogenic activity (EU, 2002), but a mode of action 

analysis has not been conducted. Data on children’s exposure are limited, though children may have 

greater exposure to NP and NPEs because they consume more food, drink more water, and breathe 
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more air per pound than adults. While biomonitoring data are also limited, a recent Italian study found 

maximum exposures from human breast milk of 3.9 μg /kg/day (Ademollo, 2008).

IX. Next Steps

 In conducting this review of NP and NPEs, EPA considered a number of potential risk 

management actions, including regulatory actions under TSCA sections 4 and 5, requiring reporting 

under the Emergency Planning and Community Right-to-Know Act (EPCRA) section 313, and 

voluntary actions through such programs as Design for the Environment (DfE). 

 Based on its screening-level review of hazard and exposure information, EPA intends to initiate 

actions to protect humans and the environment from exposure to NP and NPEs due to manufacture 

(including import) use, or disposal of commercial NP and NPEs. In addition, as part of the Agency’s 

efforts to address these chemical substances, EPA also intends to evaluate the potential for 

disproportionate impact of exposure to NP and NPEs on children and other sub-populations. 

 On the basis of existing information, the Agency believes that the following actions would be 

warranted: 

1. Support and encourage the voluntary phase out of the use of NPEs in industrial laundry 

detergents. 

a. In discussions with EPA, the Textile Rental Services Association of America (TRSA), 

whose members represent a large majority of the industrial launderers in the U.S., 

agreed to expedite a phase out of the use of NPEs in industrial laundry detergents. The 

phase out, which has already begun, would end the use of NPEs in industrial laundry 

detergents by 2013 (for liquid detergents) and 2014 (for powder detergents). 

b. The phase-out of detergents in industrial laundry detergents and other products will also 

be coordinated with EPA’s DfE Safer Detergents Stewardship Initiative (SDSI) 

program which has had great success in obtaining public commitment by consumer 

product manufacturers to end the use of NPEs in household laundry detergents. EPA 

intends to encourage any industrial launderers who are not members of TRSA to also 

join this effort. 

2. Initiate rulemaking to simultaneously propose a TSCA significant new use rule (SNUR) and a 

test rule for NP and NPEs. 

a. The proposed SNUR would designate use of NPEs in detergents and cleaning products 

as a significant new use, which would require submission of a significant new use 

notice (SNUN) to EPA at least 90 days before beginning that use. This gives EPA the 

opportunity to take regulatory action if appropriate. The proposed SNUR would be 

published at the end of 2011; with the effective date of the final SNUR timed to 

coincide with the anticipated completion of the phase-out of NPEs in industrial laundry 

detergents. 
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b. The proposed test rule under section 4 of TSCA would require development of the 

information necessary to determine the effects that NPEs and NP have on human health 

or the environment. EPA has already issued an advance notice of proposed rulemaking 

(ANPRM) for NPEs and NP (published June 17, 2009). However, EPA intends to 

evaluate how releases and exposures are mitigated through the phase-out action; and 

would finalize any proposed testing actions accordingly. 

c. EPA also intends to evaluate the utility of issuing a SNUR for the straight-chain NPEs 

that EPA believes are no longer being manufactured. Many commercial NPEs are 

identified as linear nonyl isomer, but EPA believes that these may be misidentified 

branched forms. In part, the intent of the SNUR would be to eliminate discrepancies on 

the TSCA inventory and improve accuracy in reporting under the IUR. 

d. In addition, EPA will consider SNURs for additional uses, depending on the results of 

an ongoing use and exposure analysis. 

3. Initiate rulemaking under TSCA Section 5(b)(4) of TSCA to add NP and NPEs to the list of 

chemicals that present or may present an unreasonable risk of injury to health or the 

environment. EPA intends to publish a notice of proposed rulemaking by the end of 2011. 

4. Initiate rulemaking in late 2011 to add NP and NPEs to the TRI list. At present, neither NP nor 

NPEs are on this EPCRA section 313 list of toxic chemicals. 

5. Support and encourage the elimination of other uses of NP and NPEs, followed by regulatory 

actions as necessary. 

a. EPA intends to encourage the manufacturers of all NPE-containing direct-release 

products (e.g., firefighting gels and foams, dust-control agents and deicers) to move to 

NPE-free formulations. As TRSA implements its phase-out commitment through SDSI, 

it will provide an example for other product sectors to follow, especially those with 

“direct releases” to the environment. The DfE-sponsored CleanGredients database 

offers a source of ready alternatives—functionally equivalent to NPEs based on 

performance characteristics and safer because they meet the DfE Criteria for Safer 

Surfactants. (For more information, visit 

http://www.epa.gov/dfe/pubs/projects/formulat/sdsi.htm.) 

b. EPA will develop an alternatives analysis and encourage the elimination of NPE use in 

other industries that discharge NPEs to water, such as the pulp and paper processing and 

textile processing sectors, where safer alternatives may be available. DfE also intends to 

expand the scope of SDSI, and encourage those industries to make commitments under 

SDSI. 

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