Flouride

Fluoride: The Ultimate Cluster-Flux
And the Players Involved
A Compilation of Documents and Articles

Relating to Fluoride
This collection is dedicated to those who wrote the original works and
made them available on the internet. I have spent countless hours
searching for information on fluoride and it is my wish, by assembling
these works, to enable others to save time looking and make available
more time for them to ‘do’.
If you are sickened and appalled by the approved use of fluoride in

food, beverage and other consumer products then I ask that you spread
this knowledge on to others and contact your local representatives in the
hopes that one day fluoride will be more strictly regulated or, banned
altogether.
These documents are listed in roughly the order I found them. It would
be nearly impossible to group them in some kind of order since they are
all linked together – a cluster-flux of monumental proportions.
I would like to thank (or curse) Christopher Bryson whose excellent

book, The Fluoride Deception, opened my eyes to fluoride and started
me on this journey of uncovering the truth.
For more information on fluoride, I would recommend the Fluoride Action

Network (FAN) http://www.fluoridealert.org/ as a good place to start.
NOTICE
In accordance with Title 17 U.S.C., section 107, some material on this web site is provided without
permission from the copyright owner, only for purposes of criticism, comment, news reporting,
teaching, scholarship and research under the "fair use" provisions of federal copyright laws. These
materials may not be distributed further, except for "fair use" non-profit educational purposes,
without permission of the copyright owner.
About Phosphogypsum – EPA
http://www.epa.gov/radiation/neshaps/subpartr/about.html
General Information
How much phosphogypsum is being produced?
Since the mid-eighties, the annual production rate of phosphogypsum has been in the range of
40 to 47 million metric tons per year. The total amount generated in the United States from
1910 to 1981 was about 7.7 billion metric tons.
In Central Florida, one of the major phosphoric acid producing areas, the industry generates
about 32 million tons of phosphogypsum each year. They have a current stockpile in stacks of
nearly 1 billion metric tons.
Why is so much phosphogypsum produced?
The agriculture industry uses large amounts of chemical fertilizers to replenish and
supplement the nutrients that growing plants take up from the soil. The demand for fertilizers
and animal feed additives accounts for about 95% of the 8-10 million metric tons of
phosphoric acid that is made each year. The production of each ton of phosphoric acid is
accompanied by the production of 4½ tons of the by-product calcium sulfate, also known as
phosphogypsum.
Phosphate rock, which is processed to make phosphoric acid, contains concentrations of

naturally occurring radioactive elements (radionuclides). Even high grade ores, which contain
about 70% calcium phosphate, also contain a large number of impurities, such as calcium
fluoride, chlorides, chromium, rare earths, and radionuclides. At the end of the production
process, the radionuclides end up in the phosphogypsum.
Processing Phosphate Rock
Where does the phosphate rock come from?
In the United States, main deposits of phosphate rock are in Florida, Tennessee, and North
Carolina. There are also deposits that can be mined in Idaho. The phosphate rock, which
eventually yields the phosphogypsum by-product, is recovered by open pit mining. The rock is
transported to a washing facility, where it is separated from accompanying soil, stones, etc.
and processed. The desired phosphorus content of the phosphate rock is in a form (calcium
phosphate) that will not dissolve in water and so cannot be taken up by crops. As a result,
phosphate processors must solve the problem of getting it into a water-soluble form.
The most common solution to the problem is converting the calcium phosphate to phosphoric
acid. There are wet and dry processes for doing the conversion. U.S. production facilities
utilize a wet process in which the prepared rock is treated with sulfuric acid to produce the
phosphoric acid. Phosphoric acid is water soluble so it can be taken up by crops. It can also be
concentrated, as desired, by evaporating water from the mixture.
The by-product remaining after the acid conversion is largely calcium sulfate and has been
given the name phosphogypsum. (Gypsum is the common trade name for hydrated calcium
sulfate, a common building material.)
How many facilities are producing phosphoric acid and

phosphogypsum?
As of September 1989, the phosphoric acid production industry consisted of 21 active facilities
that use the wet-acid production process. The majority of the 21 facilities are located in the
southeast, with 12 in Florida, three in Louisiana, and one in North Carolina.
Stacks
The phosphogypsum, separated from the phosphoric acid, is in the form of a solid/water
mixture (slurry) which is stored in open-air storage areas known as stacks. The stacks form as
the slurry containing the by-product phosphogypsum is pumped onto a disposal site. Over
time the solids in the slurry build up and a stack forms. The stacks are generally built on
unused or mined out land on the processing site.
As the stack grows, the phosphogypsum slurry begins to form a small pond (gypsum pond) on
top of the stack. Workers dredge gypsum from the pond to build up the dike around it and the
pond gradually becomes a reservoir for storing and supplying process water. A total of 63
phosphogypsum stacks were identified nationwide in 1989. They were in 12 different states,
but the majority, two-thirds, were in Florida, Texas, Illinois, and Louisiana.
The surface area covered by stacks ranges from about 5 to 740 acres. The height ranges from
about 10 to 200 feet. In 1989, the total surface area covered by stacks was about 8,500
acres. More than half that acreage is in Florida.
The tops of operating phosphogypsum stacks (ones that are still receiving phosphogypsum)
are covered by ponds and ditches containing process water. "Beaches," saturated land
masses, protrude into the ponds. These surface features may cover up to 75 percent of the
top of the stack. Other surface features include areas of loose, dry materials; access roads;
and thinly crusted stack sides. (The crust thickens and hardens when the stacks become
inactive and no longer receive process slurry.)
Radioactivity in Phosphogypsum
How much radioactivity is in the phosphogypsum?
The concentrations of uranium and radium-226 in phosphogypsum samples taken in central

Florida were about 10 times the background levels in soil for uranium and 60 times the
background levels in soil for radium-226.
The radium-226 concentration in phosphogypsum varies significantly at different sampling

locations on a single stack and also in phosphogypsum from different stacks within the same
geographical area.
How are people exposed to the radiation from phosphogypsum

stacks if they don’t go near them?
Radionuclides that are small particles (i.e., radionuclide dust) can become airborne as wind-
blown dust or as dust thrown up into the air by cars and trucks. The radionuclides, uranium
and radium-226, are present in the phosphogypsum and can become airborne. Once these
radionuclides are in the air, people and animals can breathe them and they can settle out onto
ponds and agricultural areas. Radon-222, a decay product of radium-226, is a gas and so may
become airborne by diffusing into the air. EPA has determined, however, that the risks
associated with stacking phosphogypsum are in line with acceptable risk practices.
Other Phosphogypsum Constituents of Concern
In addition to the radiation health hazards covered by Subpart R, phosphogypsum contains

some trace metals in concentrations that EPA believes may pose a chemical hazard to human
health and the environment. Analysis of samples from various facilities contained arsenic,
lead, cadmium, chromium, fluoride, zinc, antimony, and copper at concentrations that may
pose significant health risks. The concentrations of these contaminants vary by more than
three orders of magnitude among samples taken from various locations. These trace metals
may also be leached from phosphogypsum and migrate to nearby surface and groundwater
resources.
The presence of these trace metals in phosphogypsum is mentioned here in order to provide a
more complete description of phosphogypsum, but they are not to be addressed in the risk
assessment.
Adverse Effects Sodium fluosilicate CAS No. 16893-85-9
http://www.fluoridealert.org/pesticides/epage.sodium.fluosilicate.htm
Activity: Insecticide, Wood preservative, US EPA List 3 Inert (Inorganic)
Structure:
Adverse Effects:
Anemia
Apoptosis
Ataxia
Bladder
Blood
Body Weight Decrease (including Cachexia, Wasting, Anorexia)
Bone
Dermal
Heart
Kidney
Liver
Lung
Spleen
Poisoning Incident
The major use is as a fluoridation agent for drinking

water.
• Some common synonymns:

Sodium Silicofluroide and Sodium Hexafluorosilicate
• "Sodium fluosilicate (sodium silico fluoride) has been used to control

ectoparasites on livestock, as well as crawling insects in homes and
work buildings. It is approximately as toxic as sodium fluoride [highly
toxic to all plant and animal life]. All uses in the U.S. have been
cancelled."
Ref: Recognition and Management of Pesticide Poisonings, 5th
Edition, Chapter 8.
The Office of Pesticide Programs, US EPA
http://www.epa.gov/oppfead1/safety/healthcare/handbook/Chap08.pdf
• The major use of sodium hexafluorosilicate and fluorosilicic acid is as

fluoridation agents for drinking water. Sodium hexafluorosilicate has
also been used for caries control as part of a silicophosphate cement,
an acidic gel in combination with monocalcium phosphate
monohydrate, and a two-solution fluoride mouth rinse. Both chemicals
are also used as a chemical intermediate (raw material) for aluminum
trifluoride, cryolite (Na3AlF6), silicon tetrafluoride, and other
fluorosilicates and have found applications in commercial laundry.
Other applications for sodium hexafluorosilicate include its use in
enamels/enamel frits for china and porcelain, in opalescent glass,
metallurgy (aluminum and beryllium), glue, ore flotation, leather and
wood preservatives, and in insecticides and rodenticides. It has been
used in the manufacture of pure silicon, as a gelling agent in the
production of molded latex foam, and as a fluorinating agent in organic
synthesis to convert organodichlorophosphorus compounds to the
corresponding organodifluorophosphorus compound. In veterinary
practice, external application of sodium hexafluorosilicate combats lice
and mosquitoes on cattle, sheep, swine, and poultry, and oral
administration combats roundworms and possibly whipworms in
swine and prevents dental caries in rats. Apparently, all pesticidal
products had their registrations cancelled or they were discontinued
by the early 1990s... Exposure to sodium hexafluorosilicate is possible
from its use to control crawling insects in homes and work buildings.
The chemical has "high inherent toxicity," and children may ingest the
material from crawling on the floors of treated houses (U.S. EPA, 1999).
Ref: Toxicological Summary for Sodium Hexafluorosilicate [CASRN
16893-85-9] and Fluorosilicic Acid [CASRN 16961-83-4]. Review of
Toxicological Literature. October 2001. Prepared for Scott Masten,
Ph.D. National Institute of Environmental Health Sciences.
http://ntp-server.niehs.nih.gov/htdocs/Chem_Background/ExSumPDF/Fluorosilicates.pdf
NOTE FROM FAN:

Sodium hexafluorosilicate is a US EPA List 3 Inert, which means it is
currently used in pesticidal formulations in the US. Due to the
absurdities of US EPA policy on "Inerts", the public is not allowed to
know which inerts are used in pesticides. Inerts can account for as
much as 99.9 % of a pesticidal formulation. US EPA's practice on
"Inerts" is wholly unscientific and an insult to a democatic society.
Toxicological data on the majority of Inerts is not available, because
they have not been studied, and most likely many are industrrial
toxic waste products. And it is these chemicals that we grow our
food with in the United States.
This chemical is unique in that it has received some public

examination because of the fluoridation issue. This is because it is
used as a "fluoridating chemical" in the US, and the issue of
"dissassociation" arose which has forced EPA to begin a first-time
study of it. In April 2002, US EPA put out a Request for Proposals for
this study. EC.
Oborova norma ON 653130, Ministry of Industry, Prague,

Czechoslovakia, 7 pages, 1969
Commercial Sodium Silicofluoride
Anonymous
Sodium-silicofluoride (Na2SiF6), used mainly in the glass industry, in

building construction and in the production of insecticides and foam
rubber, is a toxic substance. The threshold limit value is 1 milligram
per cubic meter, and the emergency exposure limit, 2 milligrams per
cubic meter. Workers should avoid all direct contact; they should wear
goggles, respirators, protective clothing and gloves. Drinking and
smoking are forbidden during work. (Czech)
Anemia (click on for all fluorinated pesticides)
Toxicological Data Human Data Chronic exposure to sodium hexafluorosilicate dust at levels above
the eight-hour TWA can result in severe calcification of the ribs, pelvis, and spinal column
ligaments; effects on the enzyme system; pulmonary fibrosis; stiffness; irritation of the eyes, skin,
and mucous membranes; weight loss; anorexia; anemia; cachexia; wasting; and dental effects.
Long-term or repeated exposure to the skin can result in skin rash. A probable oral lethal dose of 50-
500 mg/kg, classified as very toxic, has been reported for a 150-pound (70-kg) person receiving
between 1 teaspoon and 1 ounce of sodium hexafluorosilicate.
Ref: Review of Toxicological Literature. October 2001. Sodium Hexafluorosilicate [CASRN 16893-85-
9] and Fluorosilicic Acid [CASRN 16961-83-4]. Prepared for Scott Masten, Ph.D. National Institute of
Environmental Health Sciences P.O. Box 12233 Research Triangle Park, North Carolina 27709.
Contract No. N01-ES-65402. Submitted by Karen E. Haneke, M.S. (Principal Investigator) Bonnie L.
Carson, M.S. (Co-Principal Investigator) Integrated Laboratory Systems P.O. Box 13501 Research
Triangle Park, North Carolina 27709.
http://www.fluoridealert.org/pesticides/fluorosilicates.nih.2001.pdf
Apoptosis (click on for all fluorinated pesticides)
SUMMARY: Although potential toxic effects of sodium fluoride on early progenitor and
stem cells have been reported previously, surprisingly few investigations have examined
the effects of fluoride on human leukemic cells. To address this need, four different human
leukemic cell lines (HL-60, HEL, TF-1, and K562) were exposed to increasing levels (0, 0.24,
and 1.19 mM F) of two forms of fluoride: sodium fluoride (NaF) and sodium
hexafluorosilicate (Na2SiF6). Because of its widespread use in water fluoridation, Na2SiF6
was investigated in addition to NaF. The early response effect of Na2SiF6 was greater, and
in several cases significantly greater, than NaF on clonogenic growth and the induction of
apoptosis in all four cell lines. These findings show that human leukemic cells can be
influenced and damaged by fluorine compounds.
THE INFLUENCE OF SODIUM FLUORIDE AND SODIUM HEXAFLUOROSILICATE ON HUMAN
LEUKEMIC CELL LINES. By B Machalinski et al. Fluoride Vol. 36 No. 4 231-240 2003.
Full free report available at: http://www.fluoride-journal.com/03-36-4/364-231.pdf
Ataxia (click on for all fluorinated pesticides)
-- Mouse strain, 70 mg/ kg (LD 50 ; 0.37 mmol/ kg); Toxic effects were observed in the peripheral
nerves and sensation (flaccid paralysis without anesthesia, generally neuromuscular blockage) and
in behavior (ataxia and muscle contraction or spasticity). RTECS* (1997)
Bladder (click on for all fluorinated pesticides)
-- Mice orally given sodium hexafluorosilicate (70 mg/kg; 0.37 mmol/kg) exhibited toxic effects in the
peripheral nerves, sensation, and in behavior. In rats, an oral dose (248 mg/kg; 1.32 mmol/kg)
administered intermittently for one month produced toxic effects in the kidney, ureter, and/or
bladder, as well as musculoskeletal and biochemical effects (RTECS, 1997). Using guinea pigs,
inhalation experiments (13-55 mg/m 3 [1.7-7.2 ppm] sodium hexafluorosilicate in air for ¥6 hours)
resulted in pulmonary irritation; the lowest concentration that caused death was 33 mg/m 3 (4.3
ppm) (Patty, 1963; cited by HSDB, 2000b).
-- Rats, oral; 248 mg/ kg (1.32 mmol/ kg) for 30 days intermittent; Toxic effects in the kidney, ureter,
and/ or bladder (other changes in urine composition) were observed. Musculoskeletal (other
changes) and biochemical (enzyme inhibition, induction, or changes in blood or tissue
[phosphatases] levels) effects were seen. RTECS* (1997)
-- Rats, 70 mg/ kg (LD Lo ; 0.37 mmol/ kg); Fatty liver degeneration and other changes in the liver and
toxic effects in the kidney, ureter, and bladder primarily changes in glomeruli were observed.
RTECS* (1997)
Blood (click on for all fluorinated pesticides)
-- Sheep, Awassi breed, 1- to 3- yr- old, 5F technical sodium hexafluorosilicate, 25, 50, 200, 1500, and
2000 mg/ kg (0.13, 0.27, 1.06, 7.976, and 10.63 mmol/ kg) suspended in water; duration and
observation period n. p. With the 25- and 50- mg/ kg doses, animals exhibited grinding of teeth (an
indication of pain), dullness, and mild diarrhea. At 200 mg/ kg, additional symptoms were
experienced and included staggering and severe diarrhea. Animals died on day 6. With the two
higher doses, licking of the lips, kicking of the belly, grinding of the teeth, falling down (after 1.5 h),
frothing at the mouth, congested conjunctiva, protrudation of the tongue, forced and labored
breathing, fever, and increased respiration and heart rates were observed. Animals died 3 h after
administration of 1500 mg/ kg and 2.5 h after administration of 2000 mg/ kg. Post- mortem
examination showed serous pericardial fluid (few milliliters), a slightly friable liver, mild edema in the
lungs, and froth in the trachea. Hemorrhages occurred on the spleen and mucosal folds of the
abomasum, and a gelatinous fluid was present in the colon. For the 1500 mg/ kg- dose group, the
change in GOT went from 132% (of pretreatment activity) at 1.5 hours to 230% at 2.5 hours. For LDH,
the change was 158% at death. The serum ICDH [isocitrate dehydrogenase] change increased from
168% after one hour to 984% at death. Egyed and Shlosberg (1975)
Body Weight Decrease (click on for all fluorinated pesticides)
Toxicological Data. Human Data. Chronic exposure to sodium hexafluorosilicate dust at levels above
the eight-hour TWA can result in severe calcification of the ribs, pelvis, and spinal column
between 1 teaspoon and 1 ounce of sodium hexafluorosilicate. Cases of sodium hexafluorosilicate
ingestion reported symptoms such as acute respiratory failure, ventricular tachycardia and
fibrillation, hypocalcemia, facial numbness, diarrhea, tachycardia, enlarged liver, and cramps of the
palms, feet, and legs.
---- [Note from FAN. see: Case definition of AIDS as cachexia is cited.]
Ref: Sodium Hexafluorosilicate [CASRN 16893-85-9] and Fluorosilicic Acid [CASRN 16961-83-4].
Review of Toxicological Literature. October 2001. Prepared for Scott Masten, Ph.D. National Institute
of Environmental Health Sciences P.O. Box 12233 Research Triangle Park, North Carolina 27709
Bone (click on for all fluorinated pesticides)
-- Toxicological Data. Human Data. Chronic exposure to sodium hexafluorosilicate dust at levels
above the eight-hour TWA can result in severe calcification of the ribs, pelvis, and spinal column
Dermal (click on for all fluorinated pesticides)
-- Within one week after beginning work in a foam rubber plant, a 23-year-old man exhibited skin
lesions consisting of "diffuse, poorly delineated, erythematous plaques with lichenoid papules and
large pustules" on his arms, wrists, thighs, and trunk. Although scratch and patch tests with sodium
hexafluorosilicate (2% aqueous) were negative, animal testing showed the compound to be a
pustulogen. When rabbits received topical application of a 1, 5, 10, and 25% solution of sodium
hexafluorosilicate in petroleum, pustules occurred on normal skin only with the high concentration,
while all concentrations produced pustules on stabbed skin (Dooms-Goossens et al., 1985).
-- -- Rabbits, New Zealand; 0.5 mL (4 mol) to the intact and abraded skin for 1, 24, or 72 h Severe
erythema and edema were observed, indicating the material to be a primary irritant. Rhone- Poulenc
Inc. (1971)
• Definition for Erythema - abnormal redness of the skin resulting from dilation of blood vessels (as
in sunburn or inflammation)
Heart (click on for all fluorinated pesticides)

-- -- Guinea pigs, 13- 55 mg/ m 3 (1.2- 7.2 ppm) in air for ¥ 6 h; Pulmonary irritation was observed. The
lowest concentration that caused death when inhaled for 6 h was 33 mg/ m 3 . Patty (1963; cited by
HSDB, 2000b)
-- -- Mice orally given sodium hexafluorosilicate (70 mg/kg; 0.37 mmol/kg) exhibited toxic effects in
the peripheral nerves, sensation, and in behavior. In rats, an oral dose (248 mg/kg; 1.32 mmol/kg)
http://www.fluoridealert.org/pesticides/Fluorosilicates.NIH.2001.pdf
Kidney (click on for all fluorinated pesticides)
-- Mouse strain, 70 mg/ kg (LD 50 ; 0.37 mmol/ kg); Toxic effects were observed in the peripheral
nerves and sensation (flaccid paralysis without anesthesia, generally neuromuscular blockage) and
in behavior (ataxia and muscle contraction or spasticity). RTECS* (1997)
-- Rats, 70 mg/ kg (LD Lo ; 0.37 mmol/ kg); Fatty liver degeneration and other changes in the liver and
toxic effects in the kidney, ureter, and bladder primarily changes in glomeruli were observed.
RTECS* (1997)
http://www.fluoridealert.org/pesticides/gluorosilicates.nih.2001.pdf
Liver (click on for all fluorinated pesticides)
Sheep, Awassi breed, 1- to 3- yr- old, 5F technical sodium hexafluorosilicate, 25, 50, 200, 1500, and
the change was 158% at death. The serum ICDH [isocitrate dehydrogenase] change increased from
168% after one hour to 984% at death. Egyed and Shlosberg (1975)
Lung (click on for all fluorinated pesticides)
-- -- Guinea pigs, 13- 55 mg/ m 3 (1.2- 7.2 ppm) in air for ¥ 6 h; Pulmonary irritation was observed. The
lowest concentration that caused death when inhaled for 6 h was 33 mg/ m 3 . Patty (1963; cited by
HSDB, 2000b)
-- -- Mice orally given sodium hexafluorosilicate (70 mg/kg; 0.37 mmol/kg) exhibited toxic effects in
the peripheral nerves, sensation, and in behavior. In rats, an oral dose (248 mg/kg; 1.32 mmol/kg)
Poisoning Incident
A 2 1/2 year old colored girl was brought to the emergency room with progressive vomiting and
lethargy of about six hours' duration. The respiratory rate was only 6 to 8 breaths per minute. The
child had a disconjugate gaze with coarse horizontal nystagmus and muscular fasciculation
throughout the body. A soft systolic ejection murmur was audible at the left sternal border.
The child had been playing with a laundry powder called "Rayline Brand Laundry Sout"
(manufactured by BASF, Wyandotte Corporation in Michigan) which contained sodium silicofluoride.
Na2S4F6 as its major ingredient. Laboratory data showed a BUN of 31 mg/100 ml, 2 + protein and 40
red blood cells/high power field. The plasma sodium was 138 mEq/liter, potassium 6.7, bicarbonate
13 and chloride 107. Serum calcium was 3.4 mg/100 ml, the lowest ever reported in fluoride
poisoning. The EKG showed peaked t-waves which were inverted in the chest leads.
After admission the patient developed acute respiratory failure which required assisted ventilation
for 48 hours. Repeated episodes of ventricular tachycardia and fibrillation were treated with
lidocaine and eight separate courses of direct current cardioversion. The hypocalcemia was treated
with three intravenous infusions of 10% calcium chloride (0.3 gms) followed by calcium gluconate
and 0.1% calcium hydroxide (lime water) and aluminum hydroxide by nasogastric tube which
brought the serum calcum up to 13 mg/100 ml. Aspiration pneumonia required penicillin, kanamycin,
and dexamethasone. Peritoneal dialysis was instituted with a calcium concentration of 10 mg/100 ml
and continued for 48 hours.
The patient became responsive 18 hours after admission and returned to full consciousness two
days later. There were no mucosal burns or ulcerations and the upper gastrointestinal examination
was normal.
The serum fluoride levels were extremely high (14 mg/liter) but dropped to 1.8 mg/liter after 11 hours
and to 0.1 mg/liter 21 hours after the ingestion of the poison. Urinary fluoride excretion amounted to
24.8 mg over the first three days. The average fluoride clearance was 98 ml/min/1.73 sq m. In view of
the fact serum levels above 3 mg/liter had been fatal in other cases, the authors attributed the
improvement mainly to the gastric lavage with calcium salts and to the maintanence of a urinary
output. Peritoneal dialysis resulted in no significant removal of fluoride. The fluoride level of the
effluent was less than the fluoride level of the bottled dialysate, which had evidently been prepared
from fluoridated water.
Ref: Yolken R, Konecny P, McCarthy P (1976). Acute fluoride poisoning. Pediatrics 1976; 58:90-93.
As abstracted in Fluoride 1977; 10(1):38-39
Spleen (click on for all fluorinated pesticides)
-- Sheep, Awassi breed, 1- to 3- yr- old, 5F technical sodium hexafluorosilicate, 25, 50, 200, 1500, and
the change was 158% at death. The serum ICDH change increased from 168% after one hour to 984%
at death. Egyed and Shlosberg (1975)
Sept., 1938
American Journal of Public Health

and THE NATION'S HEALTH
Official Monthly Publication of the American Public Health Association
Volume 28 September, 1938 Number 9
MAZYCK P. RAVENEL, M.D., Editor AUGUSTA JAY, Editorial Associate

REGINALD M. ATWATER, M.D., Managing Editor
Editorial Board
THE MANAGING EDITOR, Chairman
PROF. IRA V. HIscocK
KENNETH F. MAXCY, M.D.
ARTHUR P. MILLER, C.E.
HARRY S. MUSTARD, M.D.
THE NEW FEDERAL LAWS RELATING TO FOODS,

DRUGS, AND COSMETICS
A FTER five years of consideration,' the Congress of the United States has
X finally adopted two important new laws to amend and strengthen the more
or less obsolescent Federal Food and Drug Act of 1906. One of these measures,
giving the Federal Trade Commission jurisdiction over false advertising of foods,
drugs, devices, and cosmetics, was signed by the President on March 21, 1938,
to become effective 60 days from that date; the other measure, a new Federal
Food, Drug, and Cosmetic Act, was signed on June 25, 1938, and becomes
effective one year from that date, except that several sections, including one
(Sec. 701) authorizing the Secretary of Agriculture to hold hearings and promul-
gate regulations for the enforcement of the act became effective on the date of
approval of the law. The Secretary is also authorized to designate prior to the
effective date food having common or usual names and exempt such food from the
requirement of the act, but only for a reasonable time to permit the formulation,
promulgation, and effective application of definitions and standards of identity.
Under the terms of the first law mentioned, which is officially designated as
Public-No. 447-75th Congress, and is popularly known as the Wheeler-Lea
Act, the jurisdiction of the Federal Trade Commission is extended to the adver-
tising of all foods, drugs, diagnostic and therapeutic devices, and cosmetics
(except soap) in interstate and foreign commerce, or through the mails. When-
ever the Commission believes that any person, partnership, or corporation is
engaged in, or is about to engage in, the dissemination of false advertising, defined
as " an advertisement, other than labeling, which is misleading in a material
respect," the Commission may bring suit in a federal district court to enjoin the
dissemination of the advertisement. If the commodity advertised is injurious
to health because of its use in accordance with its advertising, or the advertising
is intended to defraud or mislead, the advertiser may be haled -to court and
prosecuted criminally without previous notice. Ordinarily, however, false adver-
tising is regarded as an unfair or deceptive trade practice, with the advertiser
subject to a proceeding by the Commission consisting of notice, a hearing, and,
if the findings justify it, the issuance of a cease and desist order, which may
[11141
Vol. 28 EDITORIALS 1115
be appealed to a federal circuit court of appeals, and finally to the Supreme

Court.
In determining whether an advertisement is false, the law states that there
shall be taken into account (among other things) not only representations made
or suggested by statement, word, design, device, sound, or any combination
thereof, but also the extent to which the advertisement fails to reveal material
facts. Advertisements of drugs are not deemed false when disseminated only
to the medical profession, provided they disclose the formula and contain no
false representation of material facts. Publishers, radio-broadcast licensees, and
advertising agencies will not be liable for the false advertising of manufacturers
and sellers if they furnish to the Commission on request the name and address
of the person responsible for the advertisement.
This somewhat drastic law, if reasonably enforced, should have a salutary
effect upon the nature of food, drug, device, and cosmetic advertising in inter-
state commerce, although it seems likely that the law will give rise to much
time consuming litigation. It is also unfortunate that there should have been
the division of authority between the Federal Trade Commission and the U. S.
Dqpartment of Agriculture, which has had and continues to have jurisdiction
over the labeling and the adulteration of these same products. Not only is this
department equipped by training and experience to carry out the necessary admin-
istrative duties, but it has adequate laboratory and technical facilities for the
purpose.2
Under the terms of the new Federal Food, Drug, and Cosmetic Act (Public-
No. 717-75th Congress), the adulteration or misbranding of any food, drug,
diagnostic or therapeutic device, or cosmetic (except soap) in interstate com-
merce is prohibited. This act not only gives administrative jurisdiction to the
Secretary of Agriculture over devices and cosmetics, which were not included in
the law of 1906, but it also provides for injunction proceedings in federal district
courts to enjoin adulteration and misbranding of foods, drugs, devices, and
cosmetic, as well as providing for the customary criminal actions for violations,
and for seizures and destruction by court action of dangerous and fraudulent
commodities. In order to carry out the purposes of the act, the Secretary of
Agriculture is authorized to promulgate necessary regulations.
Since the law is a lengthy one, and it is difficult to review all of its many
specific provisions within the limited space of an editorial, it is suggested that
health officals and other interested sanitarians secure copies of the act from the
U. S. Department of Agriculture, for careful study.
In general, however, it may be stated that the new law contains comprehensive
and somewhat broadened definitions of adulteration and misbranding of the
variouis products, so as to include in the former category not only the presence of
poisonous or deleterious substances that are injurious to health, but the absence
of valuable constituents, the substitution of inferior materials, and, in the case
of drugs, substandard quality, purity, or strength. Under misbranding is included
not only false and misleading labels, but improper imitations of labels of other
products, misleading containers, and in cases of foods for special dietary uses,
failure to give information as to vitamin, mineral, and other dietary properties.
Special labels are required on drugs containing habit-forming narcotics, with
adequate directions for use and suitable warnings on such labels. In the section
on cosmetics there is a provision that coal-tar hair dyes must be labelled with a
1116 AMERICAN JOURNAL OF PUBLIC HEALTH Sept., 1938
caution against their use for dyeing eyebrows and eyelashes, and the statement
that such use may cause blindness.
An important section of the law requires that new drugs can be introduced
in interstate commerce only after filing an application, with submission of evi-
dence and data, and the securing of a permit from the Secretary. Refusal by
the Secretary of such a permit may be appealed to the federal courts. If this
provision of the law had been in effect a year ago, the series of unfortunate
deaths from the use of an elixir of sulfanilamide probably would not have
occurred.
The new law does not cover meat and meat food products, which are still
subject to the Meat Inspection Act of 1907, as amended. It also keeps in effect
various other existing laws, such as the Butter Standards Act of 1923, the Filled
Cheese Act of 1896, the Filled Milk Act of 1923, and the Import Milk Act of
1927.
The Federal Food, Drug, and Cosmetic Act of 1938, as sponsored by the late
Senator Royal S. Copeland, represents a noteworthy advance over its 32 year old
precursor, the Federal Food and Drug Act of 1906, as occasionally but inade-
quately amended. The enforcement of this law after June 25, 1939, should do
much to aid in the protection and promotion of public health in this country.
REFERENCES
1. Editorial. The Copeland Bill. A.J.P.H., 25:961 (Aug.), 1935.
E,ditorial. Federal Legislation to Control Foods, Drugs, and Cosmetics. The Copeland Bill. A.J.P.H.,
27:381 (Apr.), 1937.
2. Editorial. Wheeler-Lea Bill Giving Federal Trade Commission Jurisdiction Over Foods, Drugs,
Devices and Cosmetics Becomes a Law. J.A.M.A., 110:1112 (Apr. 2), 1938.
THE AIRPLANE AND YELLOW FEVER

T HE rapid multiplication of airplanes of all types and the tremendous increase
in their use for personal transportation has necessarily been a matter of
great concern to all nations. A number of reports have been made and efforts
are under way to bring about international agreements and methods for inspection
of passengers and for disinsectization of the planes. The increase in the use of
planes is shown to some extent by a report' of the examinations made at
Khartoum: 287 in 1935; 667 in 1936; and 364 up to July 2, 1937. Indeed
Khartoum is now a modern city and the crossroads for airships coming from many
different directions. Its airport is the stopping place for night for all of the
great lanes. Apparently this gives an abundance of time for disinsectization and
inspection, which requires a longer or shorter time, according to the arrange-
ments of the interior and the number of insects which it is necessary to capture.
At least one-half hour is required for inspection. The work of the Custom
officers and of the Postal service should be delayed until the planes have been
cleared of insects. It is interesting to note that in the Sudan until 1936 the
insecticides employed were " Flit " and " Shelltox," widely used in this country,
but since then a cheaper mixture made on the spot is used, which has the added
advantage of being practically noninflammable.*
Mosquitoes are found chiefly in the compartments occupied by passengers,
but also in the baggage compartments, especially in those planes in which these
are reached by a separate door at the side. So far no mosquitoes have been
* Extract of pyrethrum ......... 5.8 per cent Tetrachloride of carbon ........ 49 per cent
Essence of citronella ...........2 per cent Kerosene ..... 43.2 per cent
ALCOA Inc Needed Electricity
http://www.cityofalcoa-tn.gov/content/view/full/817
The Little Tennessee River and its hydroelectric potential brought the Alcoa Inc. to East Tennessee in
the early 1900’s. In that way, the role of electricity has played a major part in the City of Alcoa and all
of Blount County.
In February 1886, Charles Martin Hall discovered that cryolite, a sodium aluminum
fluoride, in molten state will dissolve aluminum oxide. Using a carbon crucible, Hall
isolated aluminum by passing an electric current through the molten mass. He was
issued a patent for this process in April 1889. By the end of that year, his company,
the Pittsburgh Reduction Company and the predecessor to Alcoa Inc., became a
multi-million-dollar company.
To produce one pound of aluminum required 10 kilowatts (the amount to burn a 40-watt bulb for 10
days). Thus, Alcoa Inc. created a massive plan for developing the entire watershed of the Little
Tennessee River in 1910, and built six major dams over several decades. Cheoah Dam, at 230 feet,
the highest in the world at the time it was built in 1919, is located on the Little Tennessee River just
upstream from the mouth of the Cheoah River.
Then, Santeelah Dam was constructed in 1926. Located nine miles from the mouth of the Cheoah
River, its powerhouse is located three miles above Cheoah Dam. A five-mile conduit transports water to
the powerhouse. Calderwood Dam, a 230-foot arch type dam nine miles downstream from Cheoah
Dam followed in 1930. A pressure tunnel one-half mile long transports water from the reservoir to the
Cheoah powerhouse. By 1937, the combined output of Cheoah, Santeelah and Calderwood at 330,000
horsepower was 265,000 KVA.
Although Alcoa Inc. also built two dams in North Carolina, Chilhowee Dam was the last Alcoa Inc. dam
in Tennessee completed in 1957. The project relocated more than three miles of Highway 129, and the
lake covers 1,750 acres with a 30-mile shoreline. This dam measures 88 feet high and 1,370 feet long.
In 1941, Alcoa Inc. relinquished approximately 1,500 acres to TVA, which built Fontana Dam. In
addition, TVA took over the regulation of the water flow at all of Alcoa Inc.’s facilities on the Little
Tennessee River. In return, Alcoa Inc.’s benefits included a better-integrated system, property retention
and credit for the electricity generated by the plants. In 1957, some of the transmission lines for this
system were transferred to the City of Alcoa’s Blount Electric System, known today as the City of Alcoa
Electric Department.
Meanwhile, in 1913, Alcoa Inc. opened its smelter, which would turn alumina into molten aluminum.
The first fabricating operation, known as the West Plant, opened in 1920 to produce items ranging from
aluminum pie plates and siding to aluminum for patio furniture and pots and pans.
As the United States was on the verge of entering World War II, Alcoa Inc. experienced a 600 percent
production increase and a $300 million expansion. By 1942, the North Plant fabricating facility was in
operation, making aluminum sheet for the 300,000 airplanes built for the war.
In 1943, the aluminum industry was the largest single electricity

user in the U.S., consuming 22 billion kilowatts annually. By
1945, the company’s power plants in East Tennessee and West
North Carolina were furnishing 50 percent of Alcoa Inc.’s power,
with the other 50 percent purchased from TVA.
In 1965, the company entered a new market for aluminum – the beverage can. The Tennessee
Operations and its sister plant in Evansville, Indiana, were chosen to lead the effort in can sheet
production. However, to handle the millions of aluminum cans already being recycled in the U.S., Alcoa
Inc. opened a can reclamation facility at Tennessee Operations in 1975.
In 1989, the West Plant was shut down. In 1990, the WWII vintage hotline was replaced with a state-
of-the-art, five-stand mill. Tennessee Operations continues to produce molten metal in its smelter, and
the company is considered a world benchmark in the production of high quality aluminum can sheet.
http://goliath.ecnext.com/coms2/gi_0199-4464657/Alcoa-subsidiary-receives-long-term.html
Alcoa subsidiary receives long term contract from Lockheed

Martin and Northrop Grumman awarded Global Hawk contract.
Article Excerpt
M2 PRESSWIRE-13 July 2005-US Financial Network: Alcoa subsidiary receives long term contract
from Lockheed Martin and Northrop Grumman awarded Global Hawk contract(C)1994-2005 M2
COMMUNICATIONS LTD
RDATE:13072005
City of Industry, CA - Defense industry news provided by Financial News...

USA (OTC: FNWU). A subsidiary of aluminum giant Alcoa Inc. has agreed to a long-term deal to
supply fasteners for the Lockheed...
EPA Cites Alcoa Subsidiary for Hazardous Waste Violations

Release date: 12/31/2003
Contact Information:
(#03146) NEW YORK, N.Y. -- The U.S. Environmental Protection Agency (EPA) announced
today that it has cited Howmet Corporation, a Dover, New Jersey subsidiary of Alcoa Inc.,
for violating numerous hazardous waste regulations. The manufacturing facility shipped
hazardous waste to another facility to be used in the production of fertilizer without
properly identifying and managing the material as a hazardous waste, as required by the
Resource Conservation and Recovery Act (RCRA).
"The shipment of hazardous wastes requires proper management to ensure protections,"

said EPA Regional Administrator Jane M. Kenny. "That's why EPA has strict regulations
that must be followed whenever companies handle materials that could be harmful to
people and the environment."
Howmet failed to identify the used potassium hydroxide (KOH) sent off-site for use in
fertilizer as a hazardous waste and did nothing to ensure that it was managed properly.
Neither the trucking company that transported the KOH, nor the facility receiving it was
authorized to transport, treat, store, or dispose of hazardous waste. Howmet did not
prepare required manifests for the shipment of KOH. These manifests must identify the
type and quantity of the hazardous waste being carried and designate where the waste is
going, which must be a facility permitted to treat, store, and/or dispose of hazardous
waste. Finally, the company did not send or maintain certified notices to the receiving
manufacturing facility detailing whether any treatment of the KOH hazardous waste was
necessary. Howmet is no longer sending the KOH to fertilizer manufacturing facilities. The
company faces an $180,021 penalty for the violations, and has 30 days to respond to
EPA's complaint. In addition to seeking a penalty, EPA has ordered Howmet to comply
with all RCRA requirements for managing hazardous wastes when its used KOH is sent
off-site to be used in a manner constituting disposal, as in the production of fertilizer. The
company has the right to contest the complaint and the order.
Published: April 22, 1906
Copyright © The New York Times
Strategies for Managing the Nation’s
Inventory of Depleted Uranium Hexafluoride
The U.S. Department of Energy (DOE) is responsible for managing the nation’s stockpile of depleted
uranium hexafluoride (UF6 ), most of which is now stored at three DOE sites. EVS helped DOE
formulate and compare various long-term management alternatives and combinations of alternatives.
EVS’s effort focused on a programmatic environmental impact statement (PEIS), technical analyses,
decision-making tools, and a web site to facilitate information exchange with the public.
PROBLEM/OPPORTUNITY program, including the PEIS, supporting technical

analyses, developing and using decision-making
The first U.S. uranium enrichment effort began in tools, and public information and outreach efforts.
World War II as part of the Manhattan Project to
develop the atomic bomb. Enriched uranium, which APPROACH
is used in nuclear reactors as well as weapons, is
produced using the gaseous diffusion process. EVS’s approach to this management problem
Depleted UF6 is also produced in this process. The focused on developing a “cradle-to-grave” (i.e.,
depleted UF6 is currently stored at three DOE source to disposal, conversion, or use) strategy.
facilities at Portsmouth, Ohio; Paducah, Kentucky; Different types of activities and information had to
and Oak Ridge, Tennessee. Since World War II, be integrated to create a strategy DOE could
560,000 metric tons (46,422 cylinders) of U.S. implement. EVS was responsible for three primary
Government-produced depleted UF6 has areas: preparing the PEIS and supporting analyses;
accumulated at these sites. In addition, the developing decision-making tools; and facilitating
management of approximately 140,000 metric tons public information and outreach.
(11,400 cylinders) of depleted UF6 produced by the The PEIS is constructed from a set of activity
United States Enrichment Corporation (which modules that can be combined into an infinite
assumed responsibility for U.S. enrichment variety of alternative management strategies. The
operations in 1993) is being transferred to DOE over modules are based on engineering analysis.
time. Although DOE had been storing the depleted Environmental impacts are assessed for each module
UF6 with the intent of using it, a changing political as well as for collections of modules. This approach
environment and changing agency mission are provides DOE with the necessary decision-making
forcing DOE to rethink its management strategy. flexibility.
Since storage began in the early 1950's, many of the To conduct the technical analyses, EVS reviewed
cylinders now show evidence of external corrosion. state-of-the-art models, data, and approaches used to
Moreover, there have been eight breached cylinders, evaluate the health, safety, and environmental
with associated releases of hydrogen fluoride (HF) impacts associated with uranium and component
into the environment. The states of Kentucky, and chemicals. When data and models were inadequate,
particularly Tennessee and Ohio, have been EVS staff developed new approaches. For example,
concerned whether the material is being managed they designed a new computer model to evaluate
correctly. Therefore, in 1994, DOE began depleted UF6 cylinder accidents involving fires, and
reconsidering its management strategy. To support they estimated how exposure to uranium compounds
this activity, DOE has needed integrated planning, and chemicals used or manufactured during the
environmental, and engineering capabilities. EVS, processing of depleted UF6 affected human health.
with its experience in these areas, has helped DOE in
many areas of its depleted UF6 management One decision tool developed by EVS is a computer
program to facilitate DOE cylinder management
(CMS, Cylinder Management System). Another is FUTURE
the Comment Response Management System
(CRMS), a web-based tool that expedited DOE EVS used web technology to disseminate public
responses to government and public comments about information and to facilitate public outreach. It
the PEIS. The structure of the CRMS makes it developed the DUF6 web site to explain the program
applicable to all other projects requiring to the public and collect their comments. The use of
environmental impact statements. this site increased the public’s ability to participate
in the process and broadened the base of public
interest in the program as a whole. In the
RESULTS
implementation phase of the DUF6 Program, this site
EVS has been a major participant in helping DOE will be used to involve industry and regulators in
rethink its depleted UF6 management strategy. The program activities. (http://web.ead.anl.gov/uranium/)
information in the PEIS directly influenced DOE’s
initial decisions and will also affect subsequent
strategy implementation. By participating in the
program, EVS staff have developed expertise to
contribute to future DOE material management
activities. As the program moves into the
implementation phase, EVS will continue its
technical support to help DOE assess the
environmental, health, and safety risks associated
with its chosen depleted UF6 management strategy
and communicate its findings to the public and
regulators.
Typical depleted UF6 storage cylinder (Cylinders are constructed of

steel, with the majority of cylinders having a 14-ton capacity).
For more information, contact: J. Gasper • jgasper@anl.gov • Environmental Science Division EVS2
Argonne National Laboratory, 9700 South Cass Avenue, Bldg. 900, Argonne, IL 60439 • 202-488-2420
JANUARY 11 2005
BECHTEL JACOBS COMPANY LLC
New Remediation Contractors at Paducah and Portsmouth
The Department of Energy today named the new remediation contractors at Paducah and
Portsmouth. A link to the DOE news releases is provided below.
North Wind Paducah Cleanup Company LLC has been named the Paducah remediation
contractor. North Wind is a women-owned small business based in Idaho Falls. Additional
information about North Wind, Inc., is available at http://www.nwindenv.com.
The Portsmouth remediation contractor is LATA-Parallax Portsmouth LLC. LATA-Parallax

is owned by Los Alamos Technical Associates, Inc. http://www.lata.com/home.html, a New
Mexico-based engineering, environmental and nuclear operations services company, and
Parallax Inc., http://www.parallaxabq.com/, a Maryland-based engineering, environmental
and nuclear operations services company. LATA is a service-disabled veteran owned
small business and Parallax is a women-owned, minority owned small business.
DOE has not yet announced an award date for the infrastructure contracts.
We now enter a new phase of our work as we begin the transition that will lead to the
turnover of all remediation responsibilities. Your efforts to prepare for this transition has
put us in good stead for the weeks ahead. Our work is not finished, and we must maintain
our professionalism and our commitment to safety as we assist the new team.
In the coming weeks, we will work closely together to lay the foundation for the workforce
transition process. We expect to share additional information through e-mails and
employee meetings in the very near future. This period of change is also a period of
opportunity, and we intend to do everything we can to assist our employees during this
transition. Please ensure that you await direction from our BJC Manager of Transition and
the HR Department prior to initiating specific meetings on transition.
I know that you will respond to the challenge ahead with the determination and dedication
you have shown since Bechtel Jacobs took on this work in April 1998.
Les Hurst
Paducah and Portsmouth Transition
http://www.ohio.doe.gov/pppo_seb/remediation/index.html
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Bottled Water
Pure Drink or Pure Hype?
http://www.nrdc.org/water/drinking/bw/bwinx.asp
1. Isn't bottled water safer than tap water?
No, not necessarily. NRDC conducted a four-year review of the bottled water industry and
the safety standards that govern it, including a comparison of national bottled water rules
with national tap water rules, and independent testing of over 1,000 bottles of water. Our
conclusion is that there is no assurance that just because water comes out of a bottle it is
any cleaner or safer than water from the tap. And in fact, an estimated 25 percent or more
of bottled water is really just tap water in a bottle -- sometimes further treated, sometimes
not.
2. Is bottled water actually unsafe?
Most bottled water appears to be safe. Of the bottles we tested, the majority proved to be
high quality and relatively free of contaminants. The quality of some brands was spotty,
however, and such products may pose a health risk, primarily for people with weakened
immune systems (such as the frail elderly, some infants, transplant and cancer patients, or
people with HIV/AIDS). About 22 percent of the brands we tested contained, in at least one
sample, chemical contaminants at levels above strict state health limits. If consumed over
a long period of time, some of these contaminants could cause cancer or other health
problems.
3. Could the plastic in water bottles pose a health risk?
Recent research suggests that there could be cause for concern, and that the issue should
be studied closely. Studies have shown that chemicals called phthalates, which are known
to disrupt testosterone and other hormones, can leach into bottled water over time. One
study found that water that had been stored for 10 weeks in plastic and in glass bottles
contained phthalates, suggesting that the chemicals could be coming from the plastic cap
or liner. Although there are regulatory standards limiting phthalates in tap water, there are
no legal limits for phthalates in bottled water -- the bottled water industry waged a
successful campaign opposing the FDA proposal to set a legal limit for these chemicals.
4. How can I find out where my bottled water comes from?
A few state bottled water programs (e.g., Massachusetts and New York) maintain lists of
the sources of bottled water, but many do not. Try calling or writing the bottler to ask what
the source is, or call the bottled water program in your state or the state in which the water
was bottled to see if they have a record of the source (your state's health or agriculture
department is most likely to run the bottled water program). If you choose to buy bottled
water and are concerned about its safety, buy brands with a known protected source and
ones that make readily available testing and treatment information that shows high water
quality.
5. How can I determine if bottled water is really just tap water?
Often it's not easy. First, carefully check the bottle label and even the cap -- if it says "from
a municipal source" or "from a community water system" this means it's derived from tap
water. Again, you can call the bottler, or the bottled water program in your state or the
state where it was packaged.
6. What actions can I take to improve bottled water safety?
Write to your members of Congress, the FDA, and your governor (see below for contact
information) and urge them to adopt strict requirements for bottled water safety, labeling,
and public disclosure. Specifically, point out to these officials that they should:
• set strict limits for contaminants of concern in bottled water, including arsenic,
heterotrophic-plate-count bacteria, E. coli and other parasites and pathogens, and
synthetic organic chemicals such as "phthalates";
• apply the rules to all bottled water whether carbonated or not and whether sold
intrastate or interstate; and
• require bottlers to display information on their labels about the levels of

contaminants of concern found in the water, the water's exact source, how it's
been treated, and whether it meets health criteria set by the Environmental
Protection Agency and the Centers for Disease Control for killing parasites like
cryptosporidium.
Members of Congress and governors should also pass legislation providing the resources
for the FDA and state regulators to actually enforce the law.
To take further action, you can encourage your bottlers and the International Bottled Water
Association (a trade organization that includes about 85 percent of water bottlers) to
voluntarily make labeling disclosures such as those above.
Contact information:
FDA
Andrew C. von Eschenbach, M.D.
Commissioner, U.S. Food and Drug Administration
5600 Fishers Lane
Rockville, MD 20857
Congress/State Legislators
Go to our action center to find contact information for your members of Congress and
state legislators.
7. How does drinking bottled water affect the environment?
In 2006, the equivalent of 2 billion half-liter bottles of water were shipped to U.S. ports,
creating thousands of tons of global warming pollution and other air pollution. In New
York City alone, the transportation of bottled water from western Europe released an
estimated 3,800 tons of global warming pollution into the atmosphere. In California, 18
million gallons of bottled water were shipped in from Fiji in 2006, producing about 2,500
tons of global warming pollution.
And while the bottles come from far away, most of them end up close to home -- in a
landfill. Most bottled water comes in recyclable PET plastic bottles, but only about 13
percent of the bottles we use get recycled. In 2005, 2 million tons of plastic water bottles
ended up clogging landfills instead of getting recycled.
8. If I drink tap water should I use a filter and what types of filters are most effective?
The real long-term solution is to make tap water safe for everyone. However, if you know
you have a tap water quality or taste problem, or want to take extra precautions, you
should purchase filters certified by NSF International (800 NSF-MARK). These filters
designate which contaminants they remove, and you can look for one that removes any
contaminants of special concern such as cryptosporidium. Such certification is not
necessarily a safety guarantee, but it is better than no certification at all. It is critically
important that all filters be maintained and replaced at least as often as recommended by
the manufacturer, or they might make the problem worse. See our guide to water filters for
more information.
9. How can I obtain test results on my tap water?
Under new "right-to-know" provisions in the drinking water law, all tap water suppliers
must provide annual water quality reports to their customers. To obtain a copy, call your
water provider (the one that sends your water bills).
You also can test your water yourself, though this can be expensive. There are state-
certified drinking water laboratories in virtually every state that can test your water. Call
your state drinking water program or the EPA Safe Drinking Water Hotline (800 426-4791)
for a list of contacts. Standard consumer test packages are available through large
commercial labs at a relatively reasonable price.
Summary Findings of NRDC's 1999 Bottled Water Report

While bottled water marketing conveys images of purity, inadequate regulations offer no
assurance.
[En Español]
Sales of bottled water in this country have exploded in recent years, largely as a result of a
public perception of purity driven by advertisements and packaging labels featuring
pristine glaciers and crystal-clear mountain springs. But bottled water sold in the United
States is not necessarily cleaner or safer than most tap water, according to a four-year
scientific study recently made public by NRDC.
NRDC's study included testing of more than 1,000 bottles of 103 brands of bottled water.
While most of the tested waters were found to be of high quality, some brands were
contaminated: about one-third of the waters tested contained levels of contamination --
including synthetic organic chemicals, bacteria, and arsenic -- in at least one sample that
exceeded allowable limits under either state or bottled water industry standards or
guidelines.
A key NRDC finding is that bottled water regulations are inadequate to assure consumers
of either purity or safety, although both the federal government and the states have bottled
water safety programs. At the national level, the Food and Drug Administration is
responsible for bottled water safety, but the FDA's rules completely exempt waters that are
packaged and sold within the same state, which account for between 60 and 70 percent of
all bottled water sold in the United States (roughly one out of five states don't regulate
these waters either). The FDA also exempts carbonated water and seltzer, and fewer than
half of the states require carbonated waters to meet their own bottled water standards.
Even when bottled waters are covered by the FDA's rules, they are subject to less rigorous
testing and purity standards than those which apply to city tap water (see chart below).
For example, bottled water is required to be tested less frequently than city tap water for
bacteria and chemical contaminants. In addition, bottled water rules allow for some
contamination by E. coli or fecal coliform (which indicate possible contamination with
fecal matter), contrary to tap water rules, which prohibit any confirmed contamination with
these bacteria. Similarly, there are no requirements for bottled water to be disinfected or
tested for parasites such as cryptosporidium or giardia, unlike the rules for big city tap
water systems that use surface water sources. This leaves open the possibility that some
bottled water may present a health threat to people with weakened immune systems, such
as the frail elderly, some infants, transplant or cancer patients, or people with HIV/AIDS.
Some Key Differences Between EPA Tap Water and FDA Bottled Water Rules
Water Dis- Confirmed Testing Must Must Test Testing Frequency
Type infection E. Coli & Frequency Filter to for for Most Synthetic
Required? Fecal for Remove Crypto- Organic Chemicals
Coliform Bacteria Pathogens, sporidium,
Banned? or Have Giardia,
Strictly Viruses?
Protected
Source?
Bottled No No 1/week No No 1/year

Water
Carbonated No No None No No None
or Seltzer
Water
Big City Yes Yes Hundreds/ Yes Yes 1/quarter
Tap Water month (limited waivers
(using available if clean
surface source)
water)
See Table 1 of NRDC's bottled water report for further comparisons and explanations.
Ironically, public concern about tap water quality is at least partly responsible for the
growth in bottled water sales, which have tripled in the past 10 years. This bonanza is also
fueled by marketing designed to convince the public of bottled water's purity and safety,
marketing so successful that people spend from 240 to over 10,000 times more per gallon
for bottled water than they typically do for tap water.
In fact, about one-fourth of bottled water is actually bottled tap water, according to
government and industry estimates (some estimates go as high as 40 percent). And FDA
rules allow bottlers to call their product "spring water" even though it may be brought to
the surface using a pumped well, and it may be treated with chemicals. But the actual
source of water is not always made clear -- some bottled water marketing is misleading,
implying the water comes from pristine sources when it does not. In 1995, the FDA issued
labeling rules to prevent misleading claims, but while the rules do prohibit some of the
most deceptive labeling practices, they have not eliminated the problem.
Some examples of interesting labels NRDC observed include:
"Spring Water" (with a picture of a lake surrounded by mountains on the label) -- Was
actually from an industrial parking lot next to a hazardous waste site.
Alasika™ -- "Alaska Premium Glacier Drinking Water: Pure Glacier Water From the Last
Unpolluted Frontier, Bacteria Free" -- Apparently came from a public water supply. This
label has since been changed after FDA intervention.
Vals Water -- "Known to Generations in France for its Purity and Agreeable Contribution to
Health . . . Reputed to Help Restore Energy, Vitality, and Combat Fatigue" -- The
International Bottled Water Association voluntary code prohibits health claims, but some
bottlers still make such claims.
NRDC makes the following recommendations for improving bottled water safety
precautions:
• The FDA should set strict limits for contaminants of concern in bottled water.
• The FDA's rules should apply to all bottled water distributed nationally or within a
state, carbonated or not, and bottled water standards must be made at least as
strict as those applicable to city tap water supplies.
• Water bottlers should be required to disclose water source, treatments and other
key information as is now required of tap water systems.
• A penny-per-bottle fee should be initiated on bottled water to fund testing,
regulatory programs, and enforcement at both state and national levels.
• State bottled water programs should be subject to federal review.
Ultimately, however, while Americans who choose to buy bottled water deserve the
assurance that it is safe, the long-term solution to our drinking water problems is to
ensure that safe, clean, good-tasting drinking water comes from our taps. Those who are
particularly concerned about the quality of their tap water can take action by 1) calling
their state drinking water program or the EPA Safe Drinking Water Hotline (800 426-4791)
for a list of state certified labs; and 2) purchasing filters certified by NSF International (800
NSF-MARK) to remove the contaminants of special concern to the consumer (NSF
certification is not, however, a complete guarantee of safety).
Based on BOTTLED WATER: Pure Drink or Pure Hype? a March 1999 report by the Natural Resources Defense Council
(which includes a chart of our test results). See also the bottled water FAQ.
last revised 4.29.99

Appendix A
SUMMARY OF NRDC'S TEST RESULTS

Bottled Water Contaminants Found
Brand(a T Water Purch Source Contaminant & Level Found(b) Numb Lab Comments
) es Type ase of er of Rep
t Locati Water Bottles . #
# on (if Tested
listed)
HPC Arse TTH Chlor BDC DB Phthalate Nitr Other
Bacter nic(d Ms(e) oform M(f) CM (DEHP) ate
ia(c) ) (CA (CA (CA (g) (Tap water (Fed
(Guide (CA & Prop. Prop. (CA standard 6 .&
lines Prop. Indus 65 65 Prop ppb) no CA
500 65 try Level Leve . 65 bottled stan
cfu/ml; Level bottle l0 l 2.5 Lev water dard
no 5 d ppb) ppb) el standard 10
enforc ppb) water in ppb in 3.5 ppm
eable in stand ppb ppb) ) in
standar ppb ard in ppm
d) in 10 ppb
cfu/ml ppb)
in
ppb
365 1 Natur Berkel Bottled Not Not Not Not Not Not Not Res 10 SA-
al ey, in Detect Detec Detec Detect Dete Dete Detected ults (comp 711-
Spring CA Austin, ed ted ted ed cted cted not osited) 140
Water TX rece 2
(1.5 ived
liters)
Albertso 1 Natur San Palomar Not Not Not Not Not Not Not 0.8 10 SA-
n's A+ al Diego/ Mtn. Detect Detec Detec Detect Dete Dete Detected (comp 712-
Spring San Spring ed ted ted ed cted cted osited) 039
Water Marco 0
(1 s, CA
liter)
Alhamb 1 Crysta San McKess 45 Not Not Not Not Not Not 0.1 Toluene 3 (1 EQI Toluene and
ra l Franci on Detec Detec Detect Dete Dete Detected detected for -1- o-xylene are
Fresh sco Water ted ted ed cted cted at 12.5 each 27- industrial
Drinki Prod., ppb contam 29 chemicals
ng Pasaden o- inant found at
Water a, CA xylene type) levels below
(1 at 2.7 standards.
gal.) ppb Bottle
claims
"purified
using. .
.filtration,
ozonation,
reverse
osmosis,
and/or
deionization
."
Alhamb 2 Crysta San McKess 56 Not Not Not Not Not Not Res No 10 SA-
ra l Franci on Detec Detec Detect Dete Dete Detected ults toluene (comp 711-
Fresh sco Water ted ted ed cted cted not or osited) 140
Drinki Prod., rece xylene 3
ng Pasaden ived detected
Water a, CA
(1
liter)
Alhamb 1 Sport San McKess Not Not Not Not Not Not Not 0.1 3 (1 EQI
ra Top Franci on Detect Detec Detec Detect Dete Dete Detected for -1 -
Crysta sco Water ed ted ted ed cted cted each 33a-
l Prod., contam f
Fresh Pasaden inant
Drinki a, CA type)
ng
Water
(16.9
fl. oz.)
Alhamb 1 Mount San McKess >5700 Not Not Not Not Not Not Not Colifor 3 (1 EQI HPC
ra*† ain Franci on † Detec Detec Detect Dete Dete Detected Dete ms for -1- bacteria in
Spring sco Water ted ted ed cted cted cted found at each 30- excess of
Water, Prod., >200* contam 32 guideline,
"prepa Pasaden inant and
red a, CA type) coliforms in
using excess of
filtrati FDA
on standards.
and
ozone
" (1
gal.)
Alhamb 2 Mount San McKess 1100† Not Not Not Not Not Not Res No 10 SA- HPC
ra† ain Franci on Detec Detec Detect Dete Dete Detected ults colifor (comp 711- bacteria in
Spring sco Water ted ted ed cted cted not ms osited) 140 excess of
Water Prod., rece detected 4 guideline.
(1 Pasaden ived
gallon a, CA
)
Apollin 1 Sparkl Berkel Bad Not 5.6* Not Not Not Not Not Res Fluoride 10 SA- Arsenic
aris* ing ey, Neuenah Detect Detec Detect Dete Dete Detected ults found at (comp 711- level
Miner CA r- ed ted ed cted cted not 0.37 osited) 140 exceeds CA
al Ahrweil rece ppm, 5 Prop. 65
Water er, ived below level.
(1 German std.
liter) y
Apollin 2 Sparkl No test 7.8* No No No No No test No 10 SA- Arsenic
aris* ing test test test test test (comp 806- level
Miner osited) 207 exceeds CA
al 8 Prop. 65
Water level.
Aquafin 1 Purifi Los Not Not Not Not Not Not Not Not 3 (1 EQI
a ed Angel Detect Detec Detec Detect Dete Dete Detected Dete for -1-
Drinki es ed ted ted ed cted cted cted each LA6
ng contam -
Water inant LA8
-- type)
"Purit
y
Guara
nteed"
Non-
Carbo
nated
(1
liter)
# on (if Tested
listed)
d) in 10 ppb
cfu/ml ppb)
in
ppb
Aquafin 1 Purifi Berkel Laurel Not Not Not Not Not Not Not Res 10 SA-
a ed ey, Bottling Detect Detec Detec Detect Dete Dete Detected ults (comp 711-
Drinki CA Co, ed ted ted ed cted cted not osited) 140
ng Fresno, rece 6
Water CA ived
--
"Purit
y
Guara
nteed"
(1
liter)
Aquafin 1 Purifi Houst City of Not Not 4.1 3.5 0.6 Not 5 ppb (just Not Di(2- 10 298 Pthalate
a ed on, Houston Detect Detec Dete below 6 Dete ethylhe (comp 808- (DEHP) is
Drinki TX Water ed ted cted ppb tap cted xyl) osited) 965 often
ng Supply water adipate (944 present as a
Water standard) found at - result of
0.9 ppb 949) migration
( below from the
standard bottle to the
of 400 water. The
ppb) level
detected is
just below
the EPA tap
water
standard for
this
chemical,
though there
is no bottled
water
standard
(see text).
Aquafin 2 Purifi Houst City of Not No No No No No No test No 10 298- HPC
a ed on, Houston Detect test test test test test test bottles, 808- bacteria test,
Drinki TX Water ed individ 965 none found
ng Supply ually (934 in 10
Water - bottles.
943)
Arrowh 1 Mount San Arrowhe Not 3.2 Not Not Not Not Not 1.2 3 (1 EQI
ead ain Franci ad Detect Detec Detect Dete Dete Detected for -1-
Spring sco MSW ed ted ed cted cted each 37a-
Water Co., contam f
L.A., inant
CA type)
Arrowh 2 Mount Berkel Arrowhe 5 Not Not Not Not Not Not Res 10 SA-
ead ain ey, ad Detec Detec Detect Dete Dete Detected ults (comp 711-
Spring CA MSW ted ted ed cted cted not osited) 140
Water Co., rece 7
(1.5 L.A., ived
liter) CA
Arrowh 3 Mount Los Not Not Not 4.3 1.9 1.6 0.8 Not 1.0 10 SA
ead ain Angel noted Detect Detec Detected (comp 712-
Spring es ed ted osited) 080
Water 7
(5
gallon
)
Arrowh 1 Sparkl San Arrowhe Not 3.1 Not Not Not Not Not 0.8 3 (1 EQI
ead ing Franci ad Detect Detec Detect Dete Dete Detected for -1-
Mount sco MSW ed ted ed cted cted each 34-
ain Co., contam 36
Spring L.A., inant
Water CA type)
(1.5
liter)
Arrowh 2 Sparkl Berkel Arrowhe Not Not 1.1 1.1 Not Not Not Res 10 SA-
ead ing ey, ad Detect Detec Dete Dete Detected ults (comp 711-
Mount CA MSW ed ted cted cted not osited) 140
ain Co., rece 8
Spring L.A. , ived
Water CA
(1.5
liter)
Beechnu 1 Water, San Palomar Not Not Not Not Not Not Not Not Fluoride 10 SA-
t Fluori Dimas Mountai Detect Detec Detec Detect Dete Dete Detected Dete at 0.71 (comp 712-
de , CA n, ed ted ted ed cted cted cted ppm osited) 039
Added bottled 2
(1 by
gallon Famous
) Ramona
,
Ramona
, CA
Black 1 Distill Berkel Black 1000† Not 4 1.4 1.8 0.8 Not Res 10 SA- Level of
Mounta ed ey, Mtn. Detec Detected ults (comp 711- HPC
in† Water CA Wtr.Co., ted not osited) 140 bacteria
(1 San rece 9 exceeds
gallon Carlos, ived guideline.
) CA
# on (if Tested
listed)
d) in 10 ppb
cfu/ml ppb)
in
ppb
Black 2 Distill Not No No No No No No test No No total 10 SA No HPC
Mountai ed Detect test test test test test test colifor (tested 806- bacteria
n Water ed ms individ 207 detected.
ually) 9
Black 1 Fluori Berkel Black 2100† Not 2.4 1.1 1.3 Not Not Res Fluoride 10 SA- Fluoride
Mounta dated ey, Mtn. Detec Dete Detected ults found at (comp 711- above
in† Water CA Wtr.Co., ted cted not 0.93 osited) 141 standard of
(1 San rece ppm* 0 0.8 ppm for
gallon Carlos, ived (exceed added
) CA s fluoride in
standard areas with
in warm average high
areas) temp. of
79.3°F.
HPC
bacteria
over
guideline
level of 500
cfu/ml.
Black 2 Fluori 18,000 No No No No No No test No No total 10 SA 1 bottle of
Mounta dated † test test test test test test colifor (indivi 806- 10 contained
in† Water (1bottl ms dually) 208 HPC level
e) 0 well over
30 (1 guideline
bottle) level.
Not
Detect
ed (8
bottles
)
Black 3 Fluori No test No No No No No No test No Fluoride 4 901- Fluoride
Mountai dated test test test test test test found at (comp 079 above
n Water 1.3 ppm osited) standard of
(exceed 0.8 ppm for
s added
standard fluoride in
in warm warm
areas) weather
areas
(average
high over
79°F).
Black 1 Purifi Berkel Black Not Not 2.3 1.1 1.2 Not Not Res 10 SA-
Mountai ed ey, Mtn. Detect Detec Dete Detected ults (comp 711-
n Water CA Wtr.Co., ed ted cted not osited) 141
(1 San rece 1
gallon Carlos, ived
) CA
Black 1 Spring San Black >5,700 3.6 Not Not Not Not Not 0.2 Total 3 (1 EQI Levels of
Mounta Water Franci Mtn. † Detec Detect Dete Dete Detected colifor for -1- HPC
in*† (1 sco Wtr.Co., ted ed cted cted m count each 19- bacteria
gallon San 27*; contam 20 exceed
) Carlos, Toluene inant guidelines.
CA found at type) Coliforms
8.9 ppb exceed FDA
standards.
Toluene is a
component
of gasoline
or industrial
chemicals.
Black 2 Spring San Black 330 Not Not Not Not Not Not Not No total 10 SA-
Mountai Water Franci Mtn. Detec Detec Detect Dete Dete Detected Dete colifor (comp 712-
n (5 sco Wtr.Co., ted ted ed cted cted cted ms or osited) 084
gal.) San toluene 6
Carlos, detected
CA
Black 3 Spring Berkel Black 80 Not Not Not Not Not Not Not No total 10 SA-
Mountai Water ey, Mtn. Detec Detec Detect Dete Dete Detected Dete colifor (comp 711-
n (1 CA Wtr.Co., ted ted ed cted cted cted ms or osited) 157
gallon San toluene 7
) Carlos, detected
CA
Calistog 1 Distill Berkel Calistog Not Not Not Not Not Not Not Not 10 SA-
a ed ey, a MW Detect Detec Detec Detect Dete Dete Detected Dete (comp 711-
Water CA Co., ed ted ted ed cted cted cted osited) 157
(1 Calistog 8
gallon a, CA
)
Calistog 1 Mount San Calistog Not Not Not Not Not Not Not 0.8 3 (1 EQI
a ain Franci a MW Detect Detec Detec Detect Dete Dete Detected for -1-
Spring sco Co., ed ted ted ed cted cted each 1a-f
Water Calistog contam
(0.5 a, CA inant
liter) type)
# on (if Tested
listed)
d) in 10 ppb
cfu/ml ppb)
in
ppb
Calistog 2 Mount Oakla Calistog 4900† Not Not Not Not Not Not 0.6 10 SA- HPC
a† ain nd, a MW Detec Detec Detect Dete Dete Detected (comp 712- bacteria
Spring CA Co., ted ted ed cted cted osited) 084 found at
Water Calistog 7 levels
(6 a, CA substantially
gal.) exceeding
guideline.
Calistog 3 Mount San Calistog Not Not Not Not Not Not Not 0.5 10 SA-
a ain Franci a MW Detect Detec Detec Detect Dete Dete Detected (comp 711-
Spring sco Co., ed ted ted ed cted cted osited) 157
Water Calistog 9
(1 a, CA
liter)
Calistog 4 Mount Not No No No No No No test No No total 10 SA HPC
a ain Detect test test test test test test colifor (indivi 806- bacteria
Spring ed to 1 ms dually) 208 within
Water cfu/ml 1 guidelines in
all bottles
tested.
Calistog 1 Sparkl San Napa 3 31.8* Not Not Not Not Not 0.1 3 (1 EQI Arsenic
a* ing Franci Valley Detec Detect Dete Dete Detected for -1- level
Miner sco ted ed cted cted each 2-4 exceeds CA
al contam Prop. 65
Water, inant limit.
Origin type)
al
Napa
Valley
(1
liter)
Calistog Sparkl San Napa No test Not No No No No No test No 8 SA- Arsenic
a ing Franci Valley Detec test test test test test (comp 901- retest found
Miner sco ted osited) 079 none
al 7
Water,
Origin
al
Napa
Valley
Calistog 1 Sparkl San Calistog Not Not Not Not Not Not Not Not 10 SA-
a ing Franci a MW Detect Detec Detec Detect Dete Dete Detected Dete (comp 711-
Miner sco Co., ed ted ted ed cted cted cted osited) 158
al Calistog 0
Water a, CA
(1
liter)
Calistog 2 Sparkl No test Not No No No No No test No 10 SA
a ing Detec test test test test test (comp 806-
Miner ted osited) 207
al 8
Water
Canada 1 Club Berkel Cadbury Not Not Not Not Not Not Not 0.6 10 SA-
Dry Soda ey, Beverag Detect Detec Detec Detect Dete Dete Detected (comp 711-
(1 CA es ed ted ted ed cted cted osited) 158
liter) Stamfor 1
d, CT
Canada 1 Sparkl San Cadbury 1.0 Not Not Not Not Not Not Not Fluoride 10 SA-
Dry ing Franci Beverag Detec Detec Detect Dete Dete Detected Dete found at (comp 711-
Water sco es ted ted ed cted cted cted 0.13 osited) 158
(1 Stamfor ppm, 2
liter) d, CT well
below
std.
Castle 1 "Sprin San "The Not Not Not Not Not Not Not Not 3 (1 EQI
Rock g Franci Cascade Detect Detec Detec Detect Dete Dete Detected Dete for -1-
Water sco Mountai ed ted ted ed cted cted cted each 16-
Bottle ns" contam 18
d at inant
the type)
Sourc
e" (1
liter)
# on (if Tested
listed)
d) in 10 ppb
cfu/ml ppb)
in
ppb
Cobb 1 Natur Berkel Cobb Not Not 1.2 Not Not Not Not Not Bromof 10 SA-
Mountai al ey, Mtn. Detect Detec Detect Dete Dete Detected Dete orm (a (comp 711-
n Spring CA Spring ed ted ed cted cted cted trihalom osited) 158
Water Water ethane) 3
(1.5 Co., found at
liter) Cobb, 1.2 ppb,
CA below
standard
Crystal 1 Alpin San CG 460 17.8* Not Not Not Not Not 3 (1 EQI Arsenic
Geyser* e Franci Roxane click Detec Detect Dete Dete Detected for -1- level
Spring sco source, for ted ed cted cted each 26a- exceeds CA
Water Eastern updat contam f Prop. 65
(16.9 Sierra, e inant limit.
oz.) bottled type)
at
Olancha
, CA
Crystal 2 Alpin San CG Not 11* Not Not Not Not Not Not Fluoride 10 SA- Arsenic
Geyser* e Franci Roxane Detect click Detec Detect Dete Dete Detected Dete found at (comp 711- level
Spring sco source, ed for ted ed cted cted cted 0.82 osited) 158 exceeds CA
Water Eastern updat ppm 5 Prop. 65
(1 Sierra, e limit;
liter) Olancha fluoride
, CA level is
below
standard of
1.4 ppm in
warm areas
(if natural)
but above
the warm
area
standard of
0.80 ppm if
added.
Crystal 3 Alpin No test 12* No No No No No test No 10 SA Arsenic
Geyser* e click test test test test test (comp 806- exceeds
Spring for osited) 207 Prop. 65
Water updat 8 limit and
e WHO/EU
standard.
Crystal 1 Napa San Napa 1 35.2* Not Not Not Not Not 0.2 3 (1 EQI Arsenic
Geyser* Valley Franci Valley click Detec Detect Dete Dete Detected for -1- exceeds
Sparkl sco for ted ed cted cted each 25a- Prop. 65
ing updat contam f limit.
Miner e inant
al type)
Water
Bottle
d at
the
Sourc
e (12
fl. oz.)
Crystal 2 Napa No test Not No No No No No test No 10 SA No arsenic
Geyser Valley Detec test test test test test (comp 806- detected.
Sparkl ted osited) 207
ing 8
Miner
al
Water
Crystal 3 Napa No test 14 No No No No No test No No test 10 SA- Arsenic
Geyser* Valley ppb test test test test test (comp 901- exceeds CA
Sparkl click osited) 079 Prop. 65
ing for 8 limit and
Miner updat WHO/EU
al e standard.
Water
Crystal 1 Sparkl Berkel Crystal Not Not Not Not Not Not Not Not 10 SA-
Geyser ing ey, Geyser Detect Detec Detec Detect Dete Dete Detected Dete (comp 711-
Miner CA Water ed ted ted ed cted cted cted osited) 158
al Compan 4
Water y,
(1 Calistog
liter) a, CA
Crystal 1 (1 Chica Not Not Not Not Not Not Not Not 10 297
Geyser liter) go, IL Detect Detec Detec Detect Dete Dete Detected Dete (comp 719-
ed ted ted ed cted cted cted osited) 48
(43-
48)
Crystal 1 (1 Chica Not No No No No No No test No 9 297
Geyser liter) go, IL Detect test test test test test test (indivi 790-
ed dually) 836
(810
-
818)
# on (if Tested
listed)
d) in 10 ppb
cfu/ml ppb)
in
ppb
Dannon 1 Natur San Piedmon 6 Not Not Not Not Not Not 0.8 3 (1 EQI
al Franci t, Detec Detec Detect Dete Dete Detected for -1-
Spring sco Quebec, ted ted ed cted cted each 24a-
Water Canada contam f
(1.05 inant
pint ) type)
Dannon 2 Natur San Piedmon 330 Not Not Not Not Not Not 0.8 10 SA-
al Franci t, Detec Detec Detect Dete Dete Detected (comp 711-
Spring sco Quebec, ted ted ed cted cted osited) 169
Water Canada 6
(1
liter)
Dannon 3 Natur New Piedmon Not Not Not Not Not Not Not 1.2 Di-n- 10 299 Pthalate
al York t, Detect Detec Detec Detect Dete Dete Detected butyl- (comp 863- may be from
Spring City Quebec, ed ted ted ed cted cted pthalate osited) 942 leaching
Water Canada at 7.5 (911 from bottle
ppb; - top or other
Methyle 916) packaging
ne materials;
chloride methylene
at 1.5 chloride of
ppb unknown
(below origin, and
5ppb at 30% of
statanda FDA
rd) standard.
Dannon 4 Natur New Piedmon 2 of 10 No No No No No No test No 10 299 Bacterial
† al York t, bottles test test test test test test (indivi 863- overgrowth
Spring City Quebec, tested dually) 942 was
Water Canada contain (917 observed in
ed - 2 of the 10
HPC 926) bottles
bacteri tested. The
al presence of
overgr a large
owth† number of
noncoliform
HPC
bacteria may
be inhibiting
the detection
of coliform
bacteria
during the
testing. See
text for
discussion
of HPC
bacteria.
Deer 1 Spring New Valley Not Not Not Not Not Not Not Not 10 299
Park Water York View Detect Detec Detec Detect Dete Dete Detected Dete (comp 863-
(1 City Spring, ed ted ted ed cted cted cted osited) 942
liter) Hegins (879
Twp., -
PA 884)
Deer 2 Spring New Valley Not No No No No No No test No 10 299
Park Water York View Detect test test test test test test (indivi 863-
(1 City Spring, ed dually) 942
liter) Hegins (885
Twp., -
PA 894)
Deer 3 Spring Washi Hegin Not Not Not Not Not Not Not Not 10 298
Park Water ngton Townshi Detect Detec Detec Detect Dete Dete Detected Dete (comp 808-
(1.5 DC p, PA ed ted ted ed cted cted cted osited) 965
liter) (879
-
884)
Deer 4 Spring Washi Hegin Not No No No No No No test No 10 298
Park Water ngton Townshi Detect test test test test test test (indivi 808-
(1.5 DC p, PA ed dually) 965
liter) (869
-
878)
Dominic 1 Natur Chica Not Not Not Not Not Not Not 0.6 10 297
k's al go, IL Detect Detec Detec Detect Dete Dete Detected (comp 719-
Spring ed ted ted ed cted cted osited) 48
Water (31-
(1.5 36)
liter)
Dominic 2 Natur Chica Not No No No No No No test No 9 297
k's al go, IL Detect test test test test test test (indivi 790-
Spring ed dually) 836
Water (828
(1.5 -
liter) 836)
# on (if Tested
listed)
d) in 10 ppb
cfu/ml ppb)
in
ppb
Evian 1 Natur San Cachat 21 2.0 Not Not Not Not Not 0.7 3 (1 EQI
al Franci Springs, Detec Detect Dete Dete Detected for -1-
Spring sco, Evian, ted ed cted cted each 21-
Water CA France contam 23
(1 inant
liter) type)
Evian 2 Natur San Cachat 63 Not Not Not Not Not Not 0.8 10 SA-
al Franci Springs, Detec Detec Detect Dete Dete Detected (comp 711-
Spring sco, Evian, ted ted ed cted cted osited) 169
Water CA France 7
(1
liter)
Fiuggi 1 Natur Berkel A.S.T.I. 7 Not Not Not Not Not Not 2.5 10 SA-
al ey, F., Detec Detec Detect Dete Dete Detected (comp 711-
Miner CA Fiuggi, ted ted ed cted cted osited) 169
al Italy 8
Water
(1
liter)
Gerber 1 Baby Berkel AquaPe 2 Not Not Not Not Not Not 0.6 Fluoride 10 SA-
Water ey, nn Detec Detec Detect Dete Dete Detected found at (comp 711-
with CA Springs, ted ted ed cted cted 0.46 osited) 169
Fluori Graysvil ppm, 9
de le, PA below
(1.5 standard
liter)
Gerolste 1 Sprud Berkel Gerolste Not Not Not Not Not Not Not 1.0 10 SA-
iner el ey, in, Detect Detec Detec Detect Dete Dete Detected (comp 711-
Sparkl CA German ed ted ted ed cted cted osited) 170
ing y 0
Miner
al
Water
(1
liter)
Glacier 1 Purifi Miami Not Not 1.6 1.6 Not Not Not Not Alumin 10 304 Aluminum
Springs ed , FL Detect Detec Dete Dete Detected Dete um (comp 085- found at 180
Water ed ted cted cted cted found at osited) 165 ppb, just
(1 180 ppb (150 below the
gallon (std. is - 200 ppb
) 200 155) FDA bottled
ppb) water
standard, set
based on
taste, odor,
and
aesthetic
concerns.
FDA's
standard for
aluminum is
not
applicable to
mineral
water, but is
applicable to
purified
water.
Glacier 2 Purifi Miami HPC No No No No No No test No 10 304 Bacterial
Springs ed , FL bacteri test test test test test test (indivi 085- overgrowth
† Water al dually) 165 was
overgr (304 observed in
owth 156- 1 of the 10
detecte 304 bottles
d in 1 165) tested. The
of 10 presence of
bottles a large
tested† number of
noncoliform
HPC
bacteria may
be inhibiting
the detection
of coliform
bacteria
during the
testing. See
text for
discussion
of HPC
bacteria.
Hawaii 1 Purifi Berkel Menehu Not Not Not Not Not Not Not Not 10 SA-
ed ey, neWater Detect Detec Detec Detect Dete Dete Detected Dete (comp 711-
Drinki CA Co, ed ted ted ed cted cted cted osited) 170
ng Aiea, HI 1
Water
(1.5
liters)
Hildon 1 Miner Berkel Brought Not Not Not Not Not Not Not 5.6 10 SA- Elevated
al ey, on, Detect Detec Detec Detect Dete Dete Detected (comp 711- nitrate level,
Water CA Hampsh ed ted ted ed cted cted osited) 170 though
- ire, 2 below FDA
Carbo England standard, of
nated potential
(750 concern--see
ml) text.
Hildon 2 Miner Berkel Brought No test No No No No No No test 5.4 10 SA Retest of
al ey, on, test test test test test (comp 808- elevated
Water CA Hampsh osited) 166 nitrate level;
- ire, 3 below FDA
nated potential
(750 concern--see
ml) text.
# on (if Tested
listed)
d) in 10 ppb
cfu/ml ppb)
in
ppb
Hildon 1 Miner Berkel Brought 200 Not Not Not Not Not Not 5.6 10 SA- Elevated
al ey, on, Detec Detec Detect Dete Dete Detected (comp 711- nitrate level,
Water CA Hampsh ted ted ed cted cted osited) 170 though
-Still ire, 3 below FDA
(750 England standard, of
ml) potential
concern--see
text.
Hinckle 1 (1 Chica Not Not Not Not Not Not Not 1.9 10 297
y gallon go, IL Detect Detec Detec Detect Dete Dete Detected (comp 719-
Schmidt ) ed ted ted ed cted cted osited) 48
(25-
30)
Hinckle 2 (1 Chica Not No No No No No No test No 10 297
y gallon go, IL Detect test test test test test test (indivi 790-
Schmidt ) ed dually) 836
(790
-
799)
Hyde 1 Purifi Miami >5700 Not 2.2 2.1 0.1 Not Not Not 10 304 Level of
Park† ed , FL † Detec Dete Detected Dete (comp 085- HPC
Water ted cted cted osited) 165 bacteria
(1 (101 substantially
gallon - exceeded
) 106) guideline.
Hyde 2 Purifi Miami Not No No No No No No test No 10 304 Retest for
Park ed , FL Detect test test test test test test (indivi 085- HPC
Water ed dually) 165 bacteria in
(304 10 bottles
107- found none
304
116)
Ice Age 1 "Glaci Berkel Alpine 67 Not Not Not Not Not Not Not 10 SA-
al ey, Creek, Detec Detec Detect Dete Dete Detected Dete (comp 711-
Water CA Manitob ted ted ed cted cted cted osited) 170
" (1 a Inlet, 4
liter) Canada
Janet 1 Drinki San Albertso Not Not Not Not Not Not Not 0.7 10 SA-
Lee ng Diego/ ns, Detect Detec Detec Detect Dete Dete Detected (comp 712-
Water San Boise, ed ted ted ed cted cted osited) 039
(1 Marco ID, 3
gallon s, CA distrib.
)
Janet 1 Purifi San Albertso Not Not Not Not Not Not Not Not 10 SA-
Lee ed Diego/ ns, Detect Detec Detec Detect Dete Dete Detected Dete (comp 712-
Water San Boise ed ted ted ed cted cted cted osited) 039
(1 Marco ID, 4
)
Janet 1 Spring San Albertso 41 Not Not Not Not Not Not Not 10 SA-
Lee Water Diego/ ns, Detec Detec Detect Dete Dete Detected Dete (comp 712-
(1 San Boise ted ted ed cted cted cted osited) 039
gallon Marco ID, 5
) s, CA distrib.
Jewel 1 Artesi Chica Not 1.1 Not Not Not Not Not Not 10 297
an go, IL Detect Detec Detect Dete Dete Detected Dete (comp 719-
Water ed ted ed cted cted cted osited) 48
(1 (19-
gallon 24)
)
# on (if Tested
listed)
d) in 10 ppb
cfu/ml ppb)
in
ppb
Jewel 2 Artesi Chica Not No No No No No No test No 10 298
an go, IL Detect test test test test test test (indivi 808-
Water ed dually) 965
(1 (800
gallon -
) 809)
Kroger 1 Utopi Houst Indian 1 Not Not Not Not Not Not 0.9 10 298
a on, Springs, Detec Detec Detect Dete Dete Detected (comp 808-
Spring TX Franklin ted ted ed cted cted osited) 965
Water County, (928
(1 TX -
liter) 933)
Kroger 2 Utopi Houst Indian Not No No No No No No test No 10 298
a on, Springs, Detect test test test test test test (indivi 808-
Spring TX Franklin ed dually) 965
Water County, (918
(1 TX -
liter) 927)
Lady 1 Natur San Not Not Not Not Not Not Not Not Toluene 3 (1 EQI Toluene and
Lee al Franci Detect Detec Detec Detect Dete Dete Detected Dete at 13.9 for -1- xylene are
Spring sco ed ted ted ed cted cted cted ppb; o- each 53- constituents
Water xylene contam 55 of gasoline
(1 at 3.0 inant and also
gallon ppb type) used in
) some
industrial
chemicals.
Lucky 2 Natur San Plant 20 Not Not Not Not Not Not Not No 10 SA-
(aka al Franci #06-21 Detec Detec Detect Dete Dete Detected Dete toluene (comp 712-
Lady Spring sco ted ted ed cted cted cted or osited) 002
Lee) Water xylene 5
(1 detected
gallon
)
Lady 3 Natur No test No Not Not Not Not No test No Toluene 10 SA-
Lee al test Detec Detect Dete Dete test at 0.55 (comp 806-
Spring ted ed cted cted ppb, no osited) 208
Water xylene 6
detected
Lady 1 Purifi San Not 6.5* 54.8* 54.8* Not Not Not 0.1 Toluene 3 (1 EQI Arsenic and
Lee* ed Franci Detect Dete Dete Detected at 9.5 for -1- chloroform
Water sco ed cted cted ppb; each 50- at levels
purifie ethyl- contam 52 above CA
d by benzene inant Prop. 65
deioni at 2.0 type) levels.
zation ppb; TTHMs
(1 m/p- above CA
gallon xylene and industry
) at 3.1 standard of
ppb; o- 10 ppb.
xylene Toluene and
at 6.3 xylene are
ppb gasoline
constituents
and also
used in
some
industrial
chemicals.
Lucky 2 Purifi San Plant 1 Not 1.1 1.1 Not Not Not Not 10 SA-
(aka ed Franci #06-21 Detec Dete Dete Detected Dete (comp 712-
Lady Water sco ted cted cted cted osited) 002
Lee) (1 6
gallon
)
Lady 3 Purifi San Not Not Not Not Not Not No test No Methyle 3 (1 SA- Methylene
Lee ed Franci Detect Detec Detec Detect Dete Dete test ne for 808- chloride at
Water sco ed ted ted ed cted cted chloride each 166 level just
purifie at 4.1 contam 6 below
d by ppb inant federal
deioni (std. is type) standard.
zation 5 ppb)
(1
gal.)
Lady 1 Drinki San Not 3.2 91.6* 88.9* 2.7* Not Not 0.1 Toluene 3 (1 EQI THM levels
Lee* ng Franci Detect Dete Detected at 11.0 for -1- in excess of
Water sco ed cted ppb; each 56- CA &
(1 o- contam 58 industry
gallon xylene inant standards;
) at 2.9 type) chloroform
ppb and
bromodichlo
romethane
in excess of
CA Prop. 65
level.
Toluene and
xylene are
gasoline
constituents
and also
used in
industrial
chemicals.
# on (if Tested
listed)
d) in 10 ppb
cfu/ml ppb)
in
ppb
Lady 2 Drinki No test No 29* 29* Not Not No test No Toluene 10 SA- THM levels
Lee* ng test Dete Dete test at 0.5 (comp 806- in excess of
Water cted cted ppb; no osited) 208 CA &
xylene 5 industry
found standards;
chloroform
in excess of
CA Prop. 65
level.
Toluene is a
gasoline
constituent
and used in
industrial
chemicals.
Lucky 3 Drinki San Plant 8 Not Not Not Not Not Not Not No 10 SA-
(aka ng Franci #06-21 Detec Detec Detect Dete Dete Detected Dete toluene (comp 711-
Lady Water sco ted ted ed cted cted cted or osited) 170
Lee) (1 xylene 5
gallon detected
)
Lucky* 1 Seltze San Salt Not Not 30.7* 29* 1.7 Not Not Not Fluoride 10 SA- THM level
r Franci Lake Detect Detec Dete Detected Dete found at (comp 712- exceeds CA
Water sco City, ed ted cted cted 0.84 osited) 002 & industry
(2 UT, ppm* 7 standards,
liters) distrib., and
Am chloroform
Procure level
ment & exceeds CA
Logistic Prop. 65
s level.
Fluoride
level
slightly over
CA warm
weather area
standard of
0.8 ppm if
fluoride
added (if
fluoride is
natural,
warm
weather area
standard is
1.4 ppm);
identical
FDA
standard
does not
apply to
seltzer (not
defined as
"bottled
water").
Lucky* 2 Seltze No test No 20* 20* Not Not No test No n- SA- Chloroform
r test Dete Dete test isoprop 806- level CA
Water cted cted yl- 208 Prop. 65
toluene 7 warning
at 230 level; THM
ppb; level
n-butyl- exceeds CA
benzene & industry
at 21 standards.
ppb; High level
Toluene of n-
at 1.8 isopropyl
ppb; toluene and
elevated
level of n-
butyl-
benzene of
unknown
origin; CA
law
generally
prohibits
levels over 1
ppb of these
VOCs in
source
water, but
may have
been added
in
processing.
Lucky 1 Sparkl San Not Not Not Not Not Not Not 0.2 p- 3 (1 EQI
ing Franci Detect Detec Detec Detect Dete Dete Detected isoprop for -1-
Water, sco ed ted ted ed cted cted yl- each 41-
Sugar toluene contam 43
Free found at inant
Rasbe 5.4 ppb type)
rry
Bev.
(1
liter)
Master 1 Spring New Stockbri >5700 Not Not Not Not Not Not 1.7 10 299 Level of
Choice† Water York dge, VT † Detec Detec Detect Dete Dete Detected (comp 863- HPC
(1.5 City ted ted ed cted cted osited) 942 bacteria
liters) (863 substantially
- exceeded
868) guideline.
Master 2 Spring New 1 of 10 No No No No No No test No 10 299 Bacterial
Choice† Water York bottles test test test test test test (indivi 869- overgrowth
(1.5 City had dually) 878 was
liters) HPC observed in
bacteri 1 of the 10
al bottles
overgr tested. The
owth† presence of
a large
number of
noncoliform
HPC
bacteria may
be inhibiting
the detection
of coliform
bacteria
during the
testing. See
text for
discussion
of HPC
bacteria.
Mendoc 1 Sparkl Berkel Mendoci Not Not Not Not Not Not Not Not 10 SA-
ino ing ey, no Bev., Detect Detec Detec Detect Dete Dete Detected Dete (comp 712-
Miner CA Comptc ed ted ted ed cted cted cted osited) 002
al he, CA 8
Water
(1
liter)
Natural 1 Spring Berkel Nat. 7,300† Not Not Not Not Not Not Not 10 SA- Level of
Value† Water ey, Value, Detec Detec Detect Dete Dete Detected Dete (comp 712- HPC
(1 CA Sacrame ted ted ed cted cted cted osited) 002 bacteria
gallon nto, CA, 9 substantially
) distrib. exceeded
guideline
applied to
bottled
water by
some states.
Naya 1 Canad Los Revelstr Not Not Not Not Not Not Not Not 3 (1 EQI
ian Angel oke, BC, Detect Detec Detec Detect Dete Dete Detected Dete for -1-
Natur es Canada ed ted ted ed cted cted cted each LA
al contam 15-
Spring inant LA
Water type) 17
(1
liter)
# on (if Tested
listed)
d) in 10 ppb
cfu/ml ppb)
in
ppb
Naya 2 Canad San Revelstr Not Not Not Not Not Not Not Not 10 SA-
ian Diego, oke, BC, Detect Detec Detec Detect Dete Dete Detected Dete (comp 712-
Spring CA Canada ed ted ted ed cted cted cted osited) 039
Water 6
(1
liter)
Naya 3 Canad New Revelstr Not Not Not Not Not Not Not Not 10 299
ian York oke, Detect Detec Detec Detect Dete Dete Detected Dete (comp 863-
Spring City B.C., ed ted ted ed cted cted cted osited) 942
Water Canada (927
(1.5 -
liter) 932)
Naya 4 Canad New Canada Not No No No No No No test No 10 299
ian York Detect test test test test test test (indivi 863-
Spring City ed dually) 942
Water (933
(1.5 -
liters) 942)
Niagara 1 Drinki San Irvine, 35 Not 8.5 3.7 3.1* 1.7 Not Not 10 SA- Bromodichl
* ng Diego, CA Detec Detected Dete (comp 712- ormethane
Water CA ted cted osited) 039 found above
(1 7 CA Prop. 65
gallon level.
)
Niagara 2 Drinki No test No 3.1 1.5 1.1 0.5 No test No 1 SA-
ng test test (indivi 901-
Water dual) 080
0
Niagara 3 Drinki No test No 1.6 0.9 0.7 Not No test No 8 SA-
ng test Dete test (comp 901-
Water cted osited) 080
0
Nursery 1 Drinki San Not 4.5 Not Not Not Not Not Not Toluene 3 (1 EQI Toluene and
ng Franci Detect ppb Detec Detect Dete Dete Detected Dete found at for -1- xylene are
Water, sco ed ted ed cted cted cted 12.4 each 47- constituents
sodiu ppb, o- contam 49 of gasoline
m free xylene inant and also
fluori at 3.2 type) used in
de ppb, some
added, styrene industrial
not at 3.0 chemicals.
sterile ppb
, use
as
direct
ed by
physic
ian or
by
labeli
ng
directi
ons
for
use in
infant
formu
la (1
gallon
)
Nursery 2 Drinki No test No Not Not Not Not No test No Toluene 10 SA-
ng test Detec Detect Dete Dete test at 0.57 (comp 807-
Water ted ed cted cted ppb osited) 007
9
Odwall 1 Geoth Berkel Trinity 1 3.8 Not Not Not Not Not Not Fluoride 10 SA- FDA and
a* ermal ey, Springs, Detec Detect Dete Dete Detected Dete found at (comp 712- California
Natur CA Davenp ted ed cted cted cted 1.5 osited) 003 bottled
al ort, CA ppm* 0 water
Spring regulations
Water impose a
(1 maximum of
liter) 1.4 ppm
fluoride in
areas with
annual
average high
temperature
s of >79.3
°F.
Odwall 2 No test 3.9 No No No No No test No Fluoride 10 SA- FDA and
a* test test test test test at 1.6 (comp 807- California
ppm* osited) 008 bottled
0 water
regulations
impose a
maximum of
1.4 ppm
fluoride in
areas with
annual
average high
temperature
s of >79.3
°F.
# on (if Tested
listed)
d) in 10 ppb
cfu/ml ppb)
in
ppb
Opal† 1 Spring Berkel Culver, 510† 2.4 Not Not Not Not Not Not Fluoride 10 SA- Level of
Water ey, OR Detec Detect Dete Dete Detected Dete found at (comp 712- HPC
(1.5 CA ted ed cted cted cted 0.16 osited) 003 bacteria
liter) ppm 1 exceeded
guideline
applied to
bottled
water by
some states.
Ozarka 1 Drinki Houst Houston 1 Not 2.2 1.8 0.4 Not Not Not 10 298
ng on, Municip Detec Dete Detected Dete (comp 08-
Water TX al Water ted cted cted osited) 965
Supply (960
-
965)
Ozarka 2 Drinki Houst Houston Not No No No No No No test No 10 298
ng on, Municip Detect test test test test test test (indivi 950-
Water TX al Water ed dually) 959
Supply
Paloma 1 Mount Los Palomar 2 5.8 Not Not Not Not Not 0.6 3 (1 EQI Arsenic
r* ain Angel Mountai ppb Detec Detect Dete Dete Detected for -1- level
Spring es n, ted ed cted cted each LA3 exceeds CA
Water Escondi contam -5 Prop. 65
(1 do, CA inant warning
liter) type) level.
Palomar 2 Mount Venic Palomar Not Not Not Not Not Not Not 0.6 10 SA-
ain e, CA Mountai Detect Detec Detec Detect Dete Dete Detected (comp 712-
Spring n, ed ted ted ed cted cted osited) 039
Water Escondi 8
(1.5 do, CA
liters)
Palomar 3 Mount Los Palomar No test Not No No No No No test No 10 SA-
ain Angel Mountai Detec test test test test test (comp 808-
Spring es n, ted osited) 166
Water Escondi 4
(1.5 do, CA
liters)
Pathmar 1 Spring New Guelph, 1 Not 2.4 Not Not 0.1 Not Not Bromof 10 299
k Water York Canada Detec Detect Dete Detected Dete orm (a (comp 863-
(1.5 City ted ed cted cted trihalom osited) 942
liters) ethane) (895
was -
found at 900)
2.2 ppb
Pathma 2 Spring New Guelph, 1 of 10 No No No No No No test No 10 299 Bacterial
rk† Water York Canada bottles test test test test test test (indivi 863- overgrowth
(1.5 City tested dually) 942 was
liters) contain (901 observed in
ed - 1 of the 10
HPC 910) bottles
bacteri tested. The
al presence of
overgr a large
owth† number of
noncoliform
HPC
bacteria may
be inhibiting
the detection
of coliform
bacteria
during the
testing. See
text for
discussion
of HPC
bacteria.
Pathmar 3 Spring New Guelph, Not No No No No No No test No 10 299
k Water York Canada Detect test test test test test test (indivi 863-
(1.5 City ed dually) 942
liters) (879
&
885-
893)
Perrier 1 Sparkl San Vergeze 19 Not Not Not Not Not Not 2.8 2- 3 (1 EQI Chlorotolue
ing Franci , France Detec Detec Detect Dete Dete Detected Chlorot for -1- ne of
Miner sco ted ted ed cted cted oluene each 44- unknown
al found at contam 46 origin
Water 4.6 ppb inant
(25 fl type)
oz.)
# on (if Tested
listed)
d) in 10 ppb
cfu/ml ppb)
in
ppb
Perrier 2 Sparkl Los Vergeze Not Not Not Not Not Not Not 2.6 2- 3 (1 EQI Chlorotolue
ing Angel , France Detect Detec Detec Detect Dete Dete Detected Chlorot for -1- ne of
Miner es ed ted ted ed cted cted oluene each LA unknown
al found at contam 36- origin.
Water 3.7 ppb inant LA
(25 fl type) 38
oz.)
Perrier 3 Sparkl San Vergeze Not Not Not Not Not Not Di(2- 4.3 No 10 SA- Exceeds 6
* ing Franci , France Detect Detec Detec Detect Dete Dete ethylhexyl detectio (comp 712- ppb tap
Miner sco ed ted ted ed cted cted )Phthalate n of 2- osited) 003 water
al detected at Chlorot 2 standard for
Water 12 ppb* oluene Di(2-
(1 ethylhexyl)
liter) phthalate
(DEHP), but
there is no
standard for
bottled
water for
this
chemical.
California
does not
allow this
DEHP level
in the source
water for
bottled
water, but
sets no
DEHP
standard for
finished
bottled
water.
Perrier 4 Sparkl San Vergeze No test No No No No No No test 4.1 No test 10 SA- Nitrate
ing Franci , France test test test test test (comp 808- retest.
Miner sco osited) 166
al 2
Water
Poland 1 Natur Washi 750† Not Not Not Not Not Not Not 10 298 HPC
Spring† al ngton, Detec Detec Detect Dete Dete Detected Dete (comp 808- bacteria
Spring DC ted ted ed cted cted cted osited) 965 found at
Water (819 levels
(1 - exceeding
liter) 824) guideline
applied by
some states
to bottled
water.
Poland 2 Natur Washi 5 of 10 No No No No No No test No 10 298 Bacterial
Spring† al ngton, bottles test test test test test test (indivi 808- overgrowth
Spring DC tested dually) 965 was
Water had (809 observed in
(1 HPC - 5 of the 10
liter) bacteri 818) bottles
al tested. The
overgr presence of
owth† a large
number of
non-
coliform
HPC
bacteria may
be inhibiting
the detection
of coliform
bacteria
during the
testing. See
text for
discussion
of HPC
bacteria.
Polar 1 Spring Washi Crystal Not Not 0.1 0.1 Not Not Not 0.8 Toluene 10 298 Toluene is
Water ngton, Springs, Detect Detec Dete Dete Detected detected (comp 808- often an
(1 DC Spring ed ted cted cted at 2.5 osited) 965 indicator of
gallon Grove, ppb, (851 the presence
) VT (well - of gasoline
below 856) or industrial
the chemicals,
standard here of
of 1000 unknown
ppb) origin.
Polar 2 Spring Washi Crystal Not No No No No No No test No 10 298
Water ngton, Springs, Detect test test test test test test (indivi 808-
(1 DC Spring ed dually) 965
gallon Grove, (841
) VT -
850)
Private 1 Drinki Los Not Not 47.1* 16.7* 20.1 10.3 Not 0.1 3 (1 EQI THM levels
Selectio ng Angel Detect Detec * * Detected for -1- violated CA
n* Water es ed ted each LA & industry
(Ralph' (1 contam 26- standards
s) gallon inant LA for bottled
) type) 27 water, and
chloroform,
bromodichlo
romethane,
and
dibromochlo
romethane
exceeded
CA Prop. 65
levels.
Private 2 Drinki Venic Ralph's 66 Not 22.3* 6.6 8.9* 6.8* Not Not 10 SA- THM levels
Selectio ng e, CA LA, Detec Detected Dete (comp 712- violated CA
n* Water distrib., ted cted osited) 039 & industry
(Ralph' (1 plant 9 standards
s) gallon 06-178 for bottled
) water, and
bromodichlo
romethane,
and
dibromochlo
romethane
exceeded
CA Prop. 65
levels.
Private 1 Natur Los Not Not Not Not Not Not Not 0.1 3 (1 EQI
Selectio al Angel Detect Detec Detec Detect Dete Dete Detected for -1-
n Spring es ed ted ted ed cted cted each LA
(Ralph's Water contam 34-
) (1 inant LA
gallon type) 35
)
# on (if Tested
listed)
d) in 10 ppb
cfu/ml ppb)
in
ppb
Private 1 Purifi San Ralph's Not Not 20.1* 8.4 7.4* 4.3* Not Not 10 SA- THM levels
Selectio ed Diego, LA, Detect Detec Detected Dete (comp 712- violated CA
n* Water CA distrib., ed ted cted osited) 058 & industry
) water, and
bromodichlo
romethane,
and
dibromochlo
romethane
exceeded
CA Prop. 65
levels.
Private 2 Purifi Los Ralph's No test No 10.4* 9.1 1.3 Not Not Not 10 SA- THM levels
Selectio ed Angel LA, test Dete Detected Dete (comp 808- violate CA
n* Water es distrib., cted cted osited) 166 &
(Ralph' (1 plant 5 industry/IB
s) gallon 06-178 WA
) standard for
bottled
water.
Publix† 1 Drinki Miami Not 1.3 45† 41 3.2 0.2 Not 0.8 Acetone 10 304 THM levels
ng , FL Detect Detected found at (comp 085- violate
Water ed 11 ppb osited) 165 industry/IB
(1 (no (085 WA
gallon std.); - standard of
) styrene 090) 10 ppb (no
found at longer
0.6 ppb enforceable
(below in FL)
std. of
100
ppb)
Publix† 2 Drinki Lakela No test No 53† 47 5.3 0.4 No test No Acetone 8 361 THM levels
ng nd, FL test test found at (comp 436- violate
Water 14 ppb osite 37 industry/IB
(1 (no sample (36) WA
gallon standard ) standard of
) ) 10 ppb (no
longer
enforceable
in FL).
ng nd, FL test test found at bottle 436- violate
Water 16 ppb 37 industry/IB
(1 (no (37) WA
gallon standard standard of
) ) 10 ppb (no
longer
enforceable
in FL).
Publix 4 Drinki Miami Not No No No No No No test No No test 10 304
ng , Fl Detect test test test test test test (indivi 085-
(1 (304
gallon 091-
) 304
100)
Publix† 1 Purifi Miami 1 Not 15† 14† 0.9 Not Not Not Styrene 10 304 THM found
ed , FL Detec Dete Detected Dete found at (comp 085 at level
Water ted cted cted 0.2 ppb osited) (117 exceeding
(1 (below - 10 ppb
gallon std. of 122) industry/IB
) 100 WA
ppb) standard (no
longer
enforceable
in FL).
Styrene
from
unknown
source.
Publix† 2 Purifi Miami 5 of 10 No No No No No No test No No test 10 304 Bacterial
ed , FL bottles test test test test test test bottles 085- overgrowth
Water tested (indivi 165 was
(1 contain dualy) (304 observed in
gallon ed 123- 5 of the 10
) HPC 304 bottles
"bacter 132) tested. The
ial presence of
overgr a large
owth"† number of
non-
coliform
HPC
bacteria may
be inhibiting
the detection
of coliform
bacteria
during the
testing. See
text for
discussion
of HPC
bacteria.
Puritas 1 Drinki Los Grt. Not 3.2 Not Not Not Not Not Not 3 (1 EQI
ng Angel Sprg. Detect Detec Detect Dete Dete Detected Dete for -1-
Water es Waters ed ted ed cted cted cted each LA1
(1 of contam -
gal.) America inant LA2
, type)
Milpitas
, CA
Puritas 2 Drinki Berkel Grt. 990† Not Not Not Not Not Results Not 10 SA- Level of
† ng ey, Sprg. Detec Detec Detect Dete Dete not Dete (comp 712- HPC
Water CA Waters ted ted ed cted cted received cted osited) 003 bacteria
(1 of 3 substantially
gallon America exceeded
) , guideline.
Milpitas
, CA
# on (if Tested
listed)
d) in 10 ppb
cfu/ml ppb)
in
ppb
Ralph's 1 Mount Los "Califor Not Not Not Not Not Not Not 0.8 3 (1 EQI
ain Angel nia Detect Detec Detec Detect Dete Dete Detected for -1-
Spring es Mountai ed ted ted ed cted cted each LA
Water ns," contam 28-
(1.5 L.A., inant LA
liter) CA, type) 30
distrib.
Ralph's 2 Mount San "Califor 270 Not Not Not Not Not Not 0.6 10 SA-
ain Diego nia Detec Detec Detect Dete Dete Detected (comp 712-
Spring Mountai ted ted ed cted cted osited) 058
Water ns" 3
(1.5
liters)
Randalls 1 Remar Houst Buck Not Not 0.4 Not Not Not Not Not Bromof 10 298
kable on, Springs, Detect Detec Detect Dete Dete Detected Dete orm (a (comp 808-
Drinki TX Jasper, ed ted ed cted cted cted trihalom osited) 965
ng TX ethane) (895
Water found at -
(1 0.4 ppb 900)
gallon
)
Randalls 2 Remar Houst Buck Not No No No No No No test No 10 298 HPC retest
kable on, Springs, Detect test test test test test test bottles 808- found none.
Drinki TX Jasper, ed (indivi 965
ng TX dually) (885
Water -
(1 894)
gallon
)
Randall 1 Deja Houst City of >5700 Not 29.6† 14 12 3.6 Not Not 10 298 Levels of
s† Blue on, Irving † Detec Detected Dete (comp 808- TTHM
Drinki TX Water ted cted osited) 965 exceed
ng Supply (911 IBWA/indus
Water - try standards
(1 916) (not
liter) enforceable
in TX).
Randalls 2 Deja Houst City of Not No No No No No No test No 10 298
Blue on, Irving Detect test test test test test test bottles 808-
Drinki TX Water ed (indivi 965
ng Supply dually) (901
Water -
(1 910)
liter)
Rocky 1 Drinki Los "Deep Not Not Not Not Not Not Not Not 3 (1 EQI
Mountai ng Angel Well Detect Detec Detec Detect Dete Dete Detected Dete for -1-
n Water, es Water" ed ted ted ed cted cted cted each LA
non- contam 31-
carbo inant LA
nated type) 33
(1.5
liter)
Rocky 2 Drinki San Santa Fe Not Not Not Not Not Not Not Not 10 SA-
Mountai ng Dimas Springs, Detect Detec Detec Detect Dete Dete Detected Dete (comp 712-
n Water, , CA CA ed ted ted ed cted cted cted osited) 058
non- 4
carbo
nated
(1.5
liters)
S. 1 Sparkl San San Not Not Not Not Not Not Not Not 3 (1 EQI
Pellegri ing Franci Pellegri Detect Detec Detec Detect Dete Dete Detected Dete for -1-
no Natur sco no, Italy ed ted ted ed cted cted cted each 38-
al contam 40
Miner inant
al type)
Water,
bottle
d at
the
source
(25.3
oz.)
S. 2 Sparkl San San Not Not Not Not Not Not Not Not Fluoride 10 SA-
Pellegri ing Franci Pellegri Detect Detec Detec Detect Dete Dete Detected Dete found at (comp 712-
no Natur sco no, Italy ed ted ted ed cted cted cted 0.37 osited) 003
al ppm 4
Miner (below
al standard
Water )
(1
liter)
# on (if Tested
listed)
d) in 10 ppb
cfu/ml ppb)
in
ppb
Safewa 1 Drinki Berkel Municip 8,500† Not 35.1* 31* 4.1* Not Not Not Fluoride 10 SA- THM found
y*† ng ey, al Detec Dete Detected Dete found at (comp 712- at level
(CA) Water CA Source, ted cted cted 0.81 osited) 021 above CA &
(1 Safeway ppm 4 industry
gallon Inc., (above bottled
) Oakland standard water
, CA, in warm standards;
distrib. weather chloroform
areas) and
bromodichlo
romethane
(BDCM)
found at
levels above
CA Prop. 65
limits.
Fluoride at
level above
FDA & state
limit for
areas with
av. high
temp.
>79.3°F.
HPC
bacteria
above
guideline
adopted by
some states
for bottled
water.
Safewa 2 Drinki 51,000 No 37* 35* 2.3 Not No test No 10 SA THM found
y* (CA) ng † (1 test Dete test (comp 807- at level
Water bottle) cted osited 008 above CA &
12,000 for 1 industry
†(1 chemic bottled
bottle) al water
2-21 (4 analysi standards,
bottles s) and
) 10 chloroform
Not (indivi found at a
Detect dually level above
ed in 4 for CA Prop. 65
bottles bacteri limit.
(see a Retests of
notes) analysi individual
s) bottles that
were
initially
found to
contain
51,000
cfl/mu and
12,000
cfl/mu
found no
HPC and
6,000
cfu/ml,
respectively,
though these
results are
unreliable
since they
were
retested
beyond
EPA-
mandated
"hold time"
after
opening.
Safeway 1 Key San Not Not Not Not Not Not Not 0.5 3 (1 EQI
(CA) Lime Franci Detect Detec Detec Detect Dete Dete Detected for -1-
Sparkl sco ed ted ted ed cted cted each 13-
ing contam 15
Water inant
(1 type)
quart)
Safewa 1 Purifi San >5,700 Not 26.4* 26.4* Not Not Not 0.1 Total 3 (1 EQI Coliforms,
y*† ed Franci † Detec Dete Dete Detected colifor for -1- HPC
(CA) Water sco ted cted cted ms each 7-9 bacteria,
(1 count contam trihalometha
gallon 5*; inant nes, and
) Toluene type) chloroform
found at exceed
8.4 ppb guidelines/st
andards.
Toluene is a
constituent
of gasoline
and
industrial
chemicals
that should
be removed
if treated
with reverse
osmosis.
Label claims
"prepared
by
deionization
and/or
reverse
osmosis."
Could have
been added
during
processing.
Safewa 2 Purifi San Municip 4 Not 42.5* 39* 3.5* Not Not Not Toluene 10 SA- THM levels
y* (CA) ed Franci al Detec Dete Detected Dete not (comp 712- violate CA
Water sco/ Source, ted cted cted detected osited) 058 & industry
(1 Berkel Safeway , 5 standards
gallon ey, , colifor for bottled
) CA Oakland ms not water.,
, CA, detected chloroform
distrib. and
bromodichlo
romethane
exceeded
CA Prop. 65
levels.
Safewa 1 Select Berkel Safeway Not Not 53.3* 50* 3.3* Not Not Not Fluoride 10 SA- THM levels
y* (CA) Club ey, , Detect Detec Dete Detected Dete found at (comp 712- violate CA
Soda CA Oakland ed ted cted cted 0.64 osited) 021 & industry
(2 , CA, ppm, 5 standards
liter) distrib. below for bottled
std. water.
Chloroform
and
bromodichlo
romethane
exceeded
CA Prop. 65
levels.
Safewa 2 Select No test No 25* 24* 0.54 Not No test No 10 SA- Chloroform
y* (CA) Club test Dete test (comp 807- level
Soda cted osited) 008 exceeds CA
2 Prop. 65
level;
Trihalometh
ane levels
over CA &
industry
standards.
Safewa 1 Select Berkel Safeway Not Not 36.1* 34* 2.1 Not Not Not Fluoride 10 SA- THM levels
y*† Seltze ey, , Detect Detec Dete Detected Dete found at (comp 712- violate CA
(CA) r CA Oakland ed ted cted cted 0.83 osited) 021 & industry
Water , CA, ppm* 6 standards.
(2 distrib. above Chloroform
liter) warm level
weather exceeds CA
std. for Prop. 65
added level.
fluoride Fluoride
above 0.80
CA std. for
areas with
av. high
>79.3°F (if
fluoride
added; if
natural,
warm
weather area
standard is
1.4 ppm);
identical
FDA
standard
does not
apply to
seltzer (not
defined as
"bottled
water").
Safewa 2 Select No test No 21* 21* Not Not No test No 10 SA- THM levels
y* (CA) Seltze test Dete Dete test (comp 807- violate CA
r cted cted osited) 008 & industry
Water 3 standards,
chloroform
level
exceeds CA
Prop. 65
level.
Safewa 1 Spring San >5700 Not 56.8* 53.3* 3.5* Not Not Not Toluene 3 (1 EQI Toluene and
y*† Water Franci † Detec Dete Detected Dete found at for -1- o-xylene are
(CA) "Espe sco ted cted cted 14.2 each 10- constituents
cially ppb; contam 12 of gasoline
select o- inant and
ed for xylene type) industrial
its at 3.1 chemicals.
Natur ppb, This water
al both apparently
Purity below was
" (1 standard chlorinated,
gallon s suggesting
) that it could
be tap water
or if it is
spring
water, it was
subjected to
chlorination.
Levels of
TTHMs
exceeded
CA &
industry
standard;
level of
chloroform
exceeds CA
Prop. 65
level; HPC
exceeded
guidelines.
# on (if Tested
listed)
d) in 10 ppb
cfu/ml ppb)
in
ppb
Safewa 2 Spring Berkel Safeway 15 Not 24.9* 23* 1.9 Not Invalid Not Fluoride 10 SA- THM levels
y* (CA) Water ey, , Detec Dete Dete found at (comp 712- violate CA
(1 CA Oakland ted cted cted 0.28 osited) 021 & industry
gallon , CA, ppm, 7 standards.
) distrib. below Chloroform
std.; no level
toluene exceeds CA
or Prop. 65
xylene level.
found
Safeway 3 Spring Berkel Safeway No test No No No No No Not No No test 10 SA Retest for
(CA) Water ey, , test test test test test Detected test (comp 801- phthalate
(1 CA Oakland osited) 036 and
gallon , CA, 4 semivolatile
) distrib. organics,
not
detected.
Safeway 1 Refres Washi Safeway Not Not Not Not Not Not Not 0.7 10 298
(DC) he ngton, Spring, Detect Detec Detec Detect Dete Dete Detected (comp 808-
Natur DC NY ed ted ted ed cted cted osited) 965
al (835
Spring -
Water 840)
(16.9
oz.)
Safeway 2 Refres Washi Safeway 1 of 10 No No No No No No test No 10 298 Bacterial
(DC) he ngton, Spring, bottles test test test test test test bottles 808 overgrowth
Natur DC NY tested (indivi 965 was
al had dually) (825 observed in
Spring overgr - 1 of the 10
Water owth 834) bottles
(16.9 of tested. The
oz.) HPC presence of
bacteri a large
a number of
non-
coliform
HPC
bacteria may
be inhibiting
the detection
of coliform
bacteria
during the
testing. See
text for
discussion
of HPC
bacteria.
Safeway 1 Safew Washi Tower Not Not Not Not Not Not Not Not Toluene 10 298 Toluene is a
(DC) ay ngton, City, PA Detect Detec Detec Detect Dete Dete Detected Dete found at (comp 808- constituent
Spring DC ed ted ted ed cted cted cted 4.7 ppb osited) 965 of gasoline
Water ( below (863 and
(1 the - industrial
gallon standard 868) chemicals,
) of 1000 although its
ppb) source here
is unknown.
Safeway 2 Safew Washi Tower Not No No No No No No test No 10 298
(DC) ay ngton, City, PA Detect test test test test test test (comp 808
Spring DC ed osited) 965
Water (857
(1 -
gallon 862,
) 917)
Sahara 1 Drinki Los 1 Not 37.9* 14.7* 14.9 8.3* Not 1.1 3 (1 EQI THM levels
* ng Angel Detec Detected for -1- violated CA
Water, es ted each LA9 & industry
"Prem contam -11 standards
ium" inant for bottled
(50.7 type) water, and
oz.) chloroform,
bromodichlo
romethane,
and
dibromochlo
romethane
exceeded
CA Prop. 65
levels.
Sahara 1 Mount San Bear Not Not 15.9* 6.5* 6.6* 2.8 Not 2.5 Fluoride 10 SA- THM levels
* ain Diego/ Spec. & Detect Detec Detected at 0.54 (comp 712- violated CA
Spring San Mktg., ed ted ppm osited) 058 & industry
Water Marco San 6 standards
(1.5 s, CA Bernadi for bottled
liter) no, CA, water, and
distrib. chloroform
and
bromodichlo
romethane
exceeded
CA Prop. 65
levels.
Save the 1 Natur Berkel Baxter Not Not Not Not Not Not Not Not 10 SA-
Earth al ey, Springs, Detect Detec Detec Detect Dete Dete Detected Dete (comp 712-
Spring CA CA ed ted ted ed cted cted cted osited) 021
Water 8
(1
liter)
Schwep 1 Club San Cadbury Not Not 7.7 7.7 Not Not Invalid Not Fluoride 10 SA-
pes Soda Franci Bev., Detect Detec Dete Dete test Dete found at (comp 712-
(1 sco, Stamfor ed ted cted cted cted 0.13 osited) 021
liter) CA d, CT ppm, 9
well
below
standard
# on (if Tested
listed)
d) in 10 ppb
cfu/ml ppb)
in
ppb
Schwep 2 Club San Dr. No test No No No No No Not No 10 SA Retest of
pes Soda Franci Pepper/ test test test test test Detected test (comp 801- semivolatile
(1 sco Seven osited) 036 organics,
liter) Up, Inc., 0 including
Dallas, phthalate,
TX found none.
Schwep 1 Seltze Berkel Cadbury Not Not Not Not Not Not Invalid Not Fluoride 10 SA-
pes r ey, Bev., Detect Detec Detec Detect Dete Dete test Dete found at (comp 712-
Water CA Stamfor ed ted ted ed cted cted cted 0.28 osited) 022
(1 d, CT ppm, 0
liter) well
below
standard
Schwep 2 Seltze San Dr. No test No No No No No Not No 10 SA Retest of
pes r Franci Pepper/ test test test test test Detected test (comp 801- semivolatile
Water sco Seven osited) 036 organics,
(1 Up, Inc., 1 including
liter) Dallas, phthalate,
TX found none.
Shasta 1 Sparkl Berkel Shasta Not Not Not Not Not Not Results Not Fluoride 10 SA-
ing ey, Bev., Detect Detec Detec Detect Dete Dete not Dete found at (comp 712-
Club CA Haywar ed ted ted ed cted cted received cted 0.19 osited) 022
Soda d, CA, ppm, 1
(2 distrib. well
liters) below
standard
Shasta 2 Sparkl Berkel Shasta No test No No No No No Not No 10 SA Retest of
ing ey, Bev., test test test test test Detected test (comp 801- semivolatile
Club CA Haywar osited) 036 organics,
Soda d, CA, 5 including
(2 distrib. phthalate,
liters) found none.
Sparkle 1 Crysta Los McKess 3600† Not Not Not Not Not Not 0.1 3 (1 EQI Heterotrophi
tts† l Angel on Detec Detec Detect Dete Dete Detected for -1- c Plate
Fresh es Water ted ted ed cted cted each LA Count
Drinki Prods., contam 12- Bacteri
ng Pasaden inant LA (HPC)
Water a, CA type) 14 exceeded
-- guideline.
"Meet
or
Excee
d all
State
and
Feder
al
Water
Qualit
y
Stand
ards"
(1
liter)
Sparklet 2 Crysta Venic McKess 140 Not Not Not Not Not Not Not 10 SA- HPC level
ts l e, CA on Detec Detec Detect Dete Dete Detected Dete (comp 712- below
Fresh Water ted ted ed cted cted cted osited) 058 guidelines in
Drinki Prods., 7 retest.
ng Pasaden
Water a, CA
--
"Meet
or
Excee
d all
State
and
Feder
al
Water
Qualit
y
Stand
ards"
(1
liter)
Sparklet 1 Distill Venic McKess 190 Not Not Not Not Not Not Not 10 SA-
ts ed e, CA on Detec Detec Detect Dete Dete Detected Dete (comp 712-
Drinki Water ted ted ed cted cted cted osited) 058
ng Prods., 8
Water Pasaden
(1 a, CA
gallon
)
Sparkle 1 Mount Los McKess >5700 Not Not Not Not Not Not 0.6 3 (1 EQI Heterotrophi
tts† ain Angel on † Detec Detec Detect Dete Dete Detected for -1- c Plate
Spring es Water ted ted ed cted cted each LA Count
Water Prods., contam 18- Bacteria
(33.8 Pasaden inant LA (HPC)
oz.) a, CA type) 20 exceeded
guideline.
Sparklet 2 Mount Venic McKess Not Not Not Not Not Not Not Not 10 SA- HPC Not
ts ain e, CA on Detect Detec Detec Detect Dete Dete Detected Dete (comp 712- Detected.
Spring Water ed ted ted ed cted cted cted osited) 058
Water Prods., 9
(1 Pasaden
liter) a, CA
# on (if Tested
listed)
d) in 10 ppb
cfu/ml ppb)
in
ppb
Sparklin 1 (1.5 Chica Not Not Not Not Not Not Not 3.1 10 297
g liter) go, IL Detect Detec Detec Detect Dete Dete Detected (comp 719-
Springs ed ted ted ed cted cted osited) 48
(37-
42)
Sparklin 2 (1.5 Chica Not No No No No No No test 9 297
g liter) go, IL Detect test test test test test (indivi 790
Springs ed dually) 836
(819
-
827)
Vittel* 1 Miner Berkel Vittel Not 11* 9.3 9.3 Not Not Not Not 10 SA- Arsenic
al ey, Bonne Detect Dete Dete Detected Dete (comp 712- level
Water CA Source ed cted cted cted osited) 022 exceeds CA
(1.5 Well, 2 Prop. 65
liter) Vittel, level and
France WHO/EU
arsenic
water limit.
Vittel* 2 Miner San No test 13 No No No No No test No No test 10 SA- Arsenic
al Franci ppb test test test test test (comp 901- exceeds CA
Water sco osited) 079 Prop. 65
9 level and
WHO/EU
water limit.
Volvic* 1 Natur Berkel Clairvic 11 14* Not Not Not Not Results 1.3 Fluoride 10 SA- Arsenic
al ey, Spring, Detec Detect Dete Dete not found at (comp 712- level
Spring CA Volvic, ted ed cted cted received 0.17 osited) 022 exceeds CA
Water France ppm, 3 Prop. 65
(1.5 well level and
liter) below WHO/EU
standard arsenic
water limit.
Volvic* 2 Natur Berkel Clairvic No test 12* No No No No No test No No test 10 SA- Arsenic
al ey, Spring, test test test test test (comp 808- level
Spring CA Volvic, osited) 166 exceeds CA
Water France 7 Prop. 65
(1.5 level and
liter) WHO/EU
arsenic
water limit.
Volvic 3 Natur Berkel Clairvic No test No No No No No Not No 10 SA Retest of
al ey, Spring, test test test test test Detected test (comp 801- semivolatile
Spring CA Volvic, osited) 036 organics,
Water France 2 including
(1.5 phthalate,
liter) found none.
Vons 1 Drinki Los Vons Not Not Not Not Not Not Not Not 3 (1 EQI
ng Angel LA, Detect Detec Detec Detect Dete Dete Detected Dete for -1-
Water es distrib. ed ted ted ed cted cted cted each LA
(1 contam 24-
gallon inant LA
) type) 25
Vons 2 Drinki San Vons Not Not Not Not Not Not Test Not 10 SA-
ng Diego/ LA, Detect Detec Detec Detect Dete Dete invalid Dete (comp 712-
Water San distrib. ed ted ted ed cted cted cted osited) 059
(1 Marco plt. 06- 0
gallon s, CA 2796
)
Vons 3 Drinki Los Vons No test No No No No No Not No 10 SA Retest of
ng Angel LA, test test test test test Detected test (comp 801- semivolatile
Water es distrib. osited) 036 organics,
(1 plt. 06- 3 including
gallon 2796 phthalate,
) found none.
Vons 1 Natur Los Vons Not Not Not Not Not Not Not 0.6 3 (1 EQI
al Angel LA, Detect Detec Detec Detect Dete Dete Detected for -1-
Spring es distrib. ed ted ted ed cted cted each LA
Water contam 21-
(1 inant LA
liter) type) 23
Vons 2 Natur San Vons 1.0 Not Not Not Not Not Not 0.7 10 SA-
al Diego/ Co. LA, Detec Detec Detect Dete Dete Detected (comp 712-
Mount San distrib. ted ted ed cted cted osited) 059
ain Marco 1
Spring s, CA
Water
(1
liter)
Vons 1 Purifi San Vons 1 Not Not Not Not Not Not Not 10 SA
ed Diego/ LA, plt. Detec Detec Detect Dete Dete Detected Dete (comp 712-
Water San 06-2796 ted ted ed cted cted cted osited) 080
(1 Marco 5
gallon s, CA
)
Yosemit 1 Drinki Los Highlan 1100† Not Not Not Not Not Not 1.3 10 SA Level of
e ng Angel d Park, Detec Detec Detect Dete Dete Detected (comp 712- HPC
Waters Water es CA ted ted ed cted cted osited) 080 bacteria
† (5 /Santa 6 exceeds
gallon Monic guidelines.
s) a
Zephyrh 1 Distill Miami Not Not Not Not Not Not Not Not 10 304
ills ed , FL Detect Detec Detec Detect Dete Dete Detected Dete (comp 085-
Water ed ted ted ed cted cted cted osited) 165
(1 (133
gallon -
) 138)
Note: These tests used established FDA- or EPA-approved test methods, but are not necessarily
statistically representative of all bottled water of the brand listed. See text for further discussion.
a Row with bold name indicates level exceeding standard or guideline: asterisk {*} indicates exceeds
enforceable standard; dagger {†} indicates exceeds unenforceable guideline. See text and accompanying
Technical Report (print report only).
b As discussed in the text, the California Proposition 65 ("Prop. 65") levels noted in this table are
derived from the "No Significant Risk" levels established by the California Department of Health
Services, and are based on the CDHS’s rules’ assumption that people drink 2 liters of water per day (the
same assumption used by the U.S. EPA). Thus, for example, the Arsenic Proposition 65 level is 10
micrograms per day, so assuming 2 liters of water consumed per day, the Prop. 65 Arsenic level is 5 ppb.
c There is no enforceable FDA standard for HPC bacteria. We use 500 cfu/ml as an informal guideline.
HPC bacteria are not necessarily harmful themselves but are often used as an indicator of overall
sanitation during bottling. The European Union (EU) has adopted an enforceable bottled water standard
of 100 colonies per 100 ml (at 22oC) at bottling. EPA’s tap water rules provide that water containing
over 500 cfu/ml is treated as a coliform-positive sample absent proof of adequate disinfectant residual.
The International Bottled Water Association recommends plants meet a level of <30 cfu/ml at bottling,
and <200 cfu/ml in 90% of samples tested 5 days after bottling. Massachusetts and New York have an
informal bottled water guideline (unenforceable) of 500 cfu/ml. Other states (such as RI) also have
informal guidelines.
d Federal tap water and bottled water standards for arsenic, originally set in 1942 and not revised since,
is 50 ppb. Congress has required updated standard by 2001. International (WHO/EU) standard is 10 ppb
(see text).
e TTHMs are "total trihalomethanes," potentially cancer-causing chemicals created when organic matter
reacts with chlorine. Recent studies also indicate TTHMs may also be linked to birth defects and
spontaneous abortions. While California and International Bottled Water Association (industry trade
association) standard is 10 ppb, new Federal tap water standard is 80 ppb, and FDA bottled water
standard is 100 ppb (see text).
f BDCM is bromodichloromethane, a type of trihalomethane (see above).
g DBCM is dibromochloromenthane, a type of trihalomethane (see above).
Note re Crystal Geyser: The Crystal Geyser company has provided NRDC with test results indicating
that beginning in April 1999, Crystal Geyser substantially reduced the arsenic levels in its spring water,
in an agreement reached after they were sued (based on NRDC's previous test results) by the
Environmental Law Foundation, a California Public Interest Group. This testing shows that as of April
1999, arsenic is either not found, or, if present, is found at levels between non-detectable (<2 ppb) and
4.8 ppb, maximum. These levels are below the California Proposition 65 arsenic warning level of 5 ppb
and well below current federal standard, but EPA recently has proposed to drop the federal drinking
water standard to 5 ppb.
EXECUTIVE SUMMARY
More than half of all Americans drink bottled water; about a third of the public consumes it
regularly. Sales have tripled in the past 10 years, to about $4 billion a year. This sales
bonanza has been fueled by ubiquitous ads picturing towering mountains, pristine
glaciers, and crystal-clear springs nestled in untouched forests yielding absolutely pure
water. But is the marketing image of total purity accurate? Also, are rules for bottled water
stricter than those for tap water?
Not exactly. No one should assume that just because he or she purchases water in a bottle
that it is necessarily any better regulated, purer, or safer than most tap water. NRDC has
completed a four-year study of the bottled water industry, including its bacterial and
chemical contamination problems. We have conducted a review of available information
on bottled water and its sources, an in-depth assessment of Food and Drug
Administration (FDA) and all 50 states' programs governing bottled water safety, and an
analysis of government and academic bottled water testing results. We have compared
FDA's bottled water rules with certain international bottled water standards and with the
U.S. Environmental Protection Agency (EPA) rules that apply to piped tap water supplied
by public water systems. In addition, NRDC commissioned independent lab testing of
more than 1,000 bottles of 103 types of bottled water from many parts of the country
(California, the District of Columbia, Florida, Illinois, New York, and Texas). Our
conclusions and recommendations follow.
An Exploding Bottled Water Market

• There has been an explosion in bottled water use in the United States, driven in
large measure by marketing designed to convince the public of bottled water's
purity and safety, and capitalizing on public concern about tap water quality.
People spend from 240 to over 10,000 times more per gallon for bottled water than
they typically do for tap water.
• Some of this marketing is misleading, implying the water comes from pristine
sources when it does not. For example, one brand of "spring water" whose label
pictured a lake and mountains, actually came from a well in an industrial facility's
parking lot, near a hazardous waste dump, and periodically was contaminated with
industrial chemicals at levels above FDA standards.
• According to government and industry estimates, about one fourth of bottled water
is bottled tap water (and by some accounts, as much as 40 percent is derived from
tap water) -- sometimes with additional treatment, sometimes not.
Major Regulatory Gaps

• FDA's rules completely exempt 60-70 percent of the bottled water sold in the
United States from the agency's bottled water standards, because FDA says its
rules do not apply to water packaged and sold within the same state. Nearly 40
states say they do regulate such waters (generally with few or no resources
dedicated to policing this); therefore, about one out of five states do not.
• FDA also exempts "carbonated water," "seltzer," and many other waters sold in
bottles from its bottled water standards, applying only vague general sanitation
rules that set no specific contamination limits. Fewer than half of the states require
these waters to meet bottled water standards.
• Even when bottled waters are covered by FDA's specific bottled water standards,
those rules are weaker in many ways than EPA rules that apply to big city tap
water. For instance, comparing those EPA regulations (for water systems which
serve the majority of the U.S. population) with FDA's bottled water rules:
o City tap water can have no confirmed E. coli or fecal coliform bacteria
(bacteria that are indications of possible contamination by fecal matter).
FDA bottled water rules include no such prohibition (a certain amount of
any type of coliform bacteria is allowed in bottled water).
o City tap water from surface water must be filtered and disinfected (or the
water system must adopt well-defined protective measures for the source
water it uses, such as control of potentially polluting activities that may
affect the stream involved). In contrast, there are no federal filtration or
disinfection requirements for bottled water -- the only source-water
protection, filtration, or disinfection provisions for bottled water are
completely delegated to state discretion, and many states have adopted no
such meaningful programs.
o Bottled water plants must test for coliform bacteria just once a week; big-
city tap water must be tested 100 or more times a month.
o Repeated high levels of bacteria (i.e., "heterotrophic-plate-count" bacteria)

in tap water combined with a lack of disinefectant can trigger a violation for
cities -- but not for water bottlers.
o Most cities using surface water have had to test for Cryptosporidium or
Giardia, two common water pathogens that can cause diarrhea and other
intestinal problems (or more serious problems in vulnerable people), yet
bottled water companies don't have to do this.
o City tap water must meet standards for certain important toxic or cancer-
causing chemicals such as phthalate (a chemical that can leach from
plastic, including plastic bottles); some in the industry persuaded FDA to
exempt bottled water from regulations regarding these chemicals.
o Any violation of tap-water standards is grounds for enforcement -- but

bottled water in violation of standards can still be sold if it is labeled as
"containing excessive chemicals" or "excessive bacteria" (unless FDA
finds it "adulterated," a term not specifically defined).
o Cities generally must test at least once a quarter for many chemical
contaminants. Water bottlers generally must test only annually.
o Cities must have their water tested by government-certified labs; such

certified testing is not required for bottlers.
o Tap water test results and notices of violations must be reported to state or
federal officials. There is no mandatory reporting for water bottlers.
o City water system operators must be certified and trained to ensure that
they know how to safely treat and deliver water -- not so for bottlers.
o City water systems must issue annual "right-to-know" reports telling

consumers what is in their water; as detailed in this report, bottlers
successfully killed such a requirement for bottled water.
• FDA and state bottled water programs are seriously underfunded. FDA says
bottled water is a low priority; the agency estimates it has the equivalent of fewer
than one staff person dedicated to developing and issuing bottled water rules, and
the equivalent of fewer than one FDA staffer assuring compliance with the bottled
water rules on the books. Although a small number of states (such as California)
have real bottled water programs, our 1998 survey found that 43 states have fewer
than one staff person dedicated to bottled water regulation. By comparison,
hundreds of federal staff and many more state personnel are dedicated to tap
water regulation. Directing disproportionate resources to tap water protection is
warranted. At the same time, over half the U.S. public (including many
immunocompromised people) uses bottled water, and many millions of people use
bottled water as their chief or exclusive drinking water source.
• FDA's regulations are less stringent than some international standards. For
example, unlike FDA's rules, the European Union's (EU's) bottled natural mineral
water standards regulate total bacteria count, and explicitly ban all parasites and
pathogenic microorganisms, E. coli or other coliform bacteria, fecal streptococci
(e.g., Streptococcus faecalis, recently renamed Enterococcus faecalis),
Pseudomonas aeruginosa, and sporulated sulphite-reducing anaerobic bacteria.
Moreover, unlike the weaker FDA rules, the EU rules require natural mineral bottled
water's labels to state the composition of the water and the specific water source,
and mandate that only one water label may be used per source of water. Similarly,
recent EU standards applicable to all bottled water also are far stricter than FDA
standards. FDA's standards for certain chemicals (such as arsenic) also are
weaker than certain World Health Organization (WHO) guidelines.
Bottled Water: As Pure as We Are Led to Believe?

• While most bottled water apparently is of good quality, publicly available
monitoring data are scarce. The underfunded and haphazard patchwork of
regulatory programs has found numerous cases where bottled water has been
contaminated at levels above state or federal standards. In some cases bottled
water has been recalled.
• Our "snapshot" testing of more than 1,000 bottles of 103 brands of water by three
independent labs found that most bottled water tested was of good quality, but
some brands' quality was spotty. About one third of the bottled waters we tested
contained significant contamination (i.e., levels of chemical or bacterial
contaminants exceeding those allowed under a state or industry standard or
guideline) in at least one test. This is the most comprehensive independent testing
of bottled water in the United States that is publicly available. Moreover, NRDC
contracted with an independent data verification firm to confirm the accuracy of
our positive test results. Still, the testing was limited. The labs tested most waters
for about half of the drinking water contaminants regulated by FDA (to control
costs). They found:
o Nearly one in four of the waters tested (23 of the 103 waters, or 22 percent)
violated strict applicable state (California) limits for bottled water in at least
one sample, most commonly for arsenic or certain cancer-causing man-
made ("synthetic") organic compounds. Another three waters sold outside
of California (3 percent of the national total) violated industry-
recommended standards for synthetic organic compounds in at least one
sample, but unlike in California, those industry standards were not
enforceable in the states (Florida and Texas) in which they were sold.
o Nearly one in five tested waters (18 of the 103, or 17 percent) contained, in
at least one sample, more bacteria than allowed under microbiological-
purity "guidelines" (unenforceable sanitation guidelines based on
heterotrophic plate count [HPC] bacteria levels in the water) adopted by
some states, the industry, and the EU. The U.S. bottled water industry uses
HPC guidelines, and there are European HPC standards applicable
overseas to certain bottled waters, but there are no U.S. standards in light
of strong bottler opposition to making such limits legally binding.
o In sum, approximately one third of the tested waters (34 of 103 waters, or
33 percent) violated an enforceable state standard or exceeded
microbiological-purity guidelines, or both, in at least one sample. We were
unable to test for many microbial contaminants, such as Cryptosporidium,
because the logistics and cost of testing for them post-bottling were
beyond our means.
o Four waters (4 percent) violated the generally weak federal bottled water
standards (two for excessive fluoride and two for excessive coliform
bacteria; neither of the two latter waters were found to be contaminated
with coliform bacteria in our testing of a different lot of the same brand).
o About one fifth of the waters contained synthetic organic chemicals -- such
as industrial chemicals (e.g., toluene or xylene) or chemicals used in
manufacturing plastic (e.g., phthalate, adipate, or styrene) -- in at least one
sample, but generally at levels below state and federal standards. One
sample contained phthalate -- a carcinogen that leaches from plastic -- at a
level twice the tap water standard, but there is no bottled water standard
for this chemical; two other samples from different batches of this same
water contained no detectable phthalate.
o In addition, many waters contained arsenic, nitrates, or other inorganic

contaminants at levels below current standards. While in most cases the
levels found were not surprising, in eight cases arsenic was found in at
least one test at a level of potential health concern.
o For purposes of comparison, we note that EPA recently reported that in

1996 about 1 in 10 community tap water systems (serving about one
seventh of the U.S. population) violated EPA's tap water treatment or
contaminant standards, and 28 percent of tap water systems violated
significant water-monitoring or reporting requirements. In addition, the tap
water of more than 32 million Americans (and perhaps more) exceeds 2
parts per billion (ppb) arsenic (the California Proposition 65 warning level,
applicable to bottled water, is 5 ppb); and 80 to 100 million Americans drink
tap water that contains very significant trihalomethane levels (over 40 ppb).
Thus, while much tap water is supplied by systems that have violated EPA
standards or that serve water containing substantial levels of risky
contaminants, apparently the majority of the country's tap water passes
EPA standards. Therefore, while much tap water is indeed risky, having
compared available data we conclude that there is no assurance that
bottled water is any safer than tap water.
• Other academic and government bottled water surveys generally are consistent
with the testing NRDC commissioned. Though usually limited in scope, these
studies also have found that most bottled water meets applicable enforceable
standards, but that a minority of waters contain chemical or microbiological
contaminants of potential concern.
Recommendations
Every American has a right to safe, good-tasting water from the tap. If we choose to buy
bottled water, we deserve assurances that it too is safe. In addition, whether our water
comes from a tap or a bottle, we have a right to know what's in it. Among our key
recommendations are:
• FDA should set strict limits (equivalent to those in California, EPA rules,
international standards, or industry guidelines, whichever is most health
protective) for contaminants of concern in bottled water, including arsenic,
heterotrophic-plate-count bacteria, E. coli and other parasites and pathogens,
Pseudomonas aeruginosa, and synthetic organic chemicals, including chemicals
such as phthalate, which can leach from plastic.
• FDA's rules should be overhauled and should apply to all bottled water distributed
nationally or within a state, carbonated or not. To comply with common sense and
a new requirement tucked into the 1996 Safe Drinking Water Act Amendments,
FDA standards must be made at least as strict as those applicable to city tap water
supplies. The FDA should adopt rules for bottled water testing, to control microbial
and chemical contaminants, to protect water sources, to ensure the reporting of
test results and violations to state and federal officials, to train and certify
operators of water bottling plants, and to require the use of certified labs. In
addition, FDA should do its own audits and monitoring of the quality of bottled
water sold across the nation and should publicly release the results.
• Right-to-know requirements should require water-bottle labels to disclose

contaminants, the exact water source, treatment, and other key information, as is
now required of tap water systems. If bottled water is so pure, why not prove it
with full disclosure on the label?
• FDA's bottled water program and state programs must be better funded, with a
new penny-per-bottle fee on bottled water to fund regulatory programs, testing,
and enforcement.
• State bottled water programs should be subject to federal review and approval,
and should receive federal funding from the penny-per-bottle fee recommended
above.
• If FDA fails within 18 months to make its bottled water rules and its regulatory
oversight and enforcement at least as stringent as those for tap water, the bottled
water regulatory program and funding for it (including the proceeds from a penny-
per-bottle fee) should be transferred to EPA. We recommend this transfer with
some trepidation, in light of EPA's less-than-perfect tap water program and its own
serious resource constraints. We conclude, however, that it would be hard for EPA
authority to be worse than FDA's seriously deficient program, and that a transfer of
funding for bottled water supervision to EPA from FDA would help. Clearly EPA
has more resources dedicated to drinking water and has adopted stricter rules and
oversight of state programs than FDA has. More stringent EPA tap water rules
should be applied to bottled water within six months after transfer of authority.
• A credible independent third-party nongovernmental organization should establish

a "certified safe" bottled water program that is truly open, ensures full compliance
with all FDA, EPA, state, industry, and international standards and guidelines, does
twice-a-year surprise inspections, documents sufficient source protection and
treatment to meet EPA/Centers for Disease Control and Prevention (CDC) criteria
for Cryptosporidium-safe bottled water, and makes readily available (including on
the Web) all inspections and monitoring results. Currently neither NSF nor
International Bottled Water Association certifications have sufficiently stringent
criteria, nor are they sufficiently independent of the industry, to provide consumer
confidence that such strict standards are met. Immune-compromised or other
vulnerable people particularly may want such certification to be fully confident of
their bottled water's purity.
• While we reasonably may choose to use bottled water for convenience, taste, or as
a temporary alternative to contaminated tap water, it is no long-term national
solution to this problem. Bottled water sometimes is contaminated, and we don't
use it to bathe, shower, etc. -- major routes of exposure for some tap water
contaminants. A major shift to bottled water could undermine funding for tap water
protection, raising serious equity issues for the poor. Manufacture and shipping of
billions of bottles causes unnecessary energy and petroleum consumption, leads
to landfilling or incineration of bottles, and can release environmental toxins. The
long-term solution to our water woes is to fix our tap water so it is safe for
everyone, and tastes and smells good.
Chapter 1
PRINCIPAL FINDINGS AND RECOMMENDATIONS

Americans increasingly are turning to bottled water, making it a $4 billion-a-year business
in the United States. [1] Millions of us are willing to pay 240 to over 10,000 times more per
gallon for bottled water than we do for tap water -- though we probably rarely think of it
that way. [2] However, some bottled water contains bacterial contaminants, and several
brands of bottled water contain synthetic organic chemicals (such as industrial solvents,
chemicals from plastic, or trihalomethanes -- the by-products of the chemical reaction
between chlorine and organic matter in water) or inorganic contaminants (such as arsenic,
a known carcinogen) in at least some bottles (see Chapter 3 and our accompanying
Technical Report [print report only]).[1a] Moreover, as Chapter 4 documents, bottled water
regulations have gaping holes, and both state and federal bottled water regulatory
programs are severely underfunded. In Chapter 5 we present evidence that there is
substantially misleading marketing of some bottled water, and in Chapter 6 we argue that
consumers should be informed about the contaminants found in the water they purchase.
NRDC's major findings and recommendations are summarized below.
Findings
1. Most bottled water apparently is of good quality, but some contains
contamination; it should not automatically be assumed to be purer or
safer than most tap water.
Based on available data and our testing, most bottled water is of good quality, and
contamination posing immediate risks to healthy people is rare (see Chapter 3 and the
Technical Report [print report only]). However, blanket reassurances from the bottled
water industry that bottled water is totally safe and pure are false.
No one should assume that just because water comes from a bottle that it is necessarily
any purer or safer than most tap water. Testing commissioned by NRDC and studies by
previous investigators[3] show that bottled water is sometimes contaminated. NRDC
contracted with three leading independent laboratories to do "snapshot" testing (testing
one to three times for a subset of contaminants of concern) of bottled water.
We found after testing more than 1,000 bottles that about one fourth of the bottled water
brands (23 of 103 waters, or 22 percent) were contaminated at levels violating strict
enforceable state (California) limits for the state in which they were purchased, in at least
one sample. We also found that almost one fifth of the waters we tested (18 of 103, or 17
percent) exceeded unenforceable sanitary guidelines for microbiological purity
(heterotrophic-plate-count [HPC] bacteria guidelines, adopted in some states, the
European Union (EU), and recommended by the bottled water industry) in at least one test.
While HPC bacteria may be harmless themselves, they may mask the presence of
pathogens; some states, the EU and the bottled water industry have adopted HPC
guidelines to help ensure sanitary source water, processing, and bottling practices. In all,
at least one sample of one third of the waters we tested (34 of 103, or 33 percent) exceeded
a state enforceable standard for bacterial or chemical contamination, a nonenforceable
microbiological-purity (HPC) guideline, or both.
The labs contracted by NRDC detected contaminants of potential concern (either microbes
or chemicals regulated in tap or bottled water) in at least one sample of about half of the
bottled waters we tested, though in the majority of the waters no standards were
exceeded. While state or industry standards and guidelines were violated in at least one
test for about one fourth of the bottled waters, just four waters (4 percent) exceeded the
weak federal standards. Of these four waters, two violated the FDA coliform-bacteria rule
(coliforms are bacteria that can be harmless themselves but may indicate the presence of
fecal contamination and disease-carrying organisms in the water) in one test. When we
retested another lot of the same waters for coliform bacteria, however, both of these
waters tested clean. In addition, two other waters violated the FDA standard for fluoride in
two sequential tests of samples from different lots of these two waters.
While our testing is the most comprehensive publicly available independent testing of U.S.
bottled water, it must be viewed as incomplete. Only about half of the drinking water
contaminants regulated by FDA and EPA were tested, due to cost constraints. There are,
conservatively, more than 700 brands selling bottled water in the United States, yet we
tested only 103 waters. Additionally, we generally tested just one to three lots of each
water, whereas often thousands or even millions of bottles may be produced annually by a
single bottler, with the potential for periodic (and undetected) contamination problems.
Testing by other investigators generally has been consistent with our results. For
example, as is discussed in detail in the accompanying Technical Report (print report
only), a major survey of microbiological contamination of domestic and imported bottled
water sold in Canada published in 1998 yielded results very similar to NRDC's. [4] We were
not able to test for Cryptosporidium in bottled water (nor did the Canadian investigators)
because the current EPA method for Cryptosporidium monitoring requires the filtration of
many gallons of water and analysis of the filter using a method feasible for bottlers prior
to bottling the water, but this was logistically and financially infeasible for us to use on
finished product sold at stores.
Bottled water recalls and other contamination incidents -- whether bacterial, industrial-
chemical, algae, excessive-chlorine, or other contamination problems -- have sometimes
been quietly dealt with by bottlers, generally with little or no public fanfare. In other cases,
violations of bottled water standards have been allowed to go on for months without a
recall or formal enforcement action. Although most of the bottled water on the market
seems to be of good quality, some of these products are not as absolutely pure and
pristine as many of their consumers may expect.
Comparing the data for bottled water quality with those for tap water is not
straightforward. Far more monitoring data are publicly available for tap water than for
bottled water. EPA requires frequent monitoring of tap water and makes available on its
Web site national compliance data for all tap water systems. [5] Additionally, numerous
surveys of tap water quality (beyond simple compliance data) are available for tap water
quality, [6] whereas no such comprehensive data are available for bottled water. Thus,
direct comparison of tap water quality versus bottled water quality is not possible based
on comparable databases. However, EPA recently reported that in 1996, almost 10 percent
of community tap water systems (serving 14 percent of the U.S. population) violated
federal EPA tap water treatment or contaminant standards, and 28 percent of these tap
water systems violated significant water quality monitoring or reporting requirements. [7]
While these tap water system compliance data are plagued by underreporting and likely
understate the extent of the problem somewhat, [8] without question they are based on a far
larger database than is publicly available for bottled water. Moreover, according to
available data, nearly half of the U.S. population served by tap water systems gets legally
allowable but from a health standpoint potentially significant levels of contaminants such
as cancer-causing trihalomethanes, radon, and/or arsenic in their tap water. [9] Thus, while
there definitely are problems with a substantial minority of the nation's tap water systems,
based on the limited data available there is little basis to conclude that just because water
is purchased in a bottle it is necessarily any better than most tap water.
2. Bottled water contamination with microbes may raise public health

issues, particularly for people who are immunocompromised.
Millions of Americans use bottled water as their primary source of drinking water. Some of
these people are immunocompromised (such as people undergoing cancer chemotherapy,
organ-transplant recipients, the chronically ill elderly, some infants whose immune
systems are not fully developed, and people with AIDS) and use bottled water at the
recommendation of public health officials or health care providers, who suggest that tap
water use may be too risky.[1b] In some cases, officials also may urge the general public to
use bottled water during a tap water contamination crisis.
As discussed in Chapter 3 and our attached Technical Report (print report only), NRDC's
testing and other published and unpublished data indicate that while most bottled water
apparently is of high quality in terms of microbiological purity, a substantial minority of it
may not be. As noted there, a small percentage of the bottled water we tested (about 3
percent) sometimes contained coliform bacteria -- a possible indicator of contamination
with pathogenic bacteria -- and nearly one fifth of the waters we tested contained
heterotrophic-plate-count (HPC) bacteria at levels exceeding state and industry guidelines
in at least one test. Some bottled waters contain bacteria (sometimes naturally occurring),
including species of Pseudomonas and others, some of which may be a health concern for
immunocompromised people. [10]
In cases where there is known tap water microbial contamination, or where an individual
suffers from specific health problems such as a compromised immune system, tap water
can be boiled for one minute to kill all microbes. In the alternative, certain types of bottled
water may be a temporary solution. To be cautious, however, an immunocompromised
person should buy bottled water only if it is from a protected source, and is subjected to
EPA-CDC-recommended treatment to kill Cryptosporidium, the intestinal parasite that
sickened over 400,000 people and killed over 100 in a 1993 Milwaukee tap water incident.
[11]
For example, to remove or kill Cryptosporidium, water must be treated with "absolute
one micron" membrane filtration or reverse osmosis, adequately high levels of ozone
disinfection, or distillation, at a minimum.
Thus, NRDC recommends that seriously immunocompromised people boil their tap water
for one minute before using it for consumption or washing food. If they choose to buy
bottled water, they should consider purchasing only certified "sterile" bottled water. Most
bottled water has not been independently certified to meet either the EPA-CDC standards
for killing Cryptosporidium or the definition of "sterile" water, so vulnerable people must
be especially careful in selecting a drinking water supply.[1c]
3. Government bottled water regulations and programs have serious

deficiencies.
Chapter 4 outlines in detail the gaping holes in federal regulatory controls for bottled
water, and the trivial FDA resources dedicated to protecting bottled water. FDA estimates
that one half of a full-time FDA staff person is dedicated to bottled water regulation, and
fewer than one FDA staff-person equivalent is spent on assuring compliance with FDA
bottled water rules. [12] An estimated 60 to 70 percent of the bottled water sold in the United
States, according to FDA interpretations, is exempted from FDA's contamination limits and
specific bottled water standards because it is bottled and sold in the same state.
Thus, under FDA's interpretation, the regulation of most bottled water is left to ill-equipped
and understaffed state governments. Yet 43 of 50 states have the equivalent of fewer than
a single staff person dedicated to regulating bottled water, according to our 1998 state
survey. Four states have adopted no regulations at all for bottled water, and the majority
of states have simply republished FDA's deficient rules. About 40 states say they regulate
"intrastate" waters, but most have dedicated virtually no resources to doing so.
FDA's rules also exempt many forms of what most of us would consider "bottled water"
from all of its specific water-testing and contamination standards. If the product is
declared on the ingredient label simply as "water," "carbonated water," "disinfected
water," "filtered water," "seltzer water," "sparkling water," or "soda water," it is not
considered "bottled water" by FDA, [13] nor, as noted in Chapter 4, do most states regulate
this water as bottled water. For these products, the specific FDA contamination standards
and water quality testing requirements for bottled water are not applicable. No
contamination monitoring is required, and only a vague narrative legal standard applies,
stating that the water cannot be "adulterated" -- a term not specifically defined and, to
date, apparently never enforced against any of these products by FDA. Therefore, the
generalized FDA "good manufacturing practice" requirements applicable to these waters[14]
set no specific contamination standards. The same is true with most state regulations.
Even what FDA defines to be "bottled water" is exempt from many of the standards and
testing requirements that apply to tap water. This appears to directly contradict the letter
and the spirit of the Federal Food, Drug, and Cosmetic Act (FFDCA), which requires --
under a provision strengthened in 1996 -- that FDA's bottled water standards must be at
least as stringent as tap water standards. [15] For example, EPA's rules clearly prohibit tap
water from containing any confirmed E. coli or fecal coliform bacteria (bacteria that are
indicators of possible fecal matter contamination often associated with waterborne
disease). [16] FDA has no such prohibition for bottled water; instead, any type of coliform
bacteria is allowed up to a certain level. [17] (See Table 1 for a comparison of EPA and FDA
rules.)
Similarly, a big city has to test its tap water 100 times or more each month for coliform
bacteria -- many times a day, on average -- yet bottled water (even at an enormous bottling
plant) must be tested for coliform bacteria only once a week under FDA rules. Moreover,
while high overall levels of bacteria (known as heterotrophic-plate-count [HPC] bacteria)
can be counted toward bacteria violations for city tap water (in the absence of adequate
disinfection), as described in Chapter 4, FDA bowed to bottled water industry arguments
and decided to apply no standards for HPC bacteria in bottled water. HPC bacteria are
commonly found in bottled water.
EPA's "information collection rule" generally requires big cities that use surface water
(such as rivers or lakes) for tap water to test for common parasites such as viruses,
Giardia, and Cryptosporidium. Under FDA rules, water bottlers are never required to do so.
In the same vein, cities using surface water generally must disinfect their water and filter it
to remove bacteria and certain parasites.[1d] Yet there are no FDA standards requiring
bottled water to be disinfected or treated in any way to remove bacteria or parasites.
Additionally, the FDA requirement that bottled water be derived from an "approved
source" is no substitute for source water protection, filtration, or disinfection. This rule
has been aptly characterized as a "regulatory mirage," since what is "approved" is left to
state discretion with no meaningful federal requirements or oversight.
For chemical contaminants, the regulations for bottled water are also weak in many ways.
While a city generally must test its tap water for scores of organic chemicals (such as
industrial chemicals, some pesticides, and trihalomethanes) at least quarterly,[1e] bottlers
generally need only test once a year under FDA's rules. These infrequent annual tests
could miss serious problems, because levels of these contaminants sometimes vary
substantially depending on when they are tested.
Also, phthalate[1f] -- a toxic chemical produced in plastic-making that tests show can leach
from plastic into water under common conditions -- is regulated by EPA in tap water but
FDA does not regulate it in bottled water. After some water bottlers and plastics
manufacturers argued that phthalate controls would be inappropriate and burdensome for
bottled water, FDA decided not to regulate it in bottled water, where it is sometimes found,
particularly after long storage.
Furthermore, FDA currently has no enforceable standard or treatment requirement for

three other contaminants regulated by EPA in tap water -- acrylamide, asbestos, and
epichlorohydrin. Thus, while city water systems generally must test for all of these
contaminants and must meet EPA standards for them, presently water bottlers need not.
EPA also requires city tap water suppliers to test for more than a dozen "unregulated"
contaminants -- chemicals that are not currently subject to EPA standards but which, if
present, may pose a health concern, such as a risk of cancer. Under EPA rules, states are
to consider adding 15 additional named unregulated contaminants to this list for
mandatory water system monitoring, if they are believed to be a potential problem in local
tap water. [18] Bottlers face no monitoring requirements for any unregulated contaminants.
Even if bottled water is more contaminated than FDA's standards would otherwise allow,
FDA rules explicitly allow the water to be sold, as long as it says on the label "contains
excessive chemical substances" or "contains excessive bacteria" or includes a similar
statement on the label. FDA says it may enforce against such labeled contaminated water
if it finds that it is "adulterated" and "injurious to health." However, there is no
requirement that water bottlers report such problems to FDA, and apparently there are no
cases of FDA having taken any enforcement action against any such bottlers.
FDA has stated that bottled water regulation carries a low priority. [19] Because of this,
water bottlers can expect to be FDA-inspected only about every four to five years, on
average. [20] This is far too infrequent to detect certain possible problems, such as periodic
contamination caused by occasional substandard plant operations or maintenance,
bacteria from sewage overflows or leaks, pest infestations, or occasional spikes of
pollution due to short-lived phenomena. In addition, bottlers are not required to keep
records of their operations and testing for more than two years, making effective
inspections difficult or impossible, since evidence of periodic or past problems can simply
be discarded before it is ever reviewed by inspectors.
It also should be noted than in many cases FDA's rules are weaker than international
standards. The European Union's (EU's) bottled water standards, for example, set limits
for total bacteria count, [21] which, as noted above, FDA does not. Moreover, the EU's
bottled mineral water rules ban all parasites and pathogenic microorganisms, E. coli or
other coliform bacteria, fecal streptococci (e.g., Streptococcus faecalis, recently renamed
Enterococcus faecalis), Pseudomonas aeruginosa, or sporulated sulphite-reducing
anaerobes, whereas FDA's rules include no such bans. [22] Additionally, unlike the FDA
rules, EU rules require natural mineral water's labels to state the waters' "analytical
composition, giving its characteristic constituents" and the specific water source and
name, and information on certain treatments used. [23] The EU mineral water rules further
forbid use of more than one brand label per source of water[24] and generally prohibit labels
from making any claims about the prevention, treatment or cure of human illness. [25] No
such provisions are included in FDA rules. Similarly, the EU's new general standards for
all bottled water generally are far stricter than FDA's rules, and FDA's standards for certain
chemicals (such as arsenic) are weaker than World Health Organization (WHO) guidelines
for drinking water. [26]
4. Voluntary bottled water industry controls are commendable, but an

inadequate substitute for strong government rules and programs.
The bottled water industry's trade association, the International Bottled Water Association
(IBWA), has sometimes been a progressive force in seeking to improve certain FDA
controls (petitioning for stronger FDA rules in some areas, for example). Moreover, IBWA
has adopted a voluntary state bottled water code -- somewhat stricter than the FDA rules --
which has been adopted in whole or in part by 16 states. However, IBWA sometimes has
vigorously fought against tough FDA rules, such as possible controls on Pseudomonas
aeruginosa bacteria, rules for heterotrophic bacteria, and right-to-know requirements for
bottled water. The fight against right-to-know for bottled water is interesting in light of the
bottled water industry's frequent references to tap water contamination problems. It also
starkly contrasts with IBWA's admission that bottled water sales may have increased due
to the requirement that diet soda labels disclose all ingredients, which IBWA said may
have driven consumers concerned about diet soda's contents to use bottled water. [27]
IBWA has adopted a much-ballyhooed voluntary industry code and inspection program for
its members. The association claims its members produce 85 percent of the bottled water
sold in the United States. [28] But these voluntary IBWA standards are just that -- voluntary -
- in the 34 states that have not adopted them, and there is no published reporting about
compliance. Additionally, IBWA does not disclose the results of its inspections and testing
to the public, so it is impossible to verify independently the effectiveness of these
voluntary programs. Moreover, even by IBWA's count, many bottlers are not IBWA
members and have never volunteered to comply with the association's standards. In fact,
some of the problems with some bottled waters discussed in this report have occurred
with IBWA members, suggesting the IBWA program is not foolproof. Finally, it should be
noted that, as with FDA rules, IBWA standards do not apply to seltzer, soda water,
carbonated water, or the many other waters exempt from FDA's bottled water rules. [29]
5. Bottled water marketing can be misleading.

Chapter 5 shows that despite recent FDA rules intended to reduce misleading marketing,
some bottled water comes from sources that are vastly different from what the labels
might lead consumers to believe. One brand of water discussed in this report was sold as
"spring water" and its label showed a lake and mountains in the background -- with FDA's
explicit blessing. But until recently the water actually came from a periodically
contaminated well in an industrial facility's parking lot, near a waste dump (a state
whistleblower informed the local media after years of internal struggles, finally putting an
end to the use of this source).[30] Another brand of water sold with a label stating it is "pure
glacier water" actually came from a public water supply, according to state records.[31]
While FDA recently adopted rules intended to curb such practices, those rules include
many weak spots and loopholes (including those that allowed the water taken from an
industrial-park well to be sold as spring water with a label picturing mountains), and there
are very few resources to enforce them.
Water with one brand name can come from numerous different sources, depending upon
the time of year, location of sale, or other market factors. Moreover, water from one source
(such as the industrial-parking-lot well noted above) can be used and labeled for a half-
dozen or more different labels and brands. In addition, according to government and
industry estimates, about one fourth or more of the bottled water sold in the United States
[32]
(and by some accounts 40 percent[33]) is taken from public water systems -- tap water,
essentially. Sometimes this tap water is bottled after additional treatment (such as carbon
filtration or ozonation), and sometimes it is bottled with little or no additional treatment.
6. The long-term solution to drinking water problems is to fix tap

water -- not to switch to bottled water.
Many people may choose to use bottled water because they prefer its taste and smell, or
because it is convenient. Bottled water, in some cases, also may be needed as a stopgap
measure when tap water is contaminated, rendering the water nonpotable (as in the case
of a boil-water alert). In the long run, however, it is far better from an economic,
environmental, and public health point of view to improve public drinking water supplies
than it is to have a massive societal shift from consumer use of tap water to use of bottled
water. We cannot give up on tap water safety. The reasons we have reached this
conclusion include:
• Public health concerns. Bottled water sometimes poses its own potential health
risks due to contamination. Furthermore, even if bottled water is completely pure,
use of it can only somewhat reduce public exposure to contaminants in tap water;
some people will continue to use tap water. Even if no one were to drink tap water,
virtually everyone would continue to be exposed to some common contaminants
(especially those that are volatile or can penetrate the skin) when showering,
bathing, washing dishes, and cooking.
• Equity concerns. If those who can afford bottled water shift to it as their primary
source of drinking water, only low-income people are left drinking tap water, its
quality may then slip into an ever-downward spiral.
• Environmental concerns. Provision of water by underground pipe is energy-

efficient and consumes far fewer natural resources per gallon than using bottled
water. Placing water in bottles and transporting those heavy bottles around the
country (or around the globe) consumes far more energy and other resources than
using tap water. The manufacture of bottles also can cause release of phthalates,
and other byproducts of plastic-making, into water, air, or other parts of the
environment. And, ultimately, many bottles will be added to already overflowing
landfills or incinerated, potentially adding to our environmental problems.
• Economic concerns. Bottled water typically costs hundreds of times more than tap
water, even up to 10,000 or more times more than what comes out of your faucet.
These costs cannot be easily borne by low-income people and should not have to
be borne by the elderly, the immunocompromised, or chronically ill people in order
to get water that is safe to drink. The $4 billion a year now spent by consumers on
bottled water could be better spent on upgrading tap water supplies.
Thus, in NRDC's view, although bottled water may be a convenience or needed as a short-
term solution to tap water contamination problems in some communities or for highly
vulnerable subpopulations, it should generally be viewed only as a temporary fix. Our
study leads us to make the following recommendations:
Recommendations
1. Fix tap water quality -- don't give up and just rely on bottled water.
For the reasons just noted, it would generally be better to upgrade and improve tap water
quality than to have a part of society shift to bottled water. Those who dislike the taste and
smell of their tap water may want to consider placing tap water in a glass or ceramic
pitcher in their refrigerator, with the top loose to allow the chlorine to dissipate overnight.
This also will allow volatile disinfection by-products to evaporate (though less volatile
disinfection by-products may stay in the water). Overnight refrigeration in a loosely
capped container eliminates the objectionable chlorine taste and odor, and the chilled
water can be put in reusable sports bottles as desired to make it convenient to carry ice-
cold water to the office, on trips, or when exercising. It also saves money and has
environmental and other benefits, as previously noted.
2. Establish the public's right to know for bottled water as now

required for tap water.
Bottled water labels should be required to list any contaminants found in the water (as
well as health goals and standards), the water's fluoride and sodium content, the health
effects of the contaminants found, the bottler's compliance with applicable standards, the
source of the water, and any treatment used. Labels also should indicate whether the
water meets the EPA-CDC criteria for Cryptosporidium safety. The date of bottling and
information on how to get further information also should be placed on labels. We fail to
understand why, if bottled water is as pure as the bottlers say, they are so afraid of a right-
to-know requirement. However, FDA has the authority to require such information on
bottled water labels, has been required by the Safe Drinking Water Act to evaluate the
feasibility of doing so, and therefore should move forward with rules requiring such
disclosure for bottled water.
3. FDA should create a Web site and a phone-accessible information

system on bottled water.
FDA should add to its Web site and should make available, through a hot line, a user-
friendly array of information on bottled water brands, including all of the basic information
noted in recommendation 2, for each bottler. This bottled water information should build
upon and expand the EPA hotline and web site that gives specific information on
individual tap water systems and drinking water generally. The FDA hot line and Web site
should make available the results of all government, industry, or other bottled water
testing by certified labs for all brands. It also should include information on all inspections
and recalls, and any other relevant consumer information on particular brands of bottled
water.
4. Overhaul FDA rules for bottled water.

The FDA rules for bottled water are weak and should be strengthened. If necessary, FDA
should request additional legislative authority to adopt these changes. FDA should:
• Establish standards and monitoring requirements for bottled water no less

stringent than EPA's rules for tap water in major cities, including standards for all
microbiological and chemical contaminants, specific and defined water treatment
(including filtration and disinfection or strict source-protection requirements),
operator-certification requirements, and unregulated-contaminant monitoring
rules.
• Set strict, up-to-date standards for contaminants potentially found in bottled water.
These standards should be at least as protective of public health as the strictest
regulations adopted by other authorities. Thus, the standards should be as
stringent as possible for the bottled water industry and certainly should be no less
stringent than the following: arsenic less than 5 parts per billion (ppb)(California
Proposition 65); heterotrophic-plate-count bacteria less than 100 colony-forming
units per milliliter at bottling (EU standard), 200 cfu/ml 5 days after bottling in 90
percent of samples (industry recommendation), and a maximum at all times of 500
cfu/ml; no parasites, pathogens, fecal streptococci (e.g., the recently renamed
Enterococcus faecalis), Pseudomonas aeruginosa, sporulated sulphite-reducing
anaerobes (EU natural mineral water rules); trihalomethanes less than 10 ppb
(California law and industry model code); phthalate less than 6 ppb (EPA tap
water); individual synthetic organic and inorganic chemicals (e.g.,
bromodichloromethane) equal to California's Proposition 65 levels. For other
contaminants more strictly controlled under bottled water industry code than
under current FDA rules or with EPA Health Advisories, FDA should adopt the
industry or EPA recommendation.
• Immediately finalize its 1993 proposed ban on coliform bacteria in bottled water.
• Establish clearly defined criteria and protections for an "approved source" of

bottled water under FDA rules, and require annual state reevaluation of compliance
with these new "approved source" rules, including review of potential
contamination problems.
• Require bottlers to retain microbial test results for 5 years, and chemical tests for
10 years, as EPA requires for tap water.
• Mandate a bottling date and "refrigerate after opening" statement on labels, in

order to inform consumers who seek to minimize the chances of potentially
excessive microbial growth and contamination in bottled water.
• Require labs used for bottled water analysis to be certified by EPA or FDA.
• Direct that water be tested daily at the plant for microbes, quarterly for chemicals
during bottling, and quarterly in bottles after extended storage, especially for
chemicals that can leach from bottles and for microbes that can multiply during
storage.
• Require quarterly reporting of test results to states and FDA, and reporting of
acute violations within 24 hours to state and FDA officials.
• Prohibit all sales of water contaminated at levels above FDA standards.
• Apply FDA's standards to all intrastate bottled water sales.
• Mandate that water bottlers be trained and certified.
• Require state bottled water programs to be reviewed and approved by FDA, and
FDA should oversee their effectiveness.
• Establish clear mandatory recall authority for FDA through administrative order or
a civil action.
• Maintain an inventory, and register all water bottlers.
• Cover all water sold in a bottle that is likely to be ingested by people, including
"purified," "disinfected," "seltzer," etc., under the FDA bottled water standards --
as under California and other states' laws.
• Conduct routine FDA monitoring of bottled water quality for waters sold across the
country, as has been done in Canada for many years, and release the results,
including brand names, to the public in published reports and on its website.
5. Annual inspections should be required.
FDA should conduct annual inspections (or fund annual state inspections) of all bottling
facilities and of their water sources.
6. Institute a "penny-per-bottle" fee to assure bottled water safety.

We recommend that a fee of one cent per bottle of bottled water sold should be instituted,
to be placed in a trust fund for use without further appropriation by FDA to pay for a
stringent bottled water regulatory program. The fee, which we estimate would raise more
than $30 million dollars a year, should fund improved FDA implementation, random
testing, a public Web site, state and federal inspections, and funding and oversight of
state programs and bottlers.
7. Set a deadline for transferring the bottled water program to EPA if

FDA lacks the resources or will to implement it effectively.
FDA has made it clear that bottled water protection is a low priority. If FDA concludes that
making bottled water comply with the same requirements as tap water is unduly
burdensome, or that the preceding recommendations to achieve that goal are not of
sufficient priority to claim FDA resources, the program should be transferred to EPA,
which already regulates tap water. FDA should be given no more than 18 months to
demonstrate, by overhauling its rules and program, whether it wishes to retain the
program. If such an overhaul does not occur, the program should be automatically
transferred to EPA. EPA should be given six months to apply the rules applicable to big
city water systems to bottled water; of course, the rules should be modified where they
would be inapplicable to bottled water (as where EPA rules require monitoring at the tap).
EPA also should be provided the revenue from a penny-per-bottle fee on bottled water to
carry out the program. We make this recommendation for transfer with some uneasiness,
since EPA's tap water regulatory program suffers from its own serious deficiencies and
resource constraints. However, on balance we believe that if FDA continues to lack the will
and resources to address bottled water issues as the sales skyrocket, even an inadequate
EPA bottled water regulatory program could hardly be worse than FDA's current effort.
8. Establish "certified safe" bottled water.

In light of the poor government regulatory performance, an independent third-party
organization such as Green Seal or Underwriters Labs should establish a "certified safe"
bottled water program. Criteria for inclusion would be that the water always meets the
strictest of all standards, including FDA, IBWA, international (e.g., EU and WHO) and state
rules, recommendations, and guidelines, meets all EPA health goals, health advisories,
and national primary drinking water regulations, is tested at least daily for microbial
contaminants and quarterly for chemicals (monthly if using surface water or other water
subject to frequent water quality changes), meets source-water protection criteria, is
protected from Cryptosporidium in accordance with EPA-CDC guidelines, is disinfected,
and is surprise inspected twice a year by independent third-party inspectors. The
certifying organization should establish an open-docket release of its inspection, testing,
and compliance evaluation results. While the current NSF and IBWA seals are intended to
provide such a stamp of approval, we believe a more independent and open body
imposing stricter standards and making all testing, inspection, and other collected
information readily available to consumers (including on the Web), would provide greater
consumer confidence in the certification.
Thus, we believe the long-term national solution is to fix the nation's tap water supplies.
Until the recommended regulatory changes are adopted, those who wish to use bottled
water for reasons of taste or otherwise cannot be confident that they are necessarily
getting what they pay for -- a pure, well-regulated product. Unless such reforms are
adopted, bottled water consumers should observe the ancient rule of caveat emptor --
"buyer beware.")
Chapter Notes
1a. Throughout this document we use the term contaminant in the same way that term is used in the Safe Drinking Water
Act (SDWA) -- i.e, "any physical, chemical, biological, or radiological substance or matter in water." 42 U.S.C. § 300f(6).
1b. EPA and CDC have jointly recommended that severely immunocompromised people consult with their health care
provider to decide whether they should drink tap water or switch to bottled water treated with certain advanced
technologies (or use tap water that is boiled or treated with an advanced home filter). However, we have found that very
few bottled water companies clearly label their bottles to enable consumers to determine whether the water meets the
EPA-CDC recommendations.
1c. The use of home filtration devices is an issue beyond the scope of this study, but experts recommend that at a
minimum, an immunocompromised person should only purchase a filter certified by NSF International for "cyst removal"
(i.e., to remove protozoa "cysts," such as Cryptosporidium). In addition, users of home filters must be extremely careful
to maintain the filter and to change the filtration media at least as frequently as recommended by the manufacturer, or
more often.
1d. Cities using surface water as their source generally must disinfect, unless they can document and obtain state
approval for a filtration waiver, based on evidence that their source water is pure and highly protected from
contamination.
1e. In certain cases, EPA's rules allow tap water to be tested less frequently than quarterly for some organic
contaminants. For example, a waiver may be available to a system if the contaminant was not detected in the first round
of four quarterly tests and the system is evaluated by the state and found unlikely to become contaminated in the future.
1f. Specifically, di(2-ethylhexyl)phthalate, or DEHP--a likely carcinogen that studies have indicated also may cause
disruption of the endocrine system. See, e.g., B.J. Davis, R.R. Maronpot, and J.J. Heindel, " Di-(2-ethylhexyl) phthalate
Suppresses Estradiol and Ovulation in Cycling Rats," Toxicol Appl Pharmacol, vol. 128, no. 2, pp. 216-223 (October
1994),(exposure to DEHP resulted in hypoestrogenic anovulatory cycles and polycystic ovaries in adult female rats).
Report Notes
1. Beverage Marketing Association, 1998 data cited in "Advertising & Marketing:Waterlogged," Los Angeles Times p. D5
(April 23, 1998); Tim Madigan, Fort Worth Star-Telegram, August 24, 1997, page 1.
2. The bottled water NRDC purchased ranged in price from a low of about $0.70 per gallon to more than $5.00 per gallon
for more expensive imports sold in smaller bottles. The average cost of bottled water in California has been reported to
be $0.90 cents per gallon, though that appears to be a low estimate compared to most of our purchases. Tap water
generally costs from a low of around $0.45 cents per thousand gallons to about $2.85 per thousand gallons, with an
average cost of about $1.60. L. Allen & J.L. Darby, "Quality Control of Bottled and Vended Water in California: A Review
and Comparison of Tap Water," Journal of Environmental Health, vol. 56, no. 8, pp. 17-22 (April 1994); "Bottled Water
Regulation," Hearing of the Subcommittee on Oversight and Investigations of the House Committee on Energy and
Commerce, Serial No. 102-36, 102nd Cong., 1st Sess. 5, (April 10, 1991). Thus, the ratio for bottled water to tap water
ranges from a low of about 240 times more expensive (cheap bottled water: expensive tap water), to over 10,000 times
more expensive (expensive bottled water: cheap tap water).
3. See Chapter 3 on bottled water contamination, and for more details see attached Technical Report (print report only)
on bacterial and chemical contamination of bottled water.
4. D. Warburton, B. Harrison, C. Crawford, R. Foster, C. Fox, L. Gour, and P. Krol, "A Further Review of the
Microbiological Quality of Bottled Water Sold in Canada: 1992-1997 Survey Results," International Journal of Food
Microbiology, vol. 39, pp. 221-226 (1998).
5. See www.epa.gov/enviro/html/sdwis/sdwis_ov.html
6. See, e.g. NRDC, USPIRG, and Clean Water Action, Trouble on Tap: Arsenic, Radon, and Trihalomethanes in Our
Drinking Water (1995); NRDC, Your Are What You Drink (1995); NRDC, Think Before You Drink (1993); NRDC, Think
Before You Drink: Urgent Release: 1992-1993 Update (1994); EWG & NRDC, Just Add Water (1996).
7. EPA, Providing Safe Drinking Water in America: 1996 National Public Water System Annual Compliance Report and
Update on Implementation of the 1996 Safe Drinking Water Act Amendments, Executive Summary (September
1998),(available at www.epa.gov/ogwdw).
8. See, e.g. NRDC, Think Before You Drink (1993); NRDC, Think Before You Drink: Urgent Release: 1992-1993 Update
(1994); EWG & NRDC, Just Add Water (1996).
9. See, e.g. NRDC, USPIRG, and Clean Water Action, Trouble on Tap: Arsenic, Radon, and Trihalomethanes in Our
Drinking Water (1995)
10. See, e.g., D.W. Warburton, "A Review of the Microbiological Quality of Bottled Water Sold in Canada, Part 2: The Need
for More Stringent Standards and Regulations," Canadian J. of Microbiology, vol. 39, p. 162 (1993); H. Hernandez-
Duquino, and F.A. Rosenberg, "Antibiotic-Resistant Pseudomonas in Bottled Drinking Water," Canadian J. of
Microbiology, vol. 33, pp. 286-289 (1987); P.R. Hunter, "The Microbiology of Bottled Natural Mineral Waters," J. Applied
Bacteriol., vol. 74, pp. 345-352 (1993); see also, F.A. Rosenberg, "The Bacterial Flora of Bottled Waters and Potential
Problems Associated With the Presence of Antibiotic-Resistant Species," in Proceedings of the Bottled Water Workshop,
September 13 and 14, 1990, A Report Prepared for the Use of the Subcommittee on Oversight and Investigations of the
Committee on Energy and Commerce, U.S. House of Representatives, Committee Print 101-X, 101st Cong., 2d Sess. pp.
72-83 (December 1990).
11. See, e.g. , W. R. MacKenzie, et al., "A Massive Outbreak in Milwaukee of Cryptosporidium Infection Transmitted
Through the Public Water Supply," New Engl. J. of Med. vol. 331, no. 3, pp. 161-167 (July 21, 1994); Marilyn Marchione,
"Silent Disaster: Crypto Has Killed 104 -- And Counting," Milwaukee Journal, p. 1 (March 27, 1994).
12. Personal Communication with Terry Troxel and Shellee Davis, FDA, September 18, 1997; Personal Communication
with Ron Roy, FDA, compliance programs, November 20, 1998.
13. 21 C.F.R. § 165.110(a)(1).
14. 21 C.F.R. part 110 (1997).
15. 21 U.S.C. § 349(b)(3).
16. See 40 C.F.R.§ 141.63(b), prohibiting any confirmed fecal coliform bacteria or E. Coli (i.e. confirmed with a repeat
sample).
17. 21 C.F.R. § 165.110(b)(2).
18. 40 C.F.R. § 141.40.
19. Interview with Terry Troxel, FDA, September 18, 1997.
20. Ibid.; 60 Fed. Reg. 57076, at 57117 (November 13, 1995).

21. European Union, Council Directive of 15 July 1980 on the Approximation of the Laws of the Member States Relating
to the Exploitation and Marketing of Natural Mineral Waters, Article 5 § 1 (80/777/EEC: OJ No. L 229, 30.8. 1980 p. 1), as
amended (available in consolidated text form at www.europa.eu.int);EU, Council Directive 98/83/EC of 3 November 1998
On The Quality of Water Intended for Human Consumption [available at same web site].
22. Ibid. Directive 80/777/EEC Article 5 § 2.
23. Ibid. Article 7 § 2.
26. EU, Council Directive 98/83/EC, Supra; The WHO provisional guideline for arsenic in drinking water for human
consumption is 10 ppb. World Health Organization, Guidelines for Drinking Water Quality (2nd Edition, Geneva, 1993).
The FDA standard for arsenic (and the EPA tap water standard, required to be updated in 2001), based on an outdated
1942 U.S. Public Health Service guideline, is 50 ppb.
27. Constance Hayes, "Now, Liquid Gold Comes in Bottles," New York Times, p. D4 (January 20, 1998).
28. IBWA, "What is IBWA?" available at www.bottledwater.org/about.html (printed11/20/1998).
29. IBWA Model Code § 1(d)., available at www.bottledwater.org/regs/indreg.html (printed 11/30/1998).
30. This troubling case arose in Massachusetts. Massachusetts state files reveal that the described well in Millis,
Massachusetts for years supplied several bottlers, including Cumberland Farms, West Lynn Creamery, Garelick Farms,
and Spring Hill Dairy for sale as "spring water" under many brand names. Massachusetts Department of Public Health,
Ann & Hope Water Incident Files, 1993-1997; MDPH Memoranda Provided to NRDC Pursuant to Freedom of Information
Request; Personal Communication with Dr. Liz Bourque, MDPH, August 1997.
31. According to State of Washington files, bottled water called "Alaska Premium Glacier Drinking Water: Pure Glacier
Water From the Last Unpolluted Frontier, Bacteria Free" actually was derived from"Public Water System #111241,"
apparently a public water system in (Juneau, Alaska), according to the files. The bottler apparently was told that when it
reordered its labels, it had to state that the water is "from a municipal source" or "from a community water system" in
accordance with FDA rules; the phrase "Pure Glacier Water" was, according to State files, "considered false and
misleading." Also, the bottler was required to drop the "bacteria free" claim, as this was "considered synonymous with
sterile and false." Washington State Department of Agriculture Food Establishment Inspection Report 4/17/97 and
attachments; WSDA Food Establishment Inspection Report 10/4/96 and attachments; WSDA Food Processor Licensing
Worksheet and Attachments, and WSDA Food Establishment Inspection Report and Attachments, 3/20/96. State officials
report that the required label changes have been made after the intervention of FDA and state regulators. Personal
communication with Shelly Haywood, USDA (January 1999)
32. L. Allen & J.L. Darby, "Quality Control of Bottled and Vended Water in California: A Review and Comparison of Tap
Water," Journal of Environmental Health, Vol. 56, No. 8, p. 19 (April 1994), citing FDA; accord, "Bottled Water
Regulation," Hearing Before the Subcommittee on Oversight and Investigation of the House Committee on Energy and
Commerce, 102nd Cong., 1st Sess., p. 3, Serial No. 102-36 (April 10, 1991); accord, Ibid. at 152 (Statement of William F.
Deal, CEO, International Bottled Water Association). In a recent interview with the head of the FDA bottled water
program, FDA confirmed that they have no reason to believe that this percentage has changed substantially since 1991.
Interview with Terry Troxel, FDA, September 18, 1997.
33. Memorandum, Dr. Karen Golden, FDA:CFSAN:OC:RCS, Regarding Discussion with Tyrone Wilson, International
Bottled Water Association, Regarding Bottled Drinking Water (dated February 10, 1992)[FDA Docket 93N-0200, Reference
2].
Chapter 2
EXPLODING SALES: MARKETING A PERCEPTION

OF PURITY
Over half of all Americans (54 percent) drink bottled water, and about 36 percent of us
imbibe regularly (more than once a week). [34] Sales have nearly tripled in the last decade,
to about $4 billion in 1997, rising from 4.5 gallons per year for the average American in
1986 to 12.7 gallons per year per person in 1997. [35] Americans consumed a total of 3.43
billion gallons of bottled water in 1997 (see Figure 1). [36] Globally, the market was
estimated in 1995 to be worth more than $14 billion annually in wholesale sales, and it has
certainly grown since then. [37] According to a 1992 inventory, there were already 700
brands of bottled water produced by about 430 bottling facilities in the United States, [38] a
number that likely has grown since that time, because of the enormous expansion in
bottled water sales.
Enormous Growth in Sales of Bottled Water

The industry has more than recovered from adverse public attention to problems with
bottled water quality in 1990 and 1991. At that time benzene contamination was found in
Perrier mineral water, causing a worldwide recall of this bottled water in February 1990.
Congressional hearings convened in 1991 by Michigan congressman John Dingell
focused intense public scrutiny on bottled water quality issues in the wake of the Perrier
incident, giving the industry a fleeting black eye. [39]
Since expunging these blotches on its image of purity, the industry has exploded, with the
market now growing at a strong rate of 8 to 10 percent per year -- about twice as fast as
the rate for other beverages. [40] According to industry stock analysts, "the profit margins
in the business are really pretty good" -- for some bottlers in the neighborhood of 25 to 30
percent. [41] That means every $1.50 bottle of water brings around $0.50 in profit. The actual
cost of the water in the bottle purchased off a store shelf is generally just a fraction of a
cent to a few cents. [42] Thus, typically 90 percent or more of the cost paid by bottled water
consumers goes to things other than the water itself -- bottling, packaging, shipping,
marketing, retailing, other expenses, and profit. As the then-chairman of the board of the
Perrier Corporation stated in a remarkable moment of candor, "It struck me . . .that all you
had to do is take the water out of the ground and then sell it for more than the price of
wine, milk, or, for that matter, oil." [43]
The bottled water industry's rapid growth is surprising in light of the retail price of bottled
water: It costs from 240 to over 10,000 times more per gallon to purchase bottled water
than it does to purchase a gallon of average tap water. For example, in California average
tap water costs about $1.60 per thousand gallons (about one tenth of a cent per gallon),
while it has been reported that average bottled water costs about $0.90 per gallon -- a 560-
fold difference. [44] Expensive imported water sold in smaller bottles can cost several
thousand times more than tap water: That $1.50 half-liter bottle of imported water may be
costing you 10,000 times more per gallon than your tap water.
While Americans with annual incomes of $60,000 per year or more are about 35 percent
more likely than those of lesser means to buy bottled water, the purchasers of bottled
water are hardly limited to high income yuppies. [45] As was put starkly in American
Demographics recently,
Black, Asian, and Hispanic households are more likely than whites to use bottled water,
even though blacks and Hispanics as a group have lower-than-average household
incomes . . . .Scares like the municipal water contamination that occurred in Milwaukee in
1993 may have even low-income families springing for bottled water. It's clear that many
households are still opting for bottled water, even though it can be an expensive habit. A
five-year supply of bottled water at the recommended intake of eight glasses a day can
cost more than $1,000. An equivalent amount of tap water costs about $1.65. [46]
Heavy Marketing of the "Purity" of Bottled Water

versus Tap Water
What has driven this ever-greater consumer demand for bottled water? Market experts and
public-opinion polls attribute the surprising increase primarily to several factors. People
choose bottled water because it is perceived to be safer and of higher quality than tap
water, and many are now using it because they view it as a healthful alternative beverage
to soft drinks or alcohol.
The public is concerned about tap water safety and quality, and, with much
encouragement from the bottled water industry's aggressive marketing, views bottled
water as a purer, safer option. As a key industry consultant put it, "water bottlers are
selling a market perception that water is 'pure and good for you' . . . ." [47]
Just to be sure this public perception is carefully nurtured, the bottled water industry has
engaged in an expensive public relations campaign to persuade the public about the
purity of bottled water and to disabuse the public of any "misconceptions about the cost,
safety, quality and regulations governing bottled water." [48] The PR campaign has included
media releases, briefings in at least 10 cities, distribution of press kits, videos and video
news releases. The campaign spent significant resources enlisting health groups as
spokespeople, "educating" consumers and groups representing populations likely to be at
elevated risk from tap water, and seeking to reach others about the safety of bottled water.
[49]
Recent figures for the total bottled water industry's advertising budget are difficult to
come by, but as long ago as 1990 -- when the industry was selling much less water than it
is today -- total media outlays for the bottled water industry were $42.9 million dollars. [50]
That spending likely has increased substantially in the past nine years.
The industry-encouraged consumer thirst for bottled water as a safer, higher-quality

source of drinking water was recently explained in a bottled water industry association
trade magazine:
Consumers Want to Drink Water That's Safe. News reports about crises involving
municipal water supplies in many parts of the country heightened public awareness and
concern about the safety of tap water. Environmental groups and the Environmental
Protection Agency sounded the safety alarm in several cities last year. As a result,
consumers began to choose bottled water as a safe alternative for drinking water. [51]
Many companies directly and openly market to consumers by highlighting tap water
contamination problems and offering their product as a safer alternative. An ad campaign
of the nation's second-largest water-bottling company, McKesson Water Products
Company (bottlers of Sparkletts, Alhambra, Aqua Vend, and Crystal), for example, was
cited in the advertising trade press as "right on" and highly effective because it took
advantage of "consumers' concern over the purity of tap water . . . ." [52] McKesson was
commended for running ads that "listed some of the contaminants in tap water,
juxtaposing Sparkletts as 'the source of pure water.'" [53] Other bottlers have used EPA data
indicating widespread tap water contamination with lead, [54] and much has been made by
the industry of the vulnerability of tap water to Cryptosporidium and the purported
complete protection of bottled water from this parasite. [55]
One soft-drink-industry executive who has increasingly turned to bottled water to boost
revenue and "sells lots of Evian" explained to The New York Times recently how the
bottled water market is helped by pollution concerns: "Water quality in the United States is
getting progressively worse. Every time there's a water main break on 23rd Street and
people have to boil water for a week, or there's problems with the Ohio River, it clears out
the supermarket shelves." [56]
In discussing the public's concern about tap water and how this opens up opportunities
for bottlers, a recent article in the magazine of the International Bottled Water Association
(IBWA), the industry's trade association, explained:
Consumers are being bombarded with headlines warning about the potential risks of tap
water, particularly water that may be contaminated with the parasite Cryptosporidium . . . .
[N]ational media attention has been focused on the issue for several reasons. First, the
Natural Resources Defense Council -- one of the country's most respected environmental
groups -- warned consumers about the dangers of Cryptosporidium in municipal water
supplies. Next, the Centers for Disease Control and Prevention (CDC) released guidelines
for immuno-compromised people who are concerned about the safety of their drinking
water. Finally, the media has been extensively covering congressional activity on water
safety.
Naturally all of this has resulted in increased consumer awareness and concern about the
safety of water . . . . The good news is that bottled water is a safe alternative. IBWA
member companies produce safe, high-quality, strictly regulated products. The challenge
for the industry is one of communication: how can we get the facts about bottled water to
consumers? [57]
In response, the industry has made a major effort to train its staff to "explain" why bottled
water is safer than tap water and to place media stories focusing on the high quality of
bottled water. These representatives portray their products as entirely free of any
contamination and free of risk from Cryptosporidium and any other contaminants. [58]
Bottled water industry advertising materials and "fact sheets" routinely state that bottled
water is pure or entirely free of contaminants. A widely circulated IBWA question-and-
answer fact sheet for consumers is one typical example:
How do I know that Cryptosporidium is not in my bottled water?
For starters, bottled water companies are required to use approved sources . . . .By law,
[springs and wells] must be protected from surface intrusion and other environmental
influences. This requirement ensures that surface water contaminants such as
Cryptosporidium and Giardia are not present . . . . All IBWA member companies that use
municipal supplies are encouraged to employ at least one of the three processing
methods recommended by [CDC] for effective removal of microbial (surface water)
contaminants, including Cryptosporidium.
Does bottled water contain any chlorine or harmful chemicals?

No.[59]
As discussed in Chapter 3 and the accompanying Technical Report (print report only),
these blanket reassurances of absolute purity of all bottled water are incorrect. At least
one sample of about a quarter of the bottled waters we tested violated strict state
(California) health standards or warning levels, and about one fifth of the waters exceeded
unenforceable state or industry bacteria guidelines. Moreover, it is incorrect to assert that
simply because water comes from a well or a spring it is immune from Cryptosporidium or
other microbial contaminants of potential concern. Several waterborne-disease outbreaks
-- including outbreaks of Cryptosporidium-induced illness -- have been caused by tap
water taken from contaminated wells or springs. [60] There is no reason to believe that
bottled water taken from springs, wells (or from tap water or other sources, for that matter)
is necessarily impervious to such contamination; only strong regulatory controls of water
sources and strict treatment mandates (controls well beyond the weak federal bottled
water rules) can ensure that no microbial contaminants are present.
While it appears that many consumers who turn to bottled water do so out of concern
about the safety of their tap water, some also have switched to bottled water because they
are turned off by tap water's taste and odor (such as the pungent chlorine smell and taste)
and simply prefer the taste and smell of bottled water. In addition, Americans are choosing
bottled water as what industry insiders call a "refreshment beverage," because it is
marketed and viewed as a light, clear, caffeine-, salt-, and sweetener-free, and healthful
alternative to soft drinks like Coke and Pepsi. [61]
In fact, a 1993 poll of people who drink bottled water[62] found that 35 percent of bottled
water drinkers used it primarily out of concern about tap water quality. Another 12 percent
chose bottled water because of both safety or health concerns and the desire for a
substitute for other beverages (see Figure 2). Thus, as of 1993 at least, nearly half (47
percent) of bottled water drinkers used it at least partially out of concern for their health
and safety. Another 35 percent drank it as a substitute for soft drinks and other beverages.
Seventeen percent said they chose bottled water for other reasons -- such as "taste" (7
percent) or "convenience."
It is absolutely clear, therefore, that a leading reason for the explosion in bottled water
sales is the public perception, fueled by heavy industry advertising, that bottled water is
pure and pristine, and thus a healthier choice than tap water.
Selling bottled tap water
What exactly are consumers getting for their money? Is the bottled water industry's
carefully marketed image of absolute purity and pristine sources an accurate reflection of
where bottled water comes from, and is the water really so immaculately pure compared
with tap water?
Government and industry estimates indicate that about 25 percent to 30 percent of the
bottled water sold in the United States comes from a city's or town's tap water --
sometimes further treated, sometimes not. [63] One IBWA expert reportedly estimated in
1992 that 40 percent of the bottled water was derived from tap water. [64] The percentage of
bottled water derived from tap water may be rising, because some major bottlers have
begun to sell new brands of water derived from city tap water.
One extremely popular newly launched brand of bottled water is Pepsico's Aquafina®
brand (which reportedly has taken Pepsi into the top 10 sellers of bottled water in the
United States, with sales jumping 126 percent in one year to more than $52 million in 1997,
according to the trade press). [65] Aquafina® bottles, which picture beautiful stylized
mountains on the label, do not mention that the water is derived from municipal tap water.
The water reportedly is treated tap water taken from 11 different city and town water
supplies across the nation. [66] Pepsi executives defend the practice. In a 1997 report,
"Pepsi spokesman Larry Jabbonsky made no apologies for the Aquafina label or
advertising and said Pepsi isn't hiding anything. He said anyone can find out the true
source of Aquafina by calling the 800 number on the bottle top." [67] Coca-Cola, according
to some accounts, is also very interested in the high profit potential of entering the U.S.
bottled water market and has carefully tracked Pepsi's success with Aquafina. [68]
Other bottlers also use tap water as their source. For example, it has been reported that in
south Texas, a brand of bottled water called Everest, with mountains on the label, lists the
source as the municipal water supply of Corpus Christi, which, as one report noted, "is
hard by the Gulf of Mexico and nowhere near Everest or any other mountain." [69]
NRDC's testing found that some brands of bottled water that claim to be spring water or
that do not indicate that they are from a municipal source have likely been chlorinated -- a
sign that they are likely derived from a municipal source, even though one of bottlers' key
selling points is the lack of chlorine taste and odor in their product. For example, tests of
two different samples of Safeway Spring Water, sold in California, chemically resembled
tap water, in that it contained substantial levels of trihalomethanes -- common by-products
of chlorine disinfection.[2a]
In addition, some cities recently have announced that they plan to enter the bottled water
market by selling their water untreated in bottles. [70] Houston, for instance, has announced
that it will sell its self-proclaimed "Superior Water" -- city water taken straight from the tap
and pumped into bottles. [71] Other cities including Kansas City and North Miami Beach are
said to be evaluating plans to sell their water in bottles. [72]
Recent FDA rules now in force do require that if water is taken from a municipal source
and not treated further, the bottle label must indicate that it is "from a municipal source"
or "from a community water system." [73] However, if the water is treated using any of
several common technologies (some of which could fail to filter out certain contaminants,
depending upon the treatment used), there is no requirement to label its municipal source.
[74]
Apparently Pepsi is permitted to not mention on the Aquafina® label that its water
derives from municipal tap water, because it considers its water "purified water" under
this exception.[2b]
Chapter Notes
2a. It is possible, albeit unlikely, that true spring water could have been chlorinated prior to bottling.
2b. No quantitative data are publicly available regarding whether this practice is in widespread use beyond the
Aquafina® label. Moreover, due to the lack of state and FDA resources dedicated to monitoring the bottled water
industry, the prevalence of the now unlawful practice of bottling untreated tap water from a public water system without
labeling its municipal water source is unknown.
Report Notes
34. "Uncapping Consumers’ Thirst for Bottled Water," Bottled Water Reporter, p. 63 (December/January, 1994); Martha
Hamilton, Washington Post, "Liquid Assets, Pure and Simple," September 14, 1996 p. D1.
35. Beverage Marketing Association, 1998 data cited in "Advertising & Marketing:Waterlogged," Los Angeles Times, p.
D5 (April 23, 1998); Tim Madigan, Fort Worth Star-Telegram, August 24, 1997, p. 1.
36. Beverage Marketing Association, 1998 data cited in "Advertising & Marketing:Waterlogged," Los Angeles Times, p.
D5 (April 23, 1998).
37. Timothy & Maureen Green, "Bottled Water Goes Global," Bottled Water Reporter, p. 48, (June/July 1995).
38. Business Trend Analysis, Inc., The Bottled Water Market: Past Performance, Current Trends, and Strategies for the
Future: A Business Information Report , p. 1 (1992).
39. See, "Bottled Water Regulation," Hearing of the Subcommittee on Oversight and Investigations of the House
Committee on Energy and Commerce, Serial No. 102-36, 102nd Cong., 1st Sess. (April 10, 1991).
40. In 1997, there was a 9.6 percent increase in bottled water sales over 1996, for example, according to Beverage
Marketing Association 1998 data cited in "Advertising & Marketing:Waterlogged," Los Angeles Times, p. D5 (April 23,
1998); see also, Harry Berkowitz, "Wading in Water: As Sales Soar, Bottlers Try to Distinguish Their Products," Newsday,
p. 1 (August 31, 1997).
41. Ibid., quoting Casey Alexander, securities analyst at Gilford Securities.
42. According to an industry consulting company: "If the bottler installs the equipment the price per gallon may be as
low as 0.0125 cents per gallon. If the property installs the equipment the price range, depending on volume and market
proximity, is 0.02 to 0.06 cents per gallon. The proximity of the source to the bottling facility has a significant fiscal
impact on the raw product costs. According to Mike Cullis formerly of Hidell-Eyster Technical Services, Inc., ‘Total
operating costs of a dedicated tanker is $1.10 per mile. Therefore the difference between a source 100 miles and a
source 200 miles from the bottling plant translates to $220 per load or a laid in cost of 0.04 cents per gallon’." "The
higher the volume, the lower the cost per gallon. Filling a 5,000 gallon tanker truck per week from a supplier with his own
pumping equipment can cost 0.05 cents per gallon. If the volume increases the cost drops considerably. According to
Roy Christensen of Black Mountain Spring Water some of the biggest cost of raw water is negotiating the contract.
Besides owning their own sources, Black Mountain has leases and agreements with spring water property owners.
‘Entrepreneurs have developed spring sources in our area and there are now more sources available than ever before,’
said Christensen. The price per gallon in Northern California has remained consistent over the past few years because,
unlike fossil fuels, spring sources are not a diminishing resource, even with increasing demand. "Road access is a
primary problem along with water quality. Lower total dissolved solids (tds) is most desirable for spring bottlers but the
threshold of acceptability varies from State to State. A source in the Western U.S. may have upwards of 150 parts per
million (ppm) tds [total dissolved solids] and be acceptable, while in the Northeast bottlers prefer 100 or less tds. "The
Perrier Group developed a pumping station at a Boys Scout Camp south of Waco, Texas for their Oasis and Ozarka
brands. The cost of the pumping station was approximately $300,000 which Perrier supplied. Today Perrier pays an
annual fee of $25,000 to draw the water from the source and average 10,000 gallons per day. "Bill Egan, owner of
Mountainwood Springs in Blairstown, New Jersey, bought property with a large 5-6 million gallon per day spring, twelve
years ago. He built a stainless steel pumping facility and developed a bulk water business selling water to bottlers like
Great Bear, Cumberland Farms and General Foods. "It is very competitive,’ said Egan. ‘A lot of people think that if you
get a spring you'll be an instant millionaire. They don't do their homework. There are not a lot of big users for bulk
water," Egan said. He tests his water every hour and it is certified by the National Sanitation Foundation. In the summer
season Egan says he fills over ten 6200 gallon tanker trucks per day, each one taking about 45 minutes to load. "The raw
spring water supplier is often tempted to enter the business himself and build a bottling facility. Ultimately this may
undermine the relationship with other bottlers who he supplies to, as they compete for supermarket shelf space and
route sales. Being a bulk water supplier is not as capital intensive as becoming a bottler and still has a lot of appeal. As
Bill Egan said, ‘The business is glamorous. Water is a topic of conversation." "What is water worth? Today water is sold
from spring owners to bottlers from a few pennies to almost 10 cents a gallon." THE BOTTLED WATER WEB, © 1997
Best Cellar Communications, www.bottledwaterweb.com/indus.html.
43. Gustave Leven, Chairman of the Board, The Perrier Corporation of France, quoted in P. Betts, "Bubbling Over in a
Healthy Market," The Financial Times, January 13, 1988.
44. L. Allen and J.L. Darby, "Quality Control of Bottled and Vended Water in California: A Review and Comparison to Tap
Water," Journal of Environmental Health, vol. 56, no. 8, pp. 17-22 (April 1994).
45. Marcia Mogelonsky, "Water Off the Shelf," American Demographics, p. 26 (April 1997)
46. Ibid.
47. Henry R. Hidell III, "Water: The Search for a Global Balance," Bottled Water Reporter, p. 53 (June/July
1995),(emphasis added).
48. See, e.g., "Bottled Water Campaign Focuses on Quality Issues," Bottled Water Reporter, p. 52 (April/May 1995); "A
Flood of Good News for Bottled Water: The Beverage For Life Campaign: A (Media) Year in Review, Bottled Water
Reporter, p. 73 (October/November 1994)
49. "Bottled Water: The ‘Beverage for Life’ Campaign," Bottled Water Reporter, p. 86 (February/March 1995); Sylvia
Swanson, "IBWA In the Forefront," Bottled Water Reporter, p. 30 (December/January 1996).
50. Business Trend Analysis, Inc., The Bottled Water Market: Past Performance, Current Trends, and Strategies for the
Future: A Business Information Report , p. 84 (1992).
51. "Uncapping Consumers’ Thirst for Bottled Water," Bottled Water Reporter, p. 63 (December/January, 1994).
52. Marcy Magiera, "Bottled Water: Sales Jump as Public Trust [of Tap Water] Drops," Advertising Age (February 7,
1994), excerpted in Greenwire, American Political Network, February 9, 1994.
53. Ibid.
54. As one typical example, advertising materials for Nicolet "Natural Artesian Water" cite as one rationale for
purchasing Nicolet water the fact that "US EPA recently stated that as many as 42 million Americans may be consuming
tapwater tainted with unacceptable lead concentrations from lead soldered joints in water mains and plumbing systems."
(www.nicoletwater.com/source/source.html [8/12/1997]).
55. International Bottled Water Association, "Frequently Asked Questions About Bottled Water," (available at
www.bottledwater.org/faq.html), (printed 11/20/1998).
56. Bruce Llewellyn, Chairman and CEO of Philadelphia Coca Cola Bottling Company, quoted by Constance Hayes,
"Now, Liquid Gold Comes in Bottles," New York Times, p. D4 (January 20, 1998).
57. Jennifer Levine, "Why Crytosporidium? Why Now? Information on Responding to Consumers’ Questions" Bottled
Water Reporter, pp. 16-17 (August/September 1995).
58. See, ibid; International Bottled Water Association, "Frequently Asked Questions About Bottled Water," (available at
www.bottledwater.org/faq.html), (printed 11/20/1998)
www.bottledwater.org/faq.html), (printed 11/20/1998), (emphasis added).
60. See, M.H. Kramer, et al. , "Surveillance for Waterborne-Disease Outbreaks--United States, 1993-1994," In: Centers for
Disease Control & Prevention Surveillance Summaries, Morbidity and Mortality Weekly Report, vol. 45, no. SS-1, pp. 1-31
(April 12, 1996); B.L. Herwart, et al., "Outbreaks of Waterborne Disease in the U.S.: 1989-90," Journal of the American
Water Works Association, p. 129 (April 1992); W.C. Levine, W.T. Stephenson, and G. Craun, "Waterborne Disease
Outbreaks, 1986-1988," Mortality and Morbidity Weekly Report vol. 39, no. SS-1 (March 1990; NRDC, The Dirty Little
Secret About Our Drinking Water (1995).
61. "Uncapping Consumers’ Thirst for Bottled Water," Bottled Water Reporter, p. 63 (December/January, 1994).
62. American Water Works Association Research Foundation, "Consumer Attitude Survey," pp. 19-20 (1993).
63. L. Allen & J.L. Darby, "Quality Control of Bottled and Vended Water in California: A Review and Comparison of Tap
Water," Journal of Environmental Health, vol. 56, no. 8, p. 19 (April 1994), citing FDA; accord, "Bottled Water Regulation,"
Hearing Before the Subcommittee on Oversight and Investigation of the House Committee on Energy and Commerce,
Serial No. 102-36 102nd Cong., 1st Sess., p. 3, (April 10, 1991); accord, Ibid. p. 152 (Statement of William F. Deal, CEO,
International Bottled Water Association). In a recent interview with the head of the FDA bottled water program, FDA
confirmed that they have no reason to believe that this percentage has changed substantially since 1991. Interview with
Terry Troxel, FDA, September 18, 1997.
64. Memorandum, Dr. Karen Golden, FDA:CFSAN:OC:RCS, Regarding Discussion with Tyrone Wilson, International
Bottled Water Association, Regarding Bottled Drinking Water (dated February 10, 1992)[FDA Docket 93N-0200, Reference
2].
65. G.W. Prince, "What it Tables," Beverage World, p. 46 (April 15, 1998).
66. See, K. Benezra, "Pepsi to Herald Aquafina as Populist Alternative to Pricey Waters," Brandweek (June 2, 1997); B.
Mohl and P. Wen, "Mountain on Water's Label is Just a Mirage," The Boston Globe, p. B2; (October 19, 1997); H.
Berkowitz, "Wading in Water: As Sales Soar, Bottlers Try to Distinguish Their Products," Newsday (August 31, 1997);
Mark Tran, "Demi Moore Creates a Fizz; Pepsi Dives Into Growth Market in Effort to Swamp French Brands," The
Guardian (London) , p. 20 (June 27, 1997); "1996 Alternative Beverages: Still Water Supply Up Sharply, Perrier, Coke,
Pepsi, and Suntory Gain Share," Beverage Digest (April 25, 1997), (www.beverage-digest.com/970425.html), (printed
9/25/1997).
67. B. Mohl and P. Wen, "Mountain on Water's Label is Just a Mirage," The Boston Globe, p. B2; (October 19, 1997).
68. Coke already sells its brand "Bon Aqua®"® in 30 countries overseas, but not in the United States. Constance Hayes,
"Now, Liquid Gold Comes in Bottles," New York Times, p. D4 (January 20, 1998).
69. S.H. Verhovek, " It's Wet. It's Bottled. It Sort of Tastes Like Water.," The New York Times, p. D2 (August 10, 1997).
70. Ibid.
71. Julie Mason, "A Big Splash? Bottled City Water Soon May be Available in Stores," The Houston Chronicle p. 1 (July
10, 1997); D. Usborne, "Oil Town Finds an New Source of Wealth on Tap," The Independent p. 10 (August 7, 1997); "No
Frills Water," The Christian Science Monitor p. 20 (September 3, 1997), (editorial).
72. Ibid; S.H. Verhovek, " It's Wet. It's Bottled. It Sort of Tastes Like Water.," The New York Times, p.D2 (August 10, 1997).
73. 21 C.F.R. section 165.110(a)(3)(ii).
74. Ibid.
Chapter 3
BOTTLED WATER CONTAMINATION: AN

OVERVIEW OF NRDC'S AND OTHERS' SURVEYS
Setting aside the question of whether bottled water is as pure as advertised, is the public’s
view that bottled water is safer than tap water correct? Certainly the aggressive marketing
by the bottled water industry would lead us to believe so.
NRDC undertook a four-year, detailed investigation to evaluate the quality of bottled water.
We reviewed published and unpublished literature and data sources, wrote to and
interviewed by phone all 50 states asking for any surveys of bottled water quality they
have conducted or were aware of, and interviewed experts from FDA. In addition, through
three leading independent laboratories, we conducted "snapshot" testing of more than
1,000 bottles of water sold under 103 brand names.
What NRDC has found is in some cases reassuring and in others genuinely troubling. The
results of all testing NRDC conducted is presented in Appendix A; Figure 4 summarizes
the results.
The bottled water industry generally has publicly maintained that there are no chemical
contaminants in bottled water. For example, as noted in Chapter 2, a widely disseminated
fact sheet on bottled water distributed by the International Bottled Water Association
(IBWA) -- the industry’s trade association -- states flatly that bottled water contains no
chlorine or harmful chemicals. [75]
However, our investigation has found that potentially harmful chemical contaminants are
indeed sometimes found in some brands of bottled water. (The box at the end of this
chapter highlights a particularly troubling example.) NRDC’s testing of more than 1,000
bottles of water (for about half of FDA-regulated contaminants; see the Technical Report
[print report only]), found that at least one sample of 26 of the 103 bottled water brands
tested (25 percent) contained chemical contaminants at levels above the strict, health-
protective limits of California, the bottled water industry code, or other states[3a] (23 waters,
or 22 percent, had at least one sample that violated enforceable state limits). We found
only two waters that violated the weaker federal bottled water standards for chemicals (in
two repeat samples), and two waters that violated the federal standards for coliform
bacteria in one test (though another batch of both of those waters tested clean for
bacteria). The Technical Report (print report only) also discusses evidence provided by
other investigators who in the past found that chemical contaminants were found in
bottled water at levels violating the federal bottled water standards. [76]
Thus, in our limited bottled water testing, while strict health-protective state limits for
chemicals sometimes were not met by about one fourth of the waters, the weaker federal
bottled water standards generally were not violated. As noted in Table 2, among the
chemical contaminants of greatest potential concern in bottled water are volatile organic
chemicals, arsenic, certain other inorganic chemicals, and plastic or plasticizing
compounds. Although most bottled water contained no detectable levels of these
contaminants, or contained levels of the contaminants lower than those found in many
major cities’ tap water, we determined that one cannot assume on faith, simply because
one is buying water in a bottle, that the water is of any higher chemical quality than tap
water.
TABLE 2
Selected Contaminants of Potential Concern for Bottled Water
Contaminant Health Concern with Excess Levels
Coliform Bacteria Broad class of bacteria used as potential indicator of fecal

contamination; may be harmless of themselves. Harmful types of
coliform bacteria (such as certain fecal coliform bacteria or E. coli)
can cause infections with vomiting, diarrhea, or serious illness in
children, the elderly, and immunocompromised or other vulnerable
people.
Heterotrophic Plate Count (HPC) Potential indicator of overall sanitation in bottling and source water;
Bacteria may be harmless of themselves. In some cases may indicate presence
of infectious bacteria; data show sometimes linked to illnesses. Can
interfere with detection of coliform bacteria or infectious bacteria.
Unregulated by FDA.
Pseudomonas aeruginosa bacteria Possible indicator of fecal contamination or unsanitary source water
or bottling. Can cause opportunistic infections. Unregulated by FDA.
Arsenic Known human carcinogen. Also can cause skin, nervous, and
reproductive or developmental problems.
Nitrate Causes "blue baby" syndrome in infants, due to interference with

blood's ability to take up oxygen. Potential cancer risk.
Trihalomethanes (i.e., chloroform, Cancer of the bladder, colorectal cancer, possibly pancreatic cancer.
bromodichloromethane, Also concerns about possible birth defects and spontaneous
dibromochloromethane, and abortions.
bromoform)
Phthalate (DEHP) Cancer; possible endocrine system disrupter. Unregulated by FDA.

Source: NRDC
NRDC Testing Methodology

NRDC began during the summer of 1997 to test bottled water quality and continued testing
or retesting some brands through early 1999. Our testing methodology is summarized in
Table 3, and described in greater detail in the accompanying Technical Report (print report
only). We conducted a four-pronged testing program, using three of the nation's most
respected laboratories: two major independent commercial labs and one academic
laboratory. In this four-pronged testing program, we tested water sold in the five states
with the highest bottled water consumption in 1994 (California, Florida, Illinois, New York,
and Texas), plus bottled water sold in the District of Columbia. [77] We tried to test major
brands that held a significant percentage of the national or regional market share (for
those brands for which market-share information was available), and we strove to
purchase a variety of other brands and types of water, including the major bottled water
products offered by some of the leading supermarket chains in the areas where the water
was purchased.
The first prong of our survey was a preliminary screening of 37 California bottled waters in
the summer and fall of 1997. The second involved detailed testing of 73 California waters
in late 1997 and early 1998. The third was a survey of five bottled waters from each of five
states other than California (a total of 25 waters) in late 1997 and early 1998. The final
prong involved retesting more than 20 in which contamination had been found in earlier
tests, which took place in mid- to late-1998 and early 1999.
We sampled the most waters from California, whose residents are by far the greatest
consumers of bottled water in the nation. More bottled water is purchased in California
than in the next five largest consuming states combined (see Figure 3). California
generally has the most stringent standards and warning levels applicable to bottled water
in the nation.
All of the labs we contracted with used standard EPA analytical methods for testing water.
We conducted "snapshot" testing -- that is, we purchased several bottles of a single type
of water, at a single location, and had those bottles tested. If we found a problem, we
generally repurchased and then retested the water to confirm the earlier results. [78] Our
testing methodology is summarized in Table 3, and described in greater detail in the
accompanying Technical Report (print report only).
We asked the labs to use their standard contaminant test packages in order to control the
total testing costs. In general, this meant that the labs tested for many of the most
commonly found regulated contaminants, plus certain other contaminants that they could
readily detect and quantify using the standard EPA methods and the analytical equipment
they routinely use. Thus, some labs were able to detect more contaminants than others,
though all tested for a core set of more than 30 regulated contaminants.
TABLE 3:
Summary of Lab Testing Protocols
Lab # of Number of General Testing Protocol Comments
Brands Contaminants
of Water Tested
Tested
Environmental 37 41 regulated, EPA analytical methods, single Initial screening

Quality Institute over 40 bottle sampled per contaminant of California
(Univ. N.C.) unregulated type waters to
determine whether
more in-depth
testing needed.
Sequoia 73 32 regulated, EPA analytical methods, FDA More extensive

Analytical over 40 protocol for sampling (test 1 testing of
unregulated composite sample of 10 bottles California waters
for chemical and microbial only.
contaminants; 10 individual
bottles tested for microbial
follow-up if excess bacteria
found in first round)
National testing 25 57 regulated, EPA analytical methods, FDA Testing of waters

over 200 protocol for sampling (test 1 from 5 states
unregulated composite sample of 10 bottles; outside of
10 individual bottles of all tested California (NY,
for bacteria) FL, TX, IL, and
DC).
Summary of Results of NRDC Testing

NRDC testing: the good news
First, the good news: Most brands of bottled water we tested were, according to our
"snapshot" analyses of a subset of regulated contaminants, of relatively good quality (i.e.,
they were comparable to good tap water). Most waters contained no detectable bacteria,
and the levels of synthetic organic chemicals and inorganic chemicals of concern for
which we tested were either below detection limits or well below all applicable standards.
Caveats. This is not to say that all of these brands are without risk. One of the key
limitations of the testing is that most tests were done just once or twice, so we could have
missed a significant but intermittent problem. Numerous studies of source-water quality --
particularly surface-water sources and shallow groundwater sources -- demonstrate that
source-water quality may substantially vary over time. [79] Operation, maintenance, or other
mishaps at a bottling plant may cause periodic water-contamination problems that would
not be detected by such "snapshot" tests. Thus, depending upon the bottler's source
water, treatment technology (if any), and manufacturing, operation, and maintenance
practices, some bottled waters' quality may vary substantially with time and with different
production runs.
In addition, while we did test for dozens of contaminants at a cost of from about $400 to
about $1,000 per type of water per round of testing (depending on the intensity of the
testing), we were unable to test for many contaminants that may be of health concern.
Thus, as is discussed in the accompanying Technical Report (print report only), we were
unable to test for many kinds of bacteria, parasites, radioactivity, and toxic chemicals
regulated by EPA and FDA in tap water or bottled water because such testing would have
been even more expensive or difficult. Still, with those caveats, many bottled waters do
appear to be of good quality, based on our limited testing.
NRDC testing: the bad news
For some other bottled waters, the story is quite different. The independent labs that
conducted testing for NRDC found high levels of heterotrophic-plate-count bacteria in
some samples, and in a few cases coliform bacteria (no coliforms were found in retests of
different lots of the same water). The labs also found that some samples contained arsenic
(a carcinogen) and synthetic organic chemicals (SOCs, i.e., man-made chemicals
containing hydrogen and carbon), such as those contained in gasoline or used in industry.
SOCs found included the probable human carcinogen phthalate (likely from the plastic
water bottles), and trihalomethanes (cancer-causing by-products of water chlorination,
which have been associated with birth defects and spontaneous abortions when found in
tap water at high levels).[3b]
A detailed review of all our testing results and those of other investigators is presented in
the accompanying Technical Report (print report only), and the actual results for each
brand of bottled water we tested are presented in Appendix A. In summary, our testing of
103 types of water found:
• Violations of state standards. At least one sample of about one fourth of the
bottled waters bought in California (23 waters, or 22 percent) violated enforceable
state limits (either bottled water standards or mandatory warning levels).
• Violations of federal bottled water quality standards (coliform bacteria and

fluoride). Based on limited testing, four waters violated the weak federal bottled
water standards (two for coliform bacteria that on retest contained no coliforms,
and two for fluoride that were confirmed on retest to contain excessive fluoride).
Coliform bacteria in water may not be dangerous themselves, but they are widely
used as an indicator that may signal the presence of other bacteria or pathogens
that could cause illness. Fluoride at excessive levels can cause mottling or dental
fluorosis (pitting of teeth), skeletal fluorosis (adverse effects on bones), and
cardiovascular and certain other health effects. [80]
• Arsenic contamination. Arsenic is a "known human carcinogen" when in drinking

water; it also can cause many other illnesses, including skin lesions, nervous-
system problems, and adverse reproductive and cardiovascular effects (the
precise levels in drinking water necessary to cause these effects are the subject of
heated debate). [81] Our testing found that one or more samples of eight waters (8
percent) purchased in California exceeded the 5 ppb warning level for arsenic set
under California's Proposition 65, a law requiring public warnings if a company
exposes people to excessive levels of toxic chemicals.[3c] (See Figure 5.)
• Trihalomethane violations. Trihalomethanes (THMs) are a family of chemicals

created when chlorine is used to disinfect water (chlorine reacts with organic
matter in the water to form THMs and other byproducts). Studies of people and
animals exposed to THMs in their tap water have found elevated risks of cancer[82]
and potentially a higher risk of spontaneous abortions and birth defects. [83]
California has adopted a 10 ppb total THM limit, a standard recommended by the
International Bottled Water Association (IBWA), the bottled water industry trade
association. Twelve waters (12 percent) purchased in California had at least one
sample that violated the state and IBWA bottled water standard for THMs in the
same fashion. (See Figure 6.) Two waters sold in Florida exceeded the IBWA
standard (Florida repealed its 10 ppb TTHM standard in 1997), and one sold in
Texas violated the IBWA standard (Texas has not made the stricter 10 ppb
standard enforceable). Chlorinated tap water also typically contains THMs
(generally at levels above 10 ppb if the water is chlorinated), though many people
who buy bottled water to avoid chlorine and its taste, odor, and by-products may
be surprised to learn THMs are sometimes found in bottled water as well.
• Excessive chloroform Chloroform is the most common THM found in tap and
bottled water; it is of particular concern because it is listed by EPA as a probable
human carcinogen. Twelve waters purchased in California had at least one sample
that exceeded the warning level for chloroform (a trihalomethane) set by California
under Proposition 65, but they were sold without the required health warning (see
Appendix A).
• Excessive bromodichloromethane (BDCM). BDCM is another THM that EPA has

listed as a probable human carcinogen. Ten waters we bought in California that
contained unlawful TTHM levels also had at least one sample that exceeded the
Proposition 65 warning level for bromodichloromethane. These waters all were
sold with no health warning that they contained BDCM at a level above the
Proposition 65 level.
• Excessive heterotrophic-plate-count (HPC) bacteria. HPC bacteria are a measure of

the level of general bacterial contamination in water. HPC bacteria are not
necessarily harmful themselves, but they can indicate the presence of dangerous
bacteria or other pathogens and are used as a general indication of whether
sanitary practices were used by the bottler. Nearly one in five waters tested (18
waters, or 17 percent) had at least one sample that exceeded the unenforceable
microbiological-purity "guidelines" adopted by some states for HPC bacteria (500
colony-forming units, or cfu, per milliliter). (See Figure 7.) These states use
unenforceable HPC-bacteria "guidelines" to measure bacterial contamination and
sanitation. These state guidelines actually are weaker than voluntary HPC
guidelines used by the industry trade association to check plant sanitation. (200
cfu/ml in 90 percent of samples taken five days after bottling), and are weaker than
the European Union (EU) standard (100 cfu/ml, at bottling at 22 degrees Celsius).
• Elevated nitrates, but at levels below standards. Nitrates can be present in water as
a result of runoff from fertilized fields or lawns, or from sewage; nitrates also may
occur naturally, generally at lower levels. At elevated levels, nitrates can cause
blue-baby syndrome -- a condition in infants in which the blood has diminished
ability to take up oxygen, potentially causing brain damage or death; according to
some, nitrates may be linked to cancer in adults. [84] The EPA and FDA standard for
nitrates is 10 parts per million (ppm). There is spirited debate about whether these
standards are sufficient to protect all infants in light of some studies suggesting ill
effects at lower levels, [85] but both EPA and the National Research Council maintain
that the current standard is adequate to protect health. [86] We found six bottled
waters that had at least one sample containing more than 2 ppm nitrates; four of
these had at least one sample containing more than 3 ppm nitrates (two contained
up to 5.6 ppm nitrates in at least one test). (See Table 4.) Four of the six waters
containing higher nitrate levels were mineral waters. The U.S. Geological Survey
says that nitrate levels in excess of 3 ppm may indicate human-caused nitrate
contamination of the water, [87] although it may be that some mineral waters
naturally contain higher nitrate levels. To be safe, babies probably should not be
fed with mineral water containing elevated nitrate levels.
TABLE 4
Selected Nitrate Levels Found in Bottled Waters
Bottled Water Nitrate Level Nitrate Level
Brand (as Nitrogen, in ppm) (as Nitrogen, in ppm)
(First Test) (Subsequent Tests, If Any)
Fiuggi Natural Mineral Water 2.5
Hildon Carbonated Mineral Water 5.6 5.4
Hildon Still Mineral Water 5.6
Perrier Sparkling Mineral Water 2.8, 2.6 4.3, 4.1
Sahara Mountain Spring Water 2.5
Sparkling Springs 3.1
Source: NRDC, 1997-1999
• No fecal coliform bacteria or Pseudomonas aeruginosa. Although, as noted

previously, we did find total coliform bacteria in a few samples, no fecal coliform
bacteria or E. coli bacteria were found. Earlier studies have found multiple species
of the bacteria Pseudomonas in bottled water. [88] However, in an effort to control
costs, we looked only for the species Pseudomonas aeruginosa and found none.
• Synthetic organic chemicals at levels below enforceable standards. About 16

percent of the waters (16 of 103) had at least one sample that contained human-
made synthetic organic chemicals (SOCs) at levels below state and federal
standards. The most frequently found SOCs were industrial chemicals (e.g.,
toluene, xylene, and isopropyltoluene), and chemicals used in manufacturing
plastic (e.g., phthalate, adipate, and styrene). As discussed in the accompanying
Technical Report (print report only), some of the chemicals found (such as
phthalate) may pose health risks such as potential cancer-causing effects, even if
present at relatively low levels. Generally, long-term consumption (over many
years) is required to pose such chronic risks. The levels of these contaminants
found in our testing are indicated in Table 5.
• Overall contamination findings Overall, at least one sample of about one third of
the tested waters (34 waters, or 33 percent) contained significant contamination
(i.e., contaminants were found at levels in excess of standards or guidelines). This
is not simply the sum of the waters that violate enforceable standards plus those
that exceeded guidelines, as some waters violated both.
• The detailed results of our testing for each type of water are presented in the
Technical Report (print report only). As is discussed there, testing by states and by
academic researchers have also sometimes found the contaminants we studied or
other potentially toxic and infectious agents in some brands of bottled water.
TABLE 5
Selected Synthetic Organic Compounds (Other Than THMs) in Bottled Water
Bottled Water Xylene Toluene Other VOCs Comments
(& State of Level Level Found
Purchase) (ppb) (ppb) (in ppb)
Alhambra Crystal 2.7 (test 1) 12.5 (test Not Detected (tests Xylene and toluene below FDA
Fresh Drinking 0 (test 2) 1) 1 & 2) & CA standards, but presence
Water (CA) Not could indicate treatment standard
Detected violation.
(test 2)
Black Mountain Not 8.9 (test Not Detected (tests Toluene below FDA and CA
Spring Water (CA) Detected 1) 1 & 2) standards, but presence could
(tests 1-3) Not indicate treatment standard
Detected violation.
(tests 2 &
3)
Lady Lee Drinking 2.9 (test 1) 11.0 (test Not Detected (tests Xylene and toluene below FDA
Water (Lucky, CA) Not 1) 1 & 2) & CA standards, but presence
Detected 0.5 (test could indicate treatment standard
(test 2) 2) violation.
Lady Lee Natural 3.0 (test 1) 13.9 (test Not Detected (tests Xylene and toluene below FDA
Spring Water Not 1) 1 & 2) & CA standards, but could
(Lucky, CA) Detected Not indicate CA treatment standard
(test 2) Detected violation.
0 (test 3) (test 2)
0.5 (test
3)
Lady Lee Purified 9.4 (test 1) 9.5 (test Ethylbenzene 2.0 Xylene, toluene, methylene
Water (Lucky, CA) Not 1) ppb (test 1) chloride, and ethylbenzene below
Detected Not Ethylbenzene not FDA & CA standards, but could
(test 2) Detected detected (test 2) indicate CA treatment standard
(test 2) Ethylbenzene not violation. Methylene chloride
detected (test 3) standard is 5 ppb.
Methylene
Chloride 4.1 ppb
(test 3)
Lucky Sparkling Not Not p-isopropyltoluene Single test; no standard for

Water Detected Detected 5.4 ppb p-isopropyltoluene.
(w/raspberry)(CA)
Lucky Seltzer Water Not Not n-isopropyltoluene Source of elevated level of n-

(CA) Detected Detected at 230 ppb (test 2) isopropyltoluene and of n-
(tests 1 & (test 1) n-butylbenzene at butylbenzene contamination
2) 1.8 (test 21 ppb (test 2) unknown; no standards apply.
2) Neither detected in
test 1
Dannon Natural Not Not Methylene chloride FDA's Methylene chloride

Spring Water (NY) Detected Detected at 1.5 ppb (test 3) (dichlormethane) standard is 5
(tests 1-3) (tests 1-3) Methylene chloride ppb.
not detected in tests
1&2
Nursery Water (CA) 3.2 (test 1) 12.4 (test Styrene 3.0 (test 1) Xylene, toluene, and styrene
Not 1) Not Detected (test below FDA & CA standards, but
Detected 0.6 (test 2) could indicate CA treatment
(test 2) 2) standards violation.
Perrier Mineral Not Not 2-Chlorotoluene No standard for 2-chlorotoluene;

Water (CA) Detected Detected 4.6 ppb (test 1) contamination from unknown
(tests 1-3) (tests 1-3) 2-Chlorotoluene source.
3.7 ppb (test 2)
2-Chlorotoluene
Not Detected
(test 3)
Polar Spring Water Not 2.5 Not Detected Toluene detected at level below
(DC) Detected FDA standard (single test).
Publix Drinking Not Not Acetone 11 ppb Styrene found at level well below
Water (FL) Detected Detected (test 1) EPA Health Advisory level; no
(tests 1-3) (tests 1-3) Acetone 14 ppb standard or Health Advisory for
(test 2) acetone.
Acetone 16 ppb
(test 3)
Styrene 0.6 ppb
(test 1)
(No styrene found
tests 2-3)
Publix Purified Not Not Styrene 0.2 ppb Styrene found at level well below
Water (FL) Detected Detected EPA Health Advisory level
(single test).
Safeway Purified Not 8.4 (test Toluene detected at level below

Water (CA) Detected 1) FDA and state standard, but could
(tests 1 & Not indicate CAtreatment standard
2) Detected violation.
(test 2)
Safeway Spring 3.1 (test 1) 14.2 (test Xylene and toluene below FDA
Water (CA) Not 1) & CA standards, but could
Detected Not indicate CAtreatment standard
(test 2) Detected violation.
(test 2)
Safeway Spring Not 4.7 Single test, toluene below FDA

Water (DC) Detected standard.
Source: NRDC 1997-1999
Other Surveys of U.S. Bottled Water Quality

Relatively little information about bottled water quality is readily available to consumers.
Few surveys of bottled water quality have been conducted in the United States during the
past four years, and fewer still are widely available.
A handful of state governments have done surveys in recent years. Kansas has done a
small survey of certain waters sold in the state, [89] Massachusetts prepares an annual
summary of industry testing of waters sold in that state, [90] and New Jersey issues an
annual summary, primarily of industry testing of water sold there. [91] In addition,
Pennsylvania periodically issues a small state survey of waters sold locally, [92] and
Wisconsin issues a small annual testing of about a dozen state waters. [93] In general, these
states have reached conclusions similar to those we have reached: that most bottled
water is of good quality but that a minority of the bottled water tested contains
contaminants such as nitrates or synthetic organic chemicals, in a few cases at levels of
potential health concern. These surveys are summarized in detail in the Technical Report
(print report only).
A few academicians have published papers focusing on bottled water contamination from
specific types of contaminants. For example, academic studies have focused on
Pseudomonas bacteria in various brands of bottled water, [94] the leaching of chemicals
from plastic manufacturing (such as phthalates) [95] from plastic bottles into the water, or
contamination of bottled water with certain volatile synthetic organic compounds. [96] The
researchers often tested only a relatively small number of brands of water, or failed even
to name which bottled water was tested, making the information of limited value to
consumers seeking to select a brand of water that is uncontaminated. Comprehensive
studies of Canadian bottled waters also have been published -- without naming the brands
with problems. The results of many of these studies are in the Technical Report (print
report only), which presents in greater detail the evidence of microbiological and chemical
contamination of bottled water.
Potential for Disease from Bottled Water

As is discussed in the accompanying Technical Report (print report only), there is no
active surveillance for waterborne disease from tap water in the United States, nor is there
active surveillance of potential disease from bottled water. There are certain "reportable"
diseases, such as measles, which are reportable to CDC and state health departments,
and for which there is active surveillance. Most diseases caused by organisms that have
been found in bottled water, however, are not reportable, and in any event may come from
a variety of sources, so the amount of disease from microbiologically contaminated
bottled water (or tap water) is unknown. Thus, since no one is conducting active
surveillance to determine if waterborne illnesses are occurring, even if waterborne illness
from bottled water were relatively common, it would be unlikely that it would be noticed by
health officials unless it reached the point of a major outbreak or epidemic.
There are cases of known and scientifically well-documented waterborne infectious

disease from bottled water, but most have occurred outside of the United States (see
Technical Report [print report only] and Appendix B). However, there clearly is a
widespread potential, according to independent experts, for waterborne disease to be
spread via bottled water. [97]
Bottled Water and Vulnerable Populations

Many people who are especially vulnerable to infection (such as the infirm elderly, young
infants, people living with HIV/AIDS, people on immunosuppressive chemotherapy,
transplant patients, etc.) use bottled water as an alternative to tap water out of concern for
their safety. Some leading public-health experts, therefore, argue that bottled water should
be of higher microbiological quality than most foods. [98] In fact, health-care providers and
other professionals often recommend that people who are immunocompromised or who
suffer from chronic health problems drink bottled water. Indeed, FDA's guidance for
immunocompromised people (posted on the FDA Web site) recommends that people with
lowered immunity should "drink only boiled or bottled water. . . ." [99]
Immunocompromised people often are not aware of the need to ensure that they are
drinking microbiologically safe water or are vaguely aware of this issue but simply switch
to bottled water on the assumption that it is safer than tap water. As discussed previously
and in detail in the accompanying Technical Report (print report only), this may not be a
safe assumption.
Bottled Water Storage and Growth of

Microorganisms
Bottled water often is stored at relatively warm (room) temperatures for extended periods
of time, generally with no residual disinfectant contained in it. As noted in the Technical
Report (print report only) and shown in Figure 8, several studies have documented that
there can be substantial growth of certain bacteria in bottled mineral water during storage,
with substantial increases in some cases in the levels of types such as heterotrophic-
plate-count-bacteria and Pseudomonas. [100] Studies also have shown that even when there
are relatively low levels of bacteria in water when it is bottled, after one week of storage,
total bacteria counts can jump by 1,000-fold or more in mineral water. [101]
Conclusions Regarding Bottled Water
Contaminants
Our limited "snapshot" testing, and that published in a few other recent surveys of bottled
water, indicate that most bottled water is of good quality. However, our testing also found
that about one fourth of the tested bottled water brands contained microbiological or
chemical contaminants in at least some samples at levels sufficiently high to violate
enforceable state standards or warning levels. About one fifth of the brands tested
exceeded state bottled water microbial guidelines in at least some samples. Overall, while
most bottled water appears to be of good quality, it is not necessarily any better than tap
water, and vulnerable people or their care providers should not assume that all bottled
water is sterile. They must be sure it has been sufficiently protected and treated to ensure
safety for those populations.
AN EXAMPLE OF INDUSTRIAL-SOLVENT
CONTAMINATION OF BOTTLED WATER [102]
One particularly troubling case of industrial-

chemical contamination of bottled water arose in
Massachusetts. Massachusetts Department of
Public Health files reveal that the Ann & Hope
commercial well in Millis, Massachusetts, for
years supplied several bottlers, including
Cumberland Farms, West Lynn Creamery,
Garelick Farms, and Spring Hill Dairy with "spring
water" sold under many brand names.
According to state officials and records, this well

is located literally in a parking lot at an industrial
warehouse facility and is sited near a state-
designated hazardous-waste site. Several
chemical contaminants were found in the water,
including trichloroethylene (an EPA-designated
probable human carcinogen). On at least four
occasions these chemicals were found at levels
above EPA and FDA standards in the well water.
Dichloroethane, methylene chloride, and other
synthetic organic chemicals (industrial
chemicals) were also found, though the source of
these contaminants reportedly was not identified.
Contamination was found in the water in 1993,

1994, 1995, and 1996, but according to a state
memo written in 1996, "at no time did Ann & Hope
[the well operating company] do anything to
determine the source of the contamination nor
treat the source. Rather, they continued to sell
water laced with volatile organic compounds,
some of which were reported in finished product."
The contamination levels depended on pumping
rates from the wells. After a state employee blew
the whistle on the problem and demanded better
protection of bottled water in the state, she was
ordered not to speak to the media or bottlers and
was reassigned by Massachusetts Department of
Public Health supervisors to other duties, in what
she alleges was a retaliatory action. State officials
deny that her reassignment was due to retaliation.
The well reportedly is no longer being used for
bottled water after the controversy became
public.
Chapter Notes
3a. For cost reasons, we did not test for any radiological contaminants.
3b. Throughout this report and the attached Technical Report (print report only) we refer to two categories of chemicals
for which we tested, semivolatile synthetic organic chemicals and volatile organic chemicals (VOCs). Technically,
synthetic organic chemicals (SOCs) include any man-made chemicals—including nonvolatile, semivolatile, and volatile—
that contain hydrogen and carbon. We, EPA, and FDA refer to VOCs as a shorthand for volatile synthetic organic
chemicals, and to semivolatile SOCs as separate types of chemicals, even though many VOCs are also a type of SOC.
The reason for differentiating between these two categories of contaminants is that EPA standard methods for testing
for them are different, and because both EPA and FDA rules tend to artificially distinguish between VOCs and SOCs—the
later being shorthand for semivolatile SOCs.
3c. None of the waters we tested exceeded the FDA and EPA standard for arsenic in water of 50 ppb. That standard
originally was set in 1942 and is 2,000 times higher than the level EPA recommends for ambient surface water for public-
health reasons; it also is 5 times higher than the World Health Organization and European Union arsenic-in-drinking-
water limit. Congress has required that the EPA standard be updated by the year 2001. For reasons discussed in the
accompanying Technical Report (print report only), many public health, medical, and other experts believe that the
current EPA/FDA standard is far too high.
Report Notes
75. IBWA, "FAQs [Frequently Asked Questions] About Bottled Water," (1998); available at
www.bottledwater.org/faq.html#3.
76. See, e.g., "The Selling of H2O," Consumer Reports, p. 531 (September 1980),.(finding excessive arsenic in several
waters); "Water, Water Everywhere," Consumer Reports, pp. 42-48 (January 1987), (also finding excessive arsenic in
several waters); see also, "Bottled Water Regulation," Hearing of the Subcommittee on Oversight and Investigations of
the House Committee on Energy and Commerce, Serial No. 102-36, 102nd Cong., 1st Sess. 5, (April 10, 1991), (noting
excessive benzene and other contaminants in bottled water).
77. According to figures for 1994 collected by the Beverage Marketing Corporation, the leading states were, in order,
California (about 30% of the market), Florida (about 6%), New York (about 6%), Texas (about 6%) and Illinois (about 4%).
Beverage Marketing Corporation, Bottled Water in the U.S. , 1996 Edition (1996), as cited in New Jersey Department of
Health & Senior Services, Report to the New Jersey Legislature, Summarizing Laboratory Test Results on the Quality of
Bottled Drinking Water for the Period January 1, 1995 through December 31, 1996, p. 6 (July 1997). A more recent survey
found "California remains the top market for bottled water, with four times the number of gallons sold as the second-
largest market. In fact, Californians drank 893,700 gallons of bottled water in 1997, more than the next four states
combined: Florida (221,700 gallons), Texas (218,700), New York (204,400), and Arizona (124,900)." C. Roush, "Bottled
Water Sales Booming," The Daily News of Los Angeles, p. B1 (April 16, 1998).
78. In a handful of cases, water was found in a test to contain contamination at levels of potential concern, but not
retested -- generally because the water could not be found for retesting or it was logistically impractical to repurchase
and reship the water for retesting. (See Appendix A.)
79. For example, the U.S. Geological Survey's (USGS) National Water Summaries (see, e.g. USGS, National Water
Summary, 1988-1996), and National Water Quality Assessment Program (see, e.g., USGS National Water Quality
Assessment Program--Pesticides in Ground Water (1996), USGS National Water Quality Assessment Program --
Pesticides in Surface Water (1997); see also www.usgs.gov (amply document that water quality measured using
pesticides or other indicator contaminants can vary by orders of magnitude in a stream or shallow groundwater in some
areas, depending upon the time of year, chemical use, hydrologic events such as precipitation, etc.)
80. See, U.S. Public Health Service, Department of Health and Human Services, Review of Fluoride: Benefits and Risks
(February 1991); B. Hileman, "Fluoridation of Water: Questions About Health Risks and Benefits Remain After More than
40 Years," Chemical & Engineering News, pp. 26-42 (August 1, 1988); Robert J. Carton, Ph.D., and J. William Hirzy, Ph.D.,
EPA, and National Treasury Employees Union, "Applying the NAEP Code of Ethics to the Environmental Protection
Agency and the Fluoride in Drinking Water Standard," Proceedings of the 23rd Annual Conference of the National
Association of Environmental Professionals; 24 June 1998, San Diego, California, Sponsored by the California
Association of Environmental Professionals, available at http://home.cdsnet.net/~fluoride/naep.htm.
81. Smith et al., "Cancer Risks from Arsenic in Drinking Water," Environmental Health Perspectives, vol. 97, pp. 259-67
(1992); Agency for Toxic Substances and Disease Registry, Toxicological Profile for Arsenic, (1993); NRDC, USPIRG, and
Clean Water Action, Trouble on Tap: Arsenic, Radioactive Radon, and Trihalomethanes in Our Drinking Water (1995);
United States Environmental Protection Agency, Health Assessment Document for Inorganic Arsenic - Final Report
(March 1984); M. S. Golub, M.S. Macintosh, and N. Baumrind, "Developmental and Reproductive Toxicity of Inorganic
Arsenic: Animal Studies and Human Concerns," J. Toxicol. Environ. Health B. Crit. Rev., vol. 1, no. 3, pp. 199-241 (July
1998).
82. R.D. Morris, "Chlorination, Chlorination By-Products, and Cancer: A Meta Analysis," American Journal of Public
Health, vol. 82, no. 7, at 955-963 (1992); EPA, "Proposed National Primary Drinking Water Regulations for Disinfectants
and Disinfection By-Products," 59 Fed. Reg. 38668 (July 29, 1994); NRDC, U.S. PIRG, and Clean Water Action, Trouble on
Tap: Arsenic, Radioactive Radon, and Trihalomethanes in Our Drinking Water (1995).
83. See, S.H. Swan, et al., "A Prospective Study of Spontaneous Abortion: Relation to Amount and Source of Drinking
Water Consumed in Early Pregnancy," Epidemiology, vol. 9, no. 2, pp. 126-133 (March 1998); K. Waller, S. H. Swan, et al.
(1998). "Trihalomethanes in Drinking Water and Spontaneous Abortion," Epidemiology, vol. 9, no. 2, pp. 134-40 (1998); F.
J. Bove, et al. "Public Drinking Water Contamination and Birth Outcomes," Amer. J. Epidemiol. , vol. 141, no. 9, pp. 850-
862 (1995); see also, NRDC, U.S. PIRG, and Clean Water Action, Trouble on Tap: Arsenic, Radioactive Radon, and
Trihalomethanes in Our Drinking Water (1995).
84. EPA, "National Primary Drinking Water Regulations, Final Rule," 56 Fed. Reg. 3526, at 3537-38 (January 30, 1991);
Environmental Working Group, Pouring it On: Nitrate Contamination of Drinking Water (1996); National Research
Council, Nitrate and Nitrite in Drinking Water (1995).
85. Environmental Working Group, Pouring it On: Nitrate Contamination of Drinking Water, p. 11 (1996),(citing P.G.
Sattelmacher, "Methemoglobinemia from Nitrates in Drinking Water, Schriftenreiche des Verins fur Wasser Boden und
Luthygiene, no. 21 (1962), and Simon, et al. , "Uber Vorkommen, Pathogenese, und Mogliichkeiten sur Prophylaxe der
Durch Nitrit Verursachten Methamogloniamie," Zeitschrift fur Kinderheilkunde, vol. 91, pp. 124-138 (1964)).
86. Ibid.
87. R. J. Madison and J.O. Brunett, U.S. Geological Survey, "Overview of Nitrate in Ground Water of the United States,"
National Water Summary, 1984: USGS Water Supply Paper 2275, p. 93 (1985).
88. D.W. Warburton, "A Review of the Microbiological Quality of Bottled Water Sold in Canada, Part 2: The Need for More
Stringent Standards and Regulations," Canadian J. of Microbiology, vol. 39, p. 162 (1993); H. Hernandez-Duquino, and
F.A. Rosenberg, "Antibiotic-Resistant Pseudomonas in Bottled Drinking Water," Canadian J. of Microbiology, vol. 33,
286-289 (1987); P.R. Hunter, "The Microbiology of Bottled Natural Mineral Waters," J. Applied Bacteriol., vol. 74, pp. 345-
352 (1993); see also, F.A. Rosenberg, "The Bacterial Flora of Bottled Waters and Potential Problems Associated With the
Presence of Antibiotic-Resistant Species," in Proceedings of the Bottled Water Workshop, September 13 and 14, 1990, A
Report Prepared for the Use of the Subcommittee on Oversight and Investigations of the Committee on Energy and
Commerce, U.S. House of Representatives, Committee Print 101-X, 101st Cong., 2d Sess. pp. 72-83 (December, 1990).
89. Kansas Department of Health and the Environment, A Pilot Study to Determine the Need for Additional Testing of
Bottled Water in the State of Kansas (undated, 1994?).
90. Commonwealth of Massachusetts, Executive Office of Health and Human Services, Department of Public Health,
Division of Food and Drugs, Survey of Bottled Water Sold in Massachusetts (May 22, 1997). See also, annual Surveys of
Bottled Water Sold in Massachusetts for 1996, 1995, and 1994.
91. New Jersey Department of Health and Senior Services, Division of Environmental and Occupational Health Services,
Report to the New Jersey legislature, Senate Environment & Assembly Environment, Science, and Technology
Committees, Summarizing Laboratory Test Results on the Quality of Bottled Drinking Water for the Period January 1,
1995 through December 31, 1996 (July 1997).
92. Pennsylvania Department of Environmental Protection, Bureau of Water Supply and Community Health, Division of
Drinking Water Management, Bottled Water Quality Assurance Survey: Summary Report for 1993 through 1995 (1995).
93. Wisconsin Department of Agriculture, Trade, and Consumer Protection, State of Wisconsin Bottled Drinking Water
Report & Analytical Results (Fiscal Year 1997); accord, Wisconsin Department of Agriculture, Trade, and Consumer
Protection, State of Wisconsin Bottled Drinking Water Sampling and Analysis Test Results (Fiscal Year 1994).
94. See, e.g., H. Hernandez-Duquino and F.A. Rosenberg, "Antibiotic-Resistant Pseudomonas in Bottled Drinking Water,"
Can. J. Microbiology, vol. 33, p. 286 (1987).
95. R. Ashby, "Migration from Polyethylene Terepthalate Under All Conditions of Use," Food Add. & Contamin., vol. 5, pp.
485-492 (1988); J. Gilbert, L. Castle, S.M. Jickells, A.J. Mercer, and M. Sharman, "Migration from Plastics Into Foodstuffs
Under Realistic Conditions of Use," Food Add. & Contamin., vol. 5, pp. 513-523 (1988); S. Monarca, R. De Fusco, D.
Biscardi, V. De Feo, R. Pasquini, C. Fatigoni, M. Moretti, and A. Zanardini, "Studies of Migration of Potentially Genotoxic
Compounds Into Water Stored In PET Bottles," Food Chem. Toxic. , vol. 32, no. 9, pp. 783-788 (1994).
96. Page, et al., "Survey of Bottled Drinking Water Sold in Canada, Part 2: Selected Volatile Organic Compounds," J.
AOAC International, vol. 76, no. 1, pp. 26-31 (1993).
97. See, e.g., D.W. Warburton, "A Review of the Microbiological Quality of Bottled Water Sold in Canada. Part 2. The Need
for More Stringent Standards and Regulations." Canadian J. Microbiology, vol. 39, pp. 158-168 (1993); P.R. Hunter, "The
Microbiology of Bottled Natural Mineral Waters," J. Applied Bacteriol. , vol. 74 345-52 (1993); L. Moreira, et al., "Survival
of Allochthonous Bacteria in Still Mineral Water Bottled in Polyvinyl Chloride and Glass, J. Applied Bacteriol. , vol. 77,
pp. 334-339 (1994).
98. D.W. Warburton, "A Review of the Microbiological Quality of Bottled Water Sold in Canada, Part 2: The Need for More
Stringent Standards and Regulations," Canadian J. of Microbiology, vol. 39, p. 162 (1993).
99. D. Farley, "Food Safety Crucial for People With Lowered Immunity," FDA Consumer, available at www.fda.gov
(printed 8/19/1997).
100. L. Moreira, P. Agostinho, P.V. Morais, and M.S. da Costa, "Survival of Allochthonous Bacteria in Still Mineral Water
Bottled in Polyvinyl Chloride (PVC) and Glass," J. Applied Bacteriology, vol. 77, pp. 334-339 (1994); P.V. Morais, and M.S.
Da Costa, "Alterations in the Major Heterotrophic Bacterial Populations Isolated from a Still Bottled Mineral Water," J.
Applied Bacteriol., vol. 69, pp. 750-757 (1990); P.R. Hunter, "The Microbiology of Bottled Natural Mineral Waters," J.
Applied Bacteriol., vol. 74, pp. 345-52 (1993); F.A. Rosenberg, "The Bacterial Flora of Bottled Waters and Potential
72-81 (December, 1990); D.W. Warburton, B. Bowen, and A. Konkle, "The Survival and Recovery of Pseudomonas
aeruginosa and its effect on Salmonellae in Water: Methodology to Test Bottled Water in Canada," Can. J. Microbiol., vol.
40, pp. 987-992 (1994); D.W. Warburton, J.K. McCormick, and B. Bowen, "The Survival and Recovery of Aeromonas
hydrophila in Water: Development of a Methodology for Testing Bottled Water in Canada," Can. J. Microbiol., vol. 40, pp.
145-48 (1994); D.W. Warburton, "A Review of the Microbiological Quality of Bottled Water Sold in Canada, Part 2: The
Need for More Stringent Standards and Regulations," Canadian J. of Microbiology, vol. 39, p. 162 (1993); A. Ferreira, P.V.
Morais, and M.S. Da Costa, "Alterations in Total Bacteria, Iodonitrophenyltetrazolium (INT)-Positive Bacteria, and
Heterotrophic Plate Counts of Bottled Mineral Water," Canadian J. of Microbiology, vol. 40, pp. 72-77 (1994).
101. Ibid; see especially A. Ferreira, A., P.V. Morais, and M.S. Da Costa, "Alterations in Total Bacteria,
Iodonitrophenyltetrazolium (INT)-Positive Bacteria, and Heterotrophic Plate Counts of Bottled Mineral Water," Canadian
J. of Microbiology, vol. 40, pp. 72-77 (1994).
102. The information in this text box is summarized from the Massachusetts Department of Public Health’s (MDPH) Ann
& Hope Water Incident Files, 1993-1997, including MDPH, Survey of Massachusetts Bottlers for Source and Finished
Product Contamination (1992-1997); Summary of the Amount of Water Withdrawn from the Millis Springs, Inc. Spring #2
(undated); Letter from Dr. Elizabeth Bourque to J. McKinnies, Ann & Hope (August 7, 1996); Memorandum From Dr.
Bourke to Paul Tierney, December 13, 1996 (MDPH Memoranda Provided to NRDC Pursuant to Freedom of Information
Request); D. Talbot, "Bottled Water Flows from Troubled Well," Boston Herald, p. 1 (December 16, 1996); E. Leuning,
"Toxin in Ann & Hope Wells Worries Officials," Middlesex News, p. 1 (September 18, 1996); E. Leuning, and H. Swails,
"Water Source has History of Contaminants," Country Gazette (September 18, 1996); Personal Communication with Dr.
Bourque, MDPH, August 1997, and January 1999; Personal Communication with Paul Tierney, MDPH, January 1999.
Chapter 4
GAPING HOLES IN GOVERNMENT BOTTLED

WATER REGULATION
The bottled water industry often makes the claim that it is far better regulated than tap
water suppliers are. For example, the International Bottled Water Association (IBWA)
testified in 1991 that "When compared to the level of regulation and scrutiny applied to tap
water . . .bottled water consumers come out way ahead." [103] IBWA asserted that "If one
considers the full range of FDA consumer protection standards, bottled water safeguards
have been more complete and protective for a longer time than tap water standards." [104]
This continues to be the industry argument. In a 1998 fact sheet, for example, IBWA
contends, "Quality is in every container of bottled water. It's consistent and it is inspected
and monitored by governmental and private laboratories. Unfortunately, tap water can be
inconsistent -- sometimes it might be okay while other times it is not." [105] The IBWA
further declares that "bottled water is strictly regulated on the federal level by the Food
and Drug Administration (FDA) and on the state level by state officials. This ensures that
all bottled water sold in the United States meets these stringent standards." [106]
FDA Rules for Bottled Water Are Generally Less

Strict than Tap Water Rules
Our in-depth review indicates that, with few exceptions, federal bottled water regulation is
weaker than the tap water regulations facing city water supplies. The bottled water
industry is disingenuous in pointing out that there are significant flaws in the tap water
regulatory scheme, since many more flaws exist in bottled water rules. Although smaller
tap water utilities sometimes face less stringent controls than do bigger cities, it still is
clear that federal rules for city tap water generally are more stringent than those for
bottled water.
For many years, under the Federal Food, Drug, and Cosmetic Act (FFDCA), FDA was
supposed to adopt and apply to bottled water all EPA tap water standards within 180 days
after EPA issued those standards. [107] FDA was authorized to refuse to apply the EPA tap
water standards to bottled water in certain circumstances where it determined and
published reasons explaining why they were inappropriate for bottled water. [108] What
happened, however, was that rather than affirmatively making such determinations, FDA
just could not seem to be able to get around to issuing bottled water standards or making
determinations at all.
Historically, FDA has lagged in its obligation to apply the EPA standards to bottled water,
having adopted only a fraction of EPA tap water standards and often being severely
criticized for its inaction. For example, a 1995 Senate committee report noted:
FDA has been slow to act. FDA took 4 years to set standards for the 8 volatile organic
chemicals (including benzene) regulated by EPA in 1989. FDA did not set standards for the
35 contaminants covered by EPA's 1991 Phase II rulemaking until December, 1994.
Standards for bottled water have not been issued for those contaminants regulated by the
[EPA] Phase V rule for tap water, although it was promulgated by EPA in 1992 and became
effective for tap water on January 1, 1994. [109]
Public and congressional criticism of FDA came to a head after benzene was found in
Perrier in 1990, and congressional hearings and a General Accounting Office investigation
in 1991 revealed widespread failures by FDA to adopt standards and to oversee the bottled
water industry. [110] The industry suffered a temporary setback in its growth as a result of
the public scrutiny, but ultimately both it and FDA weathered the storm.
The 1996 Safe Drinking Water Act (SDWA) amendments modified the FFDCA to provide
that, by operation of law, if FDA does not adopt new EPA tap water rules for bottled water
within 180 days, EPA standards will automatically serve as bottled water standards. [111] If
FDA decides to adopt its own standards, they must be at least as stringent as EPA tap
water standards, unless FDA finds that the contaminant does not occur at all in bottled
water -- in which case FDA can waive the requirement to have a bottled water standard. [112]
The current legal status of bottled water standards for contaminants for which EPA had
issued standards for tap water before the enactment of the 1996 SDWA amendments, but
for which there were no FDA bottled water contaminant standards in effect, is being
debated.
NRDC has carefully evaluated the regulatory framework now, more than seven years after
the 1990-1991 storm of controversy swirled around the industry, and more than two years
after the enactment of the SDWA amendments of 1996. We find that although, from 1993 to
1998, FDA adopted some of the additional bottled water standards it was obliged to adopt
(and either decided not to adopt others or simply has not completed rule-making on them),
little else has changed. [113]
Gaping holes remain in the regulatory fabric for bottled water, and FDA and state
resources dedicated to bottled water protection and enforcement generally are thin to
nonexistent. For example, FDA's head bottled water regulator estimates that FDA has just
one half of a person (full-time equivalent or FTE) per year dedicated to bottled water
regulation. [114] Similarly, bottled water compliance is a low priority for FDA, so specific
figures are not kept for resources dedicated to ensuring it meets standards; the
compliance office estimated in 1998 that a likely total of "less than one" FDA staff person
(FTE) is dedicated to bottled water compliance. [115]
The problems created by this lack of regulatory attention are addressed in detail below.
"Voluntary compliance" and "industry self-regulation" seem to be the watchwords for the
bottled water industry. While such an approach can be effective with motivated members
of an industry, the discussions of contamination problems documented in previous
chapters and in the Technical Report (print report only) make it clear that this approach
leaves plenty of room for unscrupulous or careless members of the industry to provide
substandard products, with little chance of being caught or subject to penalties.
This is not to say that bottled water quality is generally inferior to average tap water
quality. We do not believe such a statement is warranted, and in fact NRDC has produced
numerous reports documenting the contamination problems of tap water. [116]
Our evaluation does show, however, that the regulatory system intended to ensure bottled
water quality has enormous gaps. The majority of bottled water, according to FDA, is not
covered by federal regulations, and FDA does not regulate or monitor the bottled water
that is covered by its rules particularly well.
Gaps and Loopholes in FDA Regulations

1. Water bottled and sold in a single state -- the majority of bottled
water sold in the United States -- is not covered by FDA rules,
according to FDA.
An estimated 60 to 70 percent of the bottled water sold in the United States is sold in "
intrastate commerce" (i.e., it is bottled and sold in the same state). [117] For example, the
large delivered 5-gallon carboy bottles that are put in office or home water coolers are
often intrastate waters, as are many of the brands sold in grocery, convenience, and other
stores.
FDA says its bottled water regulations apply only to water "that is in, or is intended to be
shipped in, interstate commerce." [118] (emphasis added) Thus, according to FDA's
interpretation, 60-70 percent of the bottled water sold in the U.S. -- all bottled water sold in
intrastate commerce -- apparently is not covered by the FDA rules. This leaves the
government regulation of this water, if any, to state governments.
The position that intrastate bottled water is not covered by FDA's rules is based on FDA's
interpretation of the limitations of the Federal Food, Drug, and Cosmetic Act, [119] which
FDA says allows it to regulate only interstate commerce (i.e., water that crosses state
lines). This interpretation of the FFDCA has been questioned by experts, including some in
the bottled water industry.[4a] Indeed, the FDA interpretation of the FFDCA appears to be
unduly narrow, in light of the clear nexus between virtually all intrastate bottled water
sales and interstate commerce, as demonstrated, for instance, in the fact that packaging
materials and consumers of the bottled water frequently come from out of state.
The impact of the narrow FDA interpretation cannot be overstated. Our survey of states,
reviewed later in this chapter, found that often states have few if any resources dedicated
to policing bottled water. Thus, in many states, compliance with federal and state bottled
water standards essentially is discretionary for many bottlers, and the public's only
protection is voluntary industry self-regulation. This offers little or no protection from fly-
by-night bottlers in some states.
The problem of inadequate regulatory protection for intrastate sales of bottled water was
identified in 1991 as a significant problem by the General Accounting Office in a report
delivered to Congress. [120] Nothing has been done by FDA or Congress to remedy the
federal regulatory gap.
2. FDA's definition of "bottled water" covered by its standards

irrationally exempts many types of bottled water.
FDA's rules exempt many forms of what most of us would consider bottled water from its
definition of "bottled water," and therefore, according to FDA, exempts them from all of
FDA's specific standards for bottled water testing and contamination. If the product is
declared on the bottle ingredient label simply as "water," or as "carbonated water,"
"disinfected water," "filtered water," "seltzer water," "soda water," "sparkling water," or
"tonic water," it is not considered "bottled water" by FDA. [121] FDA says it exempted these
waters because they are "not understood by the public to be bottled water." [122] What is
covered by FDA's rules? FDA says it regulates products labeled as "spring water,"
"mineral water," "drinking water," "bottled water," "purified water," "distilled water," and a
few other specific categories of bottled water -- creating enormous confusion for any
consumer seeking to figure out whether FDA rules apply or do not apply to a specific
water on the grocery store shelf.
We doubt that most consumers would agree that water in a bottle listed on the ingredient
label as "water" or "sparkling water" or "filtered water" should be exempted from the
specific health-protection standards that cover any other bottled water. California and
some other states have chosen a different course than FDA and regulate all water that
comes in bottles likely to be ingested by people as bottled water. [123] We support this
approach and recommend that FDA revise its rules to cover all water intended for drinking
or culinary purposes that is likely to be ingested by people and that comes in a bottle, as
California and some other states have done.
Industry data indicate that these waters that FDA exempts from the definition of bottled
water represent a significant chunk of the overall bottled water industry. For example, a
report in the beverage-industry trade press noted that in 1996 there were more than 152
million cases of sparkling water sold in the United States. [124] This of course does not
include many nonsparkling exempted waters such as "filtered water" or "disinfected
water."
For these "non-bottled water" bottled waters, FDA officials have said the specific FDA
contamination standards and water-quality testing requirements, as well as the specific
bottled water good-manufacturing-practice rules for bottled water, are not applicable. [125]
Thus, no contamination monitoring is specifically required, and only a vague narrative
standard applies, according to FDA, which states that the water cannot be "adulterated"
and must be safe, wholesome, and truthfully labeled. These nebulous terms are not
defined and, to date, apparently the FDA has never enforced the standard with any of
these bottled products.
3. Even water defined as "bottled water" is not specifically required to
meet treatment, contamination, or testing standards as strict as those
applicable to city tap water.
Water that FDA does define as "bottled water" is not required by federal rules to meet
many of the specific standards and testing requirements that apply to city tap water. Some
of the important disparities between bottled water and tap water are noted in Table 1 (in
chapter 1), and in Tables 6 and 7. This seems to directly contradict the FFDCA's
requirement[126] that bottled water is supposed to be regulated as stringently as tap water.
FDA argues that it retains the authority to act against "adulterated" water (which is not
specifically defined) and that its general food-safety authorities give it broad latitude to act
if it finds a problem. [127] However, there is no indication that FDA has ever acted -- or has
any intention of acting -- aggressively to implement and enforce treatment standards akin
to those applicable to tap water. Moreover, FDA does very little random monitoring on its
own of bottled water quality, so there is little assurance that if a problem does exist, FDA
would ever find out about it.
Some of the important incongruities between tap water and bottled water standards follow.
Weaker bacteria rules for bottled water. There is a clear prohibition under EPA rules
against any confirmed E. coli or fecal coliform bacteria in tap water. [128] FDA has adopted
no such prohibition for bottled water. [129] Rather, FDA's rules set a maximum number of
total coliform bacteria in bottled water, with no specific prohibition on fecal coliform
bacteria or E. coli contamination of bottled water. [130] FDA's proposal over four years ago
(in October 1993[131]) to issue a ban on all coliform bacteria in bottled water has languished.
FDA has no specific plans to finalize this rule in the near future. [132]
Moreover, EPA's rules essentially treat excessive heterotrophic-plate-count (HPC) bacteria

(i.e., HPC presence greater than 500/ml) as a "positive" for total coliform bacteria for most
big-city water supplies; no more than 5 percent of all monthly tap water samples can
contain total coliform bacteria. [133] FDA has adopted no rules for HPC in bottled water; the
agency says if HPC levels exceed 10,000/ml (i.e. 20 times higher than the EPA benchmark
for tap water), FDA "will consider conducting a follow-up inspection of domestic
bottlers...." [134]
In addition, while we certainly do not endorse EPA's water-testing rules for tap water as a
panacea for drinking water problems, at least a system serving a larger city (more than
100,000 people) has to test its tap water over 100 times each month for coliform bacteria,
on average several times a day. [135] Yet bottled water -- even at a huge bottling plant filling
millions of water bottles a year -- must be tested for coliform bacteria only once a week
under FDA rules. [136] (IBWA's model industry code recommends daily testing of its
members' water, though IBWA's recommendation is not binding unless adopted under
state law -- an action that most states have not taken, as noted in our review of state
programs later in this chapter.)
FDA's failure to adopt these bacteriological standards contradicts FFDCA's requirement

that FDA standards for bottled water must be at least as strict as tap water standards. [137]
No treatment requirements to remove or kill bacteria and parasites in bottled water. Under
EPA's tap water rules, which are less than complete, cities using surface water generally
must disinfect their water and filter it to remove not only bacteria (e.g., coliform bacteria
and Legionella) and viruses, but also certain protozoa such as Giardia (unless they can
document and obtain formal approval for a filtration waiver because their water is of very
high quality and their source water is highly protected from contamination). [138] Yet, as
shown in Tables 1 and 6, there are no specific FDA standards requiring bottled water to be
disinfected or treated in any way to remove bacteria or parasites[139] -- another apparent
violation of FFDCA's comparability requirement for bottled water and tap water standards.
There is a maximum turbidity standard for bottled water of 5 units (the same as for tap
water, though the new tap water maximum is 1 unit effective on December 17, 2001, under
a recently issued rule). [140] There is no rule, however, requiring that bottled water average
less than 0.5 units of turbidity each month -- a requirement that currently applies to tap
water and will be dropped (effective on the same date) to 0.3 units (for the 95th percentile
level) under the same recent EPA rule. Moreover, while tap water must have ongoing
turbidity sampling every four hours, no such requirement applies to bottled water. [141] The
weaker bottled water rule is of concern because turbidity is in many cases the only
indication that water is contaminated with parasites. [142]
Despite these serious FDA regulatory gaps, the bottled water industry publicly proclaims,
we believe without justification, that consumers should turn to bottled water if they want
to avoid Cryptosporidium (the protozoan that sickened 400,000 people and killed more
than 100 due to tap water contamination in Milwaukee in 1993[143]). IBWA states, for
example, that FDA rules "ensure that surface water contaminants such as
Cryptosporidium and Giardia are not present" in bottled water derived from wells and
springs, and that it tells its members to use additional treatment if they produce tap-water-
derived bottled water, to assure that Cryptosporidium cannot get into the bottled water. [144]
Such public proclamations seem to run contrary to the bottled water industry's own
privately expressed concerns about the possibility of Cryptosporidium in bottled water
supplies. [145] Candid internal communications admit that unless all water bottlers adopt
adequate treatment to kill or remove Crypto, they will have a hard time convincing the
public that bottled water is immune from such contamination. For instance, the following
appeared in the IBWA's in-house publication, urging bottlers to upgrade their treatment to
be sure it meets CDC guidelines for removing Cryptosporidium: "How can we expect
health groups to endorse our product if we don't ALL meet the [CDC Cryptosporidium
removal] guidelines!" [146] (emphasis in original). An excellent question, indeed.
No Cryptosporidium and Giardia testing for bottled water. EPA's Information Collection
Rule has required that over the past couple of years, big cities that use surface water
(systems which serve the majority of the U.S. population) generally must test for common
parasites such as viruses, Giardia and Cryptosporidium.[147] By contrast, FDA rules do not
specify that any water bottlers are ever required to do such testing. [148]
Weaker standards for some chemical contaminants in bottled water. The regulatory
standards for several chemicals in bottled water are also weaker than the standards for
city tap water (see Table 6). For example, FDA has refused to set standards or treatment
techniques for acrylamide, asbestos, di(2-ethylhexyl)phthalate (DEHP), or epichlorohydrin,
[149]
all of which EPA regulates in tap water.[4b]
It is a strange twist indeed that DEHP, a probable human carcinogen, possible endocrine-
system disrupter, and agent produced in plastics manufacturing that migrates into water
from plastic water bottles, is regulated under EPA tap water rules but not under FDA's
bottled water rules. [150] Logic would suggest that if anything, it is more important to control
phthalate in bottled water since, it is so often sold in plastic bottles that can leach this
chemical.
In fact, FDA stated when it decided not to adopt a DEHP standard that it was the only
chemical contaminant it had proposed to regulate in that package of standards that it was
aware occurred in bottled water at levels over the EPA standard. [151] Some bottlers and
members of the plastics manufacturing industry vigorously opposed a phthalate standard,
arguing that it would cause some bottled water to be in violation after storage for long
periods. [152] As one company put it, "bottled water tested immediately after packaging
would meet the 6 ppb [FDA proposed] limit but with storage it is possible that levels might
exceed this requirement . . .[so] the proposed amendment . . .[would] effectively ban the
use of DEHP in closure sealants for bottled water . . . ." [153] Although other members of the
bottled water industry supported a phthalate standard, [154] FDA bowed to those who
objected, and decided not to apply the EPA standard -- or any other standard -- for DEHP
in bottled water. [155] FDA deferred further action on the DEHP standard indefinitely. This
appears to be a clear violation of the Federal Food, Drug and Cosmetic Act, which requires
bottled water rules to be at least as stringent as EPA's tap water rules. [156]
Similarly, in response to bottled water industry complaints about the burden of having to
comply with too many standards (and in particular the costs of testing), in 1996 FDA
decided to stay any bottled water standards for nine chemical contaminants that have
been regulated in tap water since 1992. The nine were antimony, beryllium, cyanide,
diquat, endothall, glyphosate, nickel, thallium, and 2,3,7,8-TCDD (dioxin). [157] In this case,
however, the outcome appears as if it will be different. In August 1996, Congress
mandated that FDA adopt bottled water standards for those nine chemicals within two
years of enactment, or EPA's tap water rules for those contaminants would automatically
apply to bottled water. [158] In response to that congressional mandate, in May 1998, FDA
issued a "direct final rule" that would make EPA's tap water standards for these nine
contaminants enforceable for bottled water by February 1999. [159] In August 1998, FDA
confirmed that the new rules for the nine contaminants would finally be subject to
regulation in bottled water as of February 2, 1999[160] -- seven years after EPA issued
standards for them in tap water.
There is a ray of light in the FDA bottled water regulatory program. FDA's bottled water
standards for lead, copper, and fluoride are stricter than EPA's tap water standards (see
Table 6). [161] The bottled water industry advocated stricter standards for these
contaminants, on health grounds. A cynic might speculate that these standards enable the
bottled water industry to claim that its water is more strictly regulated than tap water (a
claim some in the industry routinely make) without much of a regulatory bite, since these
contaminants are rarely a problem in bottled water. (Lead and copper generally exist in tap
water due to leaching from pipes or faucets between the treatment plant and the consumer
and should not be found in bottled water; fluoride generally is intentionally added to tap
water, though it is sometimes found in bottled water.) However, there is no record of such
a rationale influencing the bottled water industry's position.
TABLE 6
Comparison Of Health Standards: Tap Water Versus Bottled Watera
Contaminant EPA Health EPA Tap Water FDA Bottled Bottled Water
Goal Standard Water ("BW") vs. Tap
(parts per billion) Standard Water Standard
(parts per billion) (parts per billion)
Bacteria And Microbial Quality

E. Coli or Fecal 0 No confirmed Up to 1 of 10 BW Weaker
Coliform samples of E. Coli bottles tested may
or fecal coliform contain specified
allowed levels of any type
of Coliform,
subject to
conditions
Giardia lamblia 0 Treatment No Standard BW Weaker

Technique
Legionella 0 Treatment No Standard BW Weaker

Technique
Standard-Plate-Count Not Applicable Treatment No Standard BW Weaker

Bacteria Technique
(Heterotrophic-Plate-
Count)
Total Coliform 0 No more than one Specified levels BW Generally

sample/month of Total Coliform Weaker
may contain any allowed in up to 1
total coliform in 10 bottles
(small systems). tested, subject to
Cities: no more conditions; no ban
than 5% of on E. Coli or fecal
samples may coliform
contain any
coliform. No
confirmed E. Coli
or fecal coliform
allowed
Turbidity Not Applicable Treatment 5 NTUb BW Weaker

Technique; EPA lowered to 1
5 NTUb NTU 12/16/98,
maximum; less effective in 3-5
than 0.5 NTU years
95% of time.
Viruses 0 Treatment No Standard BW Weaker

Technique
Chemical Contaminants
Acrylamide 0 TT No Standard BW Weaker
Adipate, (di(2- 400 400 400 Same

ethylhexyl))
Alachlor 0 2 2 Same
Antimony 6 6 New Standard Same

effective Feb.
1999c
Arsenic 50 50 50 Same
Asbestos (>10µm) 7 MFLd 7 MFLd No Standard BW Weaker
Atrazine 3 3 3 Same
Barium 2,000 2,000 2,000 Same
Benzene 0 5 5 Same
Beryllium 4 4 New Standard Same

Feb. 1999c
Cadmium 5 5 5 Same
Carbofuran 40 40 40 Same
Carbon Tetrachloride 0 5 5 Same
Chlordane 0 2 2 Same
Chlorobenzene 100 100 100 Same
Chromium (total) 100 100 100 Same
Copper 1,300 Treatment 1,000 BW Stricter

Technique
Cyanide 200 200 New Standard Same

effective Feb.
1999c
Dalapon 200 200 200 Same
2,4-D 70 70 70 Same
Dibromochloropropane 0 0.2 0.2 Same
o-Dichlorobenzene 600 600 600 Same
p-Dichlorobenzene 75 75 75 Same
1,2 -Dichloroethane 0 5 5 Same
1,1-Dichloroethylene 7 7 7 Same
cis-1,2- 70 70 70 Same
Dichloroethylene
Trans-1,2- 100 100 100 Same

Dichloroethylene
Dichloromethane 0 5 5 Same
1,2-Dichloropropane 0 5 5 Same
Dinoseb 7 7 7 Same
Dioxin 0 0.00003 New Standard Same
effective Feb.
1999c
Diquat 20 20 New Standard Same

effective Feb.
1999c
Endothall 100 100 New Standard Same

effective Feb.
1999c
Endrin 2 2 2 Same
Epichlorohydrin 0 Treatment No Standard BW Weaker

Technique
Ethylbenzene 700 700 700 Same
Ethylene Dibromide 0 0.05 0.05 Same
Fluoride 4,000 4,000 Range from 800 BW Stricter

to 2,400
Glyphosate 700 700 New Standard Same

effective Feb.
1999c
Haloacetice Acids (5) 0 60 None BW Weaker
Heptachlor 0 0.4 0.4 Same
Heptachlor Epoxide 0 0.2 0.2 Same
Hexachloro-benzene 0 1 1 Same
Hexachlorocyclo- 50 50 50 Same
pentadiene
Lead 0 Treatment 5 BW Stricter

Technique
Lindane 0.2 0.2 0.2 Same
Mercury 2 2 2 Same
Methoxychlor 40 40 40 Same
Nitrate 10 10 10 Same
Nitrite 1 1 1 Same
Oxamyl 200 200 200 Same
PAHs 0 0.2 0.2 Same

(benzo(a)pyrene)
Pentachlorophenol 0 1 1 Same
PCBs 0 0.5 0.5 Same
Phthalate, (di(2- 0 6 No Standard BW Weaker

ethylhexyl))
Picloram 500 500 500 Same
Selenium 50 50 50 Same
Simazine 4 4 4 Same
Styrene 100 100 100 Same
Tetrachloroethylene 0 5 5 Same
Thallium 0.5 2 New Standard Same

effective Feb.
1999c
Toluene 1,000 1,000 1,000 Same
Toxaphene 0 3 3 Same
2,4,5-TP (Silvex) 50 50 50 Same
1,2,4-Trichlorobenzene 70 70 70 Same
1,1,1-Trichloroethane 200 200 200 Same
1,1-2-Trichloroethane 3 5 5 Same
Trichloroethylene 0 5 5 Same
Trihalomethanes 0 80f 100 BW Weaker
Vinyl Chloride 0 2 2 Same
Xylenes (total) 10,000 10,000 10,000 Same
Radioactive Substances
Alpha Emitters 0 15 pCi/Lg 15 pCi/Lg Same
Beta/Photon Emitters 0 4 mrem/yrh 4 mrem/yrh Same
Radium (Combined) 0 5 pCi/Lg 5 pCi/Lg Same
a Standards for bottled water reported in this table are only those adopted for health reasons and thus do
not include secondary "aesthetically based" standards (such as those for color, chloride, iron, aluminum,
silver, and manganese) that FDA adopted for aesthetic rather than health purposes; these secondary
standards (except those for aluminum and silver) do not apply to bottled mineral water.
b Nephelometric Turbidity Units (or NTU), is a measurement of turbidity, or water cloudiness.
c An explicit mandate adopted by Congress in 1996 would have automatically applied EPA's tap water
standard for this contaminant to bottled water, unless FDA adopted a bottled water standard for the
contaminant by August 6, 1998. On August 6, 1998, FDA confirmed a "direct final rule" that will apply the
1992 EPA tap water standard for this contaminant to bottled water, effective February 2, 1999. See 63 Fed.
Reg. 42198. Until February 2, 1999, there is no bottled water standard for this contaminant.
d MFL means Million Fibers of Asbestos per liter of water.
e Tap water standard of 60 ppb for 5 haloacetic acids effective December 16, 2001 (except some small
systems have until December 16, 2003). See 63 Fed. Reg. 69389 (December 16, 1998).
f On December 16, 1998, EPA reduced the tap water MCL for TTHMs to 80 ppb from 100 ppb, effective
December 16, 2001 (except some small systems have until December 16, 2003). See Fed. Reg. 69389
(December 16, 1998).
g pCi/L means picocuries (a unit measuring radioactivity) per liter.
h mrem/yr means a manmade radioactivity annual dose equivalent to the whole body or any internal organ
of 4 millirems per year.
Source: NRDC
Weaker chemical-contaminant testing requirements for bottled water. Under EPA rules, a
city must test its tap water for many organic chemicals, generally at least once a
quarter.[162] In some cases (such as for trihalomethanes), city tap water systems must test
at several locations each quarter.[4c]
Water bottlers, on the other hand, generally need only test for most chemicals once a year
under FDA's rules.[4d] Moreover, water bottlers currently are exempt from testing for
asbestos or phthalate, though there are tap water testing and health standards for these.
In addition, tap water supplies must test for 16 additional unregulated contaminants and
report the test results to authorities, as noted in Table 7. [163] Thus, it is apparent that
bottled water testing requirements for some contaminants are less extensive and in depth
than those that apply to city water systems.
TABLE 7
Contaminants That Must Be Monitored in City Tap Water but Not in Bottled Water
Regulated Contaminants Currently Required to be Monitored in Tap But Not Bottled Water
Asbestos Haloacetic acids (big cities past, soon all systems)

Bromate (big cities past, soon all systems)
Di(2-Ethylhexyl)phthalate
Unregulated Contaminants* Currently Required to be Monitored in Tap But Not Bottled Water
Dibromomethane 1,2,3-Trichloropropane
m-Dichlorobenzene 1,1,1,2-Tetrachloroethane
1,1-Dichloropropene Chloroethane
1,1-Dichloroethane 2,2-Dichloropropane
1,1,2,2-Tetrachloroethane o-Chlorotoluene
1,3-Dichloropropane p-Chlorotoluene
Chloromethane Bromobenzene
Bromomethane 1,3-Dichloropropene
Source: 40 C.F.R. §§ 141.21-141.30, 141.40 and 21 C.R. R. § 165.110
"Unregulated Contaminants" are contaminants not subject to enforceable Maximum Contaminant Levels or
treatment requirements, but still required to be monitored for in tap water. "Regulated contaminants" are
those subject to enforceable regulations currently, or under rules already promulgated but not enforceable
until December 2001.
Bottlers self-test and do not have to use certified labs to test water; tap water suppliers
may only use certified labs. Under EPA's regulations, in order to ensure that water test
results submitted by drinking water suppliers are accurate and of the highest quality, most
tests must be completed by laboratories certified by a state in accordance with EPA
criteria. [164] This helps to ensure consistent quality assurance and quality control, and
reduces the chances of inadvertent or intentional inaccuracies in water testing (although
in many states, for some systems it is up to the water system to submit the water to the
lab for testing, presenting potential opportunities for mischief).
FDA, on the other hand, relies upon water bottler self-testing and self-selection of
laboratories, and has refused to require lab certification. This failure to require certified
labs came under criticism from General Accounting Office (GAO) investigators. In a critical
1991 report, GAO noted:
FDA lacks assurance that such [bottled water] tests are done correctly or that the results
are reliable. FDA regulations specify that either "qualified bottling plant personnel" or
"competent commercial laboratories" use approved water quality test methods...[but] has
not defined qualified personnel or competent laboratories, and it does not require that
such personnel or laboratories be certified or otherwise establish their qualifications to do
the required tests. In contrast, for public drinking water, EPA requires certified
laboratories.... [165]
Even after this GAO report, FDA has twice refused to require that water bottlers use
approved certified laboratories(even when the IBWA petitioned FDA to require them. In
1993, FDA argued:
the Act does not provide a basis for these [lab] approvals. Moreover, the act does not
provide authority to the agency to require such approval. Further, even if such authority
were provided by the Act, FDA lacks the resources to monitor analytical laboratories and
personnel in the absence of a significant public health problem.[166]
FDA reiterated this position in 1995. [167]
We disagree with FDA's narrow reading of the law as not authorizing such certification.
For example, FFDCA Chapter IV and section 701 provide broad authority to FDA to
promulgate such a requirement. [168] FDA takes the position that under its authority under
the FFDCA, it can legally require bottlers to use competent commercial laboratories, but
for reasons that are not supported, FDA contends that it lacks legal authority to dictate
that bottlers must use a certified lab.
In addition, even if FDA did not enjoy the authority to mandate use of certified labs before
1996, Section 410 of the FFDCA as amended by the 1996 SDWA amendments seems to
clearly support such a requirement. That newly revised provision of the FFDCA expressly
authorizes FDA monitoring regulations for bottled water and makes EPA's tap water rules -
- apparently including the EPA's certified-lab requirements -- automatically apply in the
case of FDA inaction. [169] If, indeed, FDA still believes it lacks the legal authority to require
certified labs, FDA should ask Congress for such authority.
With respect to resource constraints, FDA could ask Congress for additional resources for
the bottled water program. As suggested in the recommendations in Chapter 1, a one-
cent-per-bottle fee on bottled water would ease the FDA resource problem. In addition, it
would require no expenditure of FDA resources whatsoever for FDA simply to require that
the labs used to test bottled water be EPA-certified (or state-certified with EPA approval)
for drinking water testing. This is a commonsense solution that FDA apparently refuses to
consider for reasons that are not entirely clear.
While tap water system operators must be trained and certified, bottlers need not be.
Under the Safe Drinking Water Act amendments of 1996, tap water suppliers' operators
must receive training and be certified as competent to treat water by EPA-approved state
authorities, pursuant to federal guidelines for determining the level of competence
needed. [170] This requirement is widely viewed as an important development, because it will
begin to ensure that opportunities for operator error -- often the cause of serious
contamination problems and even disease outbreaks in tap water systems -- will be
reduced.
Although the IBWA petitioned FDA to require certification of bottling-plant supervisory

personnel, FDA denied this petition in 1993. [171] FDA reiterated its denial in 1995. [172] As in
the case of certifying labs, FDA argued that it lacked the authority and the resources to
require such certification of bottling-plant personnel.
Again, we disagree on both points; FFDCA Chapter IV and in particular sections 410 and
701 provide FDA with ample authority to require plant personnel to be competent,
particularly in light of the 1996 SDWA amendments' incorporation by reference of EPA's
National Primary Drinking Water Regulations to bottled water in cases of FDA inaction. On
the issue of resources, creative solutions are available, including asking Congress for
funds, establishing a per-bottle fee, and/or using independent, FDA-certified trainers and
certifiers (such as state or third-party certification organizations using FDA training and
certification guidelines).
FDA's source water approval requirement is essentially meaningless. Theoretically, under

FDA rules, the source of bottled water must be approved by state or local authorities. [173]
FDA's description of what is required to be an approved source is sketchy: It "means a
source of water...that has been inspected and the water sampled, analyzed, and found to
be of a safe and sanitary quality according to applicable laws and regulations of state and
local government agencies having jurisdiction." [174] There are no guidelines for what is
required of these state and local rules, nor is there any explanation of what should be
done if there are no state or local rules or jurisdiction.
In discussing why the public should feel comfortable with bottled water quality, the bottled
water industry often cites this FDA regulatory requirement for source approval. For
example, IBWA's widely disseminated fact sheet for consumers notes:
While bottled water originates from protected sources (75 percent from underground
aquifers and springs), tap water comes mostly from rivers and lakes....
[B]ottled water companies are required to use approved sources. There are two types of
sources from which bottled water can be drawn: the first type is natural sources (i.e.,
springs and wells). By law, these sources must be protected from surface intrusion and
other environmental influences. This requirement ensures that surface contaminants such
as Cryptosporidium and Giardia are not present.
The second source water type is approved potable municipal supplies.... [175]
This highly touted FDA-approved-source requirement is, however, in the words of one
study, "a regulatory mirage." [176]
There are no specific requirements in FDA rules for protection of bottled water sources
from pollution sources (such as setbacks from hazardous-waste dumps, industrial
facilities, septic tanks, or underground gasoline storage tanks), nor are there any specific
rules for disapproval of sources once they become contaminated. In fact, there are no
requirements for bottlers or state or local authorities even to evaluate or document
whether any such potential contamination sources may exist. In addition, in 1990,
government investigators reviewing bottler records found that 25 percent of the bottlers
audited had no documentation of source approval. [177]
This contrasts with requirements for city tap water. Under the 1996 SDWA amendments,
states are required to conduct a source-water assessment for public drinking water
supplies (i.e., tap water). [178] The assessment is required to delineate the boundaries of the
assessment area that supplies the water system and to evaluate known or potential
sources of contamination and the susceptibility of the drinking water source to
contamination. [179] Millions of dollars in federal funding were made available to conduct
these assessments.
In the case of bottled water source approvals, however, NRDC's investigation has noted
cases in which the source of bottled water either was never assessed by authorities or the
assessment overlooked important nearby contamination sources. In such cases, the
source is anything but "protected" from contamination. Even in a state with a relatively
well-developed bottled water program, like Massachusetts, the source-approval process
apparently is essentially pointless. For example, as discussed in Chapter 3, the Millis well,
in an industrial parking lot in Massachusetts near a state-designated hazardous-waste
site, for several years supplied contaminated water to several major bottlers and was an
approved source. [180] If even in an extreme case, such as the Ann & Hope well in Millis, the
well meets the "approved source" requirement, the FDA rule appears to have no meaning.
Indeed, in our review of scores of bottlers' files maintained by several states, we found no
case in which source approval was denied or revoked. In the Millis Well Case, the state
said it would allow continued use of the source, despite past contamination, if the water
were subject to treatment; apparently the well is no longer used for bottling water.
4. Bottlers may violate FDA standards if the label notes that the water
"contains excessive chemical substances."
The problem with FDA bottled water standards is not limited to the gaps in their coverage
or lack of certified labs. Many people are stunned to learn that even if bottled water is
more contaminated than FDA's standards would otherwise allow, FDA rules (and those of
many states) explicitly still allow the water to be sold. The contaminated water may be
marketed so long as it says on the label "contains excessive chemical substances" or
"contains excessive bacteria" or includes a similar statement on the label. [181] For example,
as discussed in the accompanying Technical Report, (print report only) the state of New
Jersey found that Fuentes De Cutolo Spring Water contained nitrates at elevated levels
that exceeded the FDA and state standards (as noted in our discussion of nitrates' health
effects in Chapter 3 and the Technical Report (print report only), nitrates can cause blue-
baby syndrome in infants if consumed at levels in excess of standards). Rather than
taking an enforcement action, the state "requested that this firm either reduce the level of
nitrate by treatment or change the product label to include a statement 'contains excessive
nitrate'" on its label. [182]
In fact, in a 1996 Federal Register notice, FDA sent clear signals to the industry that if a
bottler violates FDA standards, in some cases FDA is prepared to take no action so long
as the bottle includes such a statement. Responding to industry concerns that bottled
water that meets chemical-contamination standards in Europe might violate some
proposed FDA rules, FDA pointed out that:
if a bottled water product...exceeds an allowable level for a particular contaminant...the

bottler can still market that product, provided that the labeling bears a statement of
substandard quality -- e.g., if it exceeds the allowable level for thallium, the labeling shall
state either "Contains Excessive Thallium" or "Contains Excessive Chemical
Substances".... Therefore, should a European or American bottled water product exceed
the allowable levels of contaminants, it still can be marketed in the United States if its
labeling bears the prescribed statement of those contents. [183]
FDA suggests that it may enforce against such labeled contaminated water if it finds that it
is "injurious to health" and thus "adulterated" [184] -- but there is no requirement that such
contaminated bottles even be reported to FDA, and we have been able to find no cases of
FDA having taken any enforcement action against any such bottlers.
5. Bottlers are not required to report test results or violations and

may dispose of records after two years; tap water suppliers must
report results and retain records.
Under EPA rules, tap water suppliers must report their monitoring results and any drinking
water standards violations that occur to EPA or, if the state has obtained formal EPA
approval to exercise "primary enforcement authority," the water system must report to the
state. [185] If there is a serious violation, it must be reported to the state within 48 hours. [186]
The state then must report results and violations to EPA, [187] and EPA then posts all
violations on the Web for easy public access. In addition, tap water suppliers must keep
on hand their bacterial testing results for 5 years, and their chemical tests for 10 years, to
allow effective EPA and state inspections. [188]
In contrast, FDA rules include no provision obligating a bottler to notify FDA or a state of
test results, contamination problems, or violations, even in the case of contamination that
could pose a serious health threat. FDA has refused to require such reporting when called
upon to do so during rule-making proceedings. [189]
Answering both criticism of this lack of reporting and questions about how it can
effectively track bottler compliance without reporting of test results, FDA said it "does not
have the resources to review bottled water test results except during FDA plant
inspections." [190] As noted below, however, such FDA inspections are quite rare (every four
to five years or less frequently). Moreover, FDA requires bottlers to retain their testing
records for just two years[191] -- unlike the 5 year/10 year EPA tap water supplier
requirement. [192] This means that since FDA inspections are so rare, many contamination
problems may never come to FDA's attention, because the record of the event can be
discarded before FDA ever reviews the bottler's records.
As GAO has pointed out, such record retention can be critically important "to allow
regulatory officials to (1) review historical test data to verify that the tests were done, (2)
gain insight into a particular or recurring problem, and (3) learn of and respond to
contaminated water problems." [193]
This lack of reporting combined with other shortcomings in FDA's program pose serious
problems for enforcement and compliance monitoring. For example, FDA does not
maintain an inventory of water bottlers or shippers, so it often must rely upon state
authorities for such information. [194] But state programs vary widely, with some having few
if any resources dedicated to tracking bottled water (see the state programs section, later
in this chapter.) Without an inventory of bottlers or reporting of testing results or
violations, it is logistically difficult, to say the least, for FDA to adequately track bottler
compliance.
6. Bottlers are not required to test water after storage, when it may
have increased contamination levels, nor are they required to list the
bottling dates for their water.
FDA's rules require weekly bacteria testing and annual chemical testing, but this testing is
generally done of water at the bottling plant. [195] There is no requirement that bottlers test
water after shipping it to stores or after storage. Moreover, FDA has refused requests to
require bottlers to place a bottling date on their bottled water, or to require a label
suggesting that consumers refrigerate their water after opening to retard bacterial growth.
This is problematic in light of the investigations discussed in earlier chapters of this report
indicating that HPC bacteria, Pseudomonas aeruginosa, algae, and other microbes that
may be present only at very low (or nondetectable) levels immediately after bottling can
bloom and grow after bottling. The "FDA acknowledges that some bacteria can grow in
bottled water, and that bottled water, unless treated in some manner, is not sterile." [196] But
such post-bottling microbial-growth problems are missed under standard "at the bottling
plant" testing under FDA rules.
Moreover, if there is no bottling date for bottled water, and no consumer warning to
refrigerate after opening, the regrowth in the bottle could become substantial. FDA admits
that "[a]dditional bacteria may enter a bottle of water with exposure to air" but argues that
bottled water "is not a good source of nutrients for most microorganisms" so no
precautions such as date of bottling or refrigeration warnings are needed. [197] As
discussed at length in the Technical Report (print report only) on microbial contamination,
however, there are several studies documenting regrowth of Pseudomonas and other
organisms occurring in bottled water after bottling that make it difficult to accept this
unsupportable FDA reassurance. [198]
Similarly, as discussed in Chapter 3 and the Technical Report (print report only), several
plasticizers and other plastic reactants or by-products can migrate from bottles into the
water with time. Some studies indicate a steady increase with time of certain cancer-
causing and other contaminants in bottles as the bottle slowly leaches out the chemical
into the water. Again, if the water is tested only immediately after bottling, such problems
will likely never be detected.
FDA Places a "Low Priority" on Bottled Water:

Resources Are Extremely Limited, Inspections
and Enforcement Are Rare
FDA has repeatedly stated that bottled water is low on its priority list. FDA says that
"bottled water products are a relatively low public health problem," [199] and "[i]n this
program bottled water plants generally are assigned low priority for inspection....When
compared to products such as low acid canned foods...bottled water products must take a
back seat." [200]
Indeed, according to FDA staff estimates, the agency has dedicated just one half of a staff
person (full-time equivalent) to bottled water regulation, and less than one to ensuring
bottled water compliance. [201] Because of this low priority, water bottlers can expect to be
FDA inspected on average every four to five years or less frequently. [202] GAO found that
"FDA inspected about half of 410 domestic bottlers only once in 5-3/4 years." [203] FDA
recently has confirmed that inspections are no more frequent today than they were in
1991, although FDA funds occasional state "contract inspections.". [204]
In 1995, FDA refused an IBWA petition asking for annual FDA inspections of bottlers,
citing low priority and lack of resources. [205] As the GAO has pointed out, however,
inspecting once every five years or less often is far too infrequent to detect certain
possible problems. For example, contamination problems may come and go depending on
conditions in the source water, on pumping patterns, bottling-plant operation and
maintenance practices, etc. Since testing and other records are required to be kept only
for two years, there is no requirement to report test results to FDA, and FDA inspects only
once every four to five years or less often, it is quite possible that many contamination
problems are never detected by FDA.
Moreover, GAO investigators found that when FDA does do inspections, often FDA relies
upon the results of the bottlers' self-testing rather than doing independent testing of its
own. Even when FDA does do independent testing, it often checks for just a handful of
contaminants out of the scores for which FDA rules require monitoring. GAO found that
FDA tested for five or fewer contaminants in 94 percent of the FDA tests they reviewed. [206]
FDA staff recently admitted there likely has been no major change in testing and
inspection practices since the GAO investigation. [207]
Finally, FDA does not inspect foreign bottlers, so the compliance of those bottlers with
FDA testing and good-manufacturing-practice requirements is uncertain. [208]
State Bottled Water Programs Lack Resources
and Regulatory Standards, and in Some Cases
Are Virtually Nonexistent
State programs range from well developed to nonexistent
NRDC conducted a detailed survey sent to all 50 states' bottled water programs,
summarized in Appendix C. As a result, we have learned that while some states, such has
California, Massachusetts, New Jersey, Texas, and Washington have bottled water
programs that are relatively well developed, other states have no or virtually no program.
Most have not adopted the IBWA model code, some have not adopted all of FDA's
standards, and most have few resources dedicated to implementing the program. This
makes FDA's heavy reliance upon state programs subject to question.
States are under no legal obligation to adopt the FDA bottled water standards. In fact, FDA
has no formal system to track the adequacy of state regulations, inspection results,
enforcement, source-water approvals, or other aspects of state bottled water programs. In
response to questions from NRDC, FDA could not answer even the most basic questions,
such as how many states have adopted FDA standards, nor does FDA maintain its own
inventory of all water bottlers. This means that often, if not most of the time, bottled water
regulation falls to the states, some of which, as noted below, are ill equipped to take on
this role.
State resources
The lack of state resources for bottled water is a major problem. Among the 50 states and
the District of Columbia, 13 states told NRDC that they have no resources, staff, or
budgetary allotments specifically earmarked to implement the state bottled water
programs. [209] In addition, 26 states reported having less than one full-time staff equivalent
(FTE) dedicated to running the state's bottled water program. Only seven states reported
having one or more full-time staff people dedicated to implementing and maintaining the
state's bottled water program. [210] This makes FDA's heavy reliance upon state programs
problematic.
As is detailed in Appendix C, state bottled water programs range from being stricter than
FDA's requirements in some areas (e.g., California, Georgia, Montana, New Jersey, New
York, Pennsylvania, Texas and Vermont), to proudly proclaiming that they are less strict
than federal rules. A few examples of states with less developed programs include:
• Alaska, which reports that it does not require bottlers to conduct annual testing for
chemical and radiological contaminants[211] (despite FDA rules requiring such
annual monitoring.
• Arizona, which reported to NRDC that "the State of Arizona does not currently
regulate the bottled water industry." [212] The state says local county health
departments have some authority to do so, and that it relies on FDA to deal with
interstate water.
• Delaware, which conducts no active regulatory oversight of the FDA's

requirements, nor does it have a permit program. Delaware has no separate state
code addressing bottled water and says it has no bottlers in the state.
• Illinois, which has no state certification or permitting process. Moreover, the

source of bottled water is inspected by the state only upon request by the bottler
(i.e, no mandatory testing of source waters). Occasionally, however, health
inspectors may inspect bottlers as part of an inspection of an otherwise-regulated
facility (such as a restaurant or hotel).
• Indiana, which does not have a separate state code regulating bottled water
processing, does not certify sources and does not have a state permit or licensing
program.
• Kansas, which has no separate state regulations and no permit program. In a

recent telephone interview, a Kansas state official reported that "Kansas has no
statutory authority to issue permits, licenses, or certificates for bottled water
processors, plants, or distributors." [213]
• Missouri, which regulates microbiological contaminants in bottled water and

inspects bottled water plants but does not regulate chemical and radiological
contaminants -- despite FDA rules requiring such annual monitoring. [214]
• North Dakota, whose Health Department reported to NRDC that "State regulations
are far less stringent tha[n] those administered by" FDA. The Health Department
also reported that "no enforcement actions" have been taken by the state in the
past four years, that "no documented violations or data [are] available," and that
"very little, if any, bottled water is tested by our agency. I know of no other State
agency that tests bottled water." [215] Additionally, the state does not require bottlers
to submit source analysis prior to initiating bottling operations.
• Texas, whose bottled water program, while stronger overall than that of many
states, has less than one FTE dedicated specifically to the state's bottled water
program. Texas reports that there are currently more than 300 bottlers operating
within its borders. [216]
• Utah, which does not currently approve sources and does not have a permitting
program for water-bottling facilities.
• Virginia, which does not certify sources, nor does it have a permitting program.
Virginia reports that it is not "empowered to permit or license." [217]
Thus, it is apparent that some states have put few if any resources into their bottled water
program. FDA's reliance upon state programs to assure compliance is, in many states,
misplaced.
There are noteworthy exceptions to our general finding that state programs lack the
necessary resources and programs to justify FDA's reliance. Encouragingly, a handful of
states seem to have placed a greater priority on making sure that bottled water is
consistently safe, healthy and free of contaminants for consumers. In addition, some
states, while not necessarily imposing strict and comprehensive bottled water programs
across the board, have adopted small but significant advances that may help to improve
bottled water protection at least somewhat.
States that have adopted at least some progressive regulatory innovations include:
• California, which has adopted stricter regulations for many contaminants than
FDA, including lower allowable THHM levels and tougher disinfection rules, and
has a fairly well developed regulatory program. Moreover, California citizens have
adopted Proposition 65, a law that requires, among other things, that those doing
business in the state must provide a clear and reasonable warning if they or their
products expose people to toxic chemicals. This law applies to bottled water as
well as to other consumer products.
• Florida, which reports that it has two full-time staffers dedicated to its bottled
water program and has its Food Laboratory collect and analyze random samples of
bottled water off retail food shelves. However, the state does not routinely publish
the results of its testing to consumers.
• Louisiana, which samples end product every three months, from both in- and out-
of-state bottlers. As in Florida, however, Louisiana does not publish its test results
to inform consumers.
• Maine, which, in addition to following FDA labeling rules requiring that finished-
product bottled water violating FDA standards must say so on the label, also
requires that contaminants that exceed maximum contaminant levels (MCLs) in the
source water be listed on the label. Although the state does not require that
bottlers list analytical results on the labels (making this optional at the prerogative
of the bottler), it does require that a bottler list on its label any altered water
quality.
• Maryland, which requires that bottlers conduct an EPA primary drinking water
analysis of its source.
• Massachusetts, which publishes an annual public report that summarizes the

bottler-filed bottled water quality testing results. The report can be misleading,
however, because in many cases it does not mention known contamination
incidents.
• Mississippi, which tries to sample each bottled water product sold in the state on a
monthly basis for E. coli. and other bacteria.
• Montana, which requires that all in-state bottlers become Public Water Systems
and meet EPA drinking water standards prior to start-up.
• Nevada, which requires that a bacteriological analysis be submitted every week to

the Department of Human Resources, Health Division, if a plant is in full operation.
• New Jersey, unique in its requirement that a bottler list a two-year expiration date
(from time of bottling) on its label, also mandates by state statute that an annual
enforcement/violation report be compiled and submitted to the state legislature.
New Jersey also conducts a limited number of "spot checks" of bottled water sold
and produced within the state.
• Ohio, which requires that any additives to bottled water be listed on labels.
• Texas, which in addition to having stricter standards and more frequent

inspections than FDA, also requires source labeling and certification of operators
under its unique Bottled Water Certification Program. Under the program, bottlers
are required to attend training/awareness courses sponsored by the state and earn
different "grade" levels (grade A being the most stringent) based upon number of
classes attended and years in operation. Texas also requires that bottlers resubmit
a water-quality analysis annually to an EPA certified lab in order to renew licenses
(unless source is municipal).
• Vermont, which has more stringent testing regulations and labeling requirements
than FDA. Vermont requires that the source, the name and address of the bottler,
and finished-product levels of arsenic, lead, sodium, and nitrates be listed on
bottled water labels.
• West Virginia, which has more stringent reporting requirements than FDA: Bottlers
must test weekly for bacteriological contaminants and submit their reports to the
state agency by the 10th of each month. Additionally, West Virginia requires that
the source be protected from outside contamination at the point of discharge and
the draw area.
• Wisconsin, which requires, by statute, publication of an annual bottled water

quality analysis report. This report evaluates only about a dozen waters sold in the
state, however. There are about 24 bottlers in Wisconsin and many more waters
imported from out of state.
State regulatory programs, such as those just listed, that have attempted to innovate or to
"put some teeth" into both federal and state regulations are to be applauded. Not all state
regulatory agencies are provided the resources or legislative authority to implement all of
the innovations just described, and many agencies are constantly being challenged to
make less do more. Yet, several of the innovations require a relatively low investment of
time and state funds, and could be adopted with minimal additional demands on state
resources.
One good example of a low-cost, high-return regulatory innovation is the requirement

adopted by several states that bottlers submit copies of state and/or federally mandated
water-quality tests to the appropriate state agency on a weekly, monthly, or yearly basis
rather than merely requiring that bottlers keep copies on hand at the plant. Similarly,
additional contaminant disclosure labeling requirements to require public information
about contaminants in the water, have a beneficial effect and carry out the public's right to
know. Such requirements, while not compelled under federal regulations, would go a long
way in flagging potential health risks early on, while at the same time would provide an
obvious incentive for bottlers to remain in compliance with the regulations. Certainly,
some of these or similar types of programs are worth consideration by other states when
the payoffs are less risk to the consumer and more compliance with the law.
No guarantee of compliance with FDA requirements
Even in states that have adopted FDA standards, there is no assurance that the states are
actively enforcing those standards. For example, Alaska has adopted bottled water
standards that generally are equal to EPA drinking water standards, in addition to
codifying IBWA and FDA standards. Curiously, however, the state of Alaska has
unilaterally decided it will not require annual bottlers to conduct chemical and radiological
contaminant testing as required under FDA's regulations. Calling such tests "expensive
and not necessary," [218] Alaska has decided it will not require these tests. While it is
commendable that the state of Alaska generally has adopted strict regulations for its
bottled water, we fail to see the logic (or legality) in openly flaunting a critical portion of
the FDA's bottled water regulatory requirements.
It is unclear how many states have unwritten policies of not enforcing part or all of their
own or FDA's rules. Such disregard for a federal requirement is unsettling and sets a poor
example for other states, which may, in the same spirit as Alaska, simply choose to
disregard other vital parts of the federal requirements. FDA relies upon voluntary
compliance with federal requirements and has dedicated no resources to auditing or
evaluating state-program performance. Unfortunately, in light of the minimal FDA
resources dedicated to the bottled water program, we cannot afford to allow the states to
pick and choose which federal requirements they are willing to comply with.
Nonregulated bottled waters

State adoption of FDA regulations becomes especially important when one considers that
even the FDA regulations for bottled water have huge gaps through which contaminated
waters can easily flow. FDA says its rules do not apply to intrastate bottled waters (water
that is bottled, sold, and distributed entirely within the borders of any one state), nor do
they apply to seltzer water, carbonated water, flavored water, and certain other waters
noted earlier. There are currently no specific standards (i.e., no required contaminant
testing or water-quality standards) that cover the processing, testing, or distribution of
these categories of bottled waters.
While many states have adopted their own standards to cover intrastate bottled waters,
either by separate state code or by voluntarily extending the FDA regulations to intrastate
bottlers, three states (Delaware, Indiana, and Kansas) and the District of Columbia have
not adopted their own regulations to cover such water. Moreover, only 35 percent (18 out
of 51 states and the District of Columbia) regulate seltzer, carbonated, and/or flavored
waters under either the FDA standards or their own state standards. The undeniable
conclusion from these statistics is that, although some states have taken the "extra" steps
to ensure that all bottled water is subject to crucial contaminant testing (even where not
required under federal law), many states have not. There remains an entire category of
bottled water actively being distributed to and consumed by the general public that is not
subject to any required testing at all in most states.
Source listing and labeling requirements

Only 14 states currently require source listing on the labels of bottled water products. [219]
Other states reported having various other labeling requirements in addition to the FDA
requirements, mostly aimed at prevention of misbranding. [220] Interestingly, Maine and
Texas require bottlers to list contaminants if the source or end product exceeds maximum
contaminant levels (MCLs). With the exception of the states just mentioned, no other
states have any requirements for source or contaminant listing on the labels of bottled
water beyond FDA requirements.
Few enforcement actions

FDA generally relies on the states to enforce federal bottled water regulations. Information
gathered by NRDC over the last several years from FDA and state agencies charged with
enforcing the federal regulations, however, indicates that few, if any, serious enforcement
actions have actually been instituted by the states. Of the 50 states and District of
Columbia, only about half[221] report having taken any enforcement action in the past four
years, and most of those were in the form of warning letters from the appropriate state
agency requesting that bottlers come into compliance with regulatory requirements. Only
a handful of states reported having to shut down bottlers or enforce involuntary recalls in
the last four years.
Optimistically, the lack of enforcement actions could mean that all bottled water
processors are virtually always in full compliance with all federal and state testing and
health requirements. Yet experience and common sense, as well as our review of state
records in some states that gave us access under freedom-of-information laws, point
toward a different, less optimistic reality. The scarcity of state resources dedicated to
implementation and enforcement of federal and state bottled water regulatory programs
lends significant support to the suspicion that the lack of serious enforcement actions is
due, in large part, to extreme shortages in state resources for enforcement purposes,
rather than lack of violations.
Violation data "unavailable"
Unfortunately, it is nearly impossible to confirm or deny such suspicions. This is

predominantly because data on the number and scope of bottled water violations are
either not reported or are unavailable to the public in all but 10 of the states. [222] If such
violation data were available, a truer picture of the enforcement-to-violation ratio could be
compiled, by conducting a relatively simple comparison between the number and scope of
enforcement actions in any given state with the number and scope of reported violations.
Without violation data, we are left in somewhat of a void when it comes to rating the
quality of enforcement, having only half of the story on which to base our conclusions.
Computerized databases would greatly facilitate both record keeping and public access to
violation data, and, subsequently, increase accountability of violating bottlers and state
enforcement divisions alike. Some states (such as Georgia, Missouri) are to be applauded
for developing databases or working toward that end. Most states, however, are unable or
unwilling to provide summaries of violations.
State permit programs
It is encouraging that most states report that they have developed and maintain a state
permitting or licensing program for bottled water processors. State licensing programs
can vary widely from state to state but serve an important function in the battle against
compromised bottled water quality. State-issued permits can be a powerful regulatory tool
(oftentimes the only enforcement tool used).
As one state official observed, state licensing programs "provide control and leverage
both administratively and to the regulatory scheme." [223] Nearly all the states require that
bottlers, prior to being issued a license or permit, submit a water quality analysis for both
source and end product that is at least as stringent as the FDA requirements. While most
permits must be renewed annually, some do not need to be renewed or have renewal
periods of three or more years. Notably, California, New Hampshire, New Jersey, New
York, Ohio, Rhode Island, Texas, and West Virginia require that a water-quality analysis be
resubmitted every year as a prerequisite to license renewal. Yet, even though state
licensing is one of the few tools states have at their disposal with proven compliance-
forcing clout, nine states and the District of Columbia have not adopted permitting or
licensing programs for bottled water processors (Delaware, Illinois, Indiana, Kansas,
Michigan, North Carolina, South Dakota, Utah, and Virginia).
State programs may bend to bottlers' political influence

In addition, even a state that has a well developed program apparently may bend to
political pressure from major bottlers. For example, in Massachusetts, Dr. Elizabeth
Bourque, a biochemist who for many years ran the state's bottled water program, made a
name for herself as an aggressive bottled water regulator.
As noted earlier, the Ann & Hope company's well in Millis, which provided water for
several brands of bottled water, became contaminated with industrial chemicals, including
trichloroethylene at a level above EPA and FDA standards. Dr. Bourque insisted that strict
controls be imposed. [224] She also demanded that when a product from major bottlers,
such as Perrier's Poland Spring water, contained high levels of HPC bacteria or chlorine,
that action be taken. [225]
After many such aggressive interventions, Dr. Bourque was asked by her supervisors to
stop working on these important problems and to instead focus on other work. She did not
relent. However, after industry complaints to the Massachusetts Department of Public
Health (MDPH) management, and a December 5, 1996, meeting of Nancy Ridley, MDPH
Assistant Commissioner, attorneys from a blue-chip Washington, D.C., law firm
(representing Perrier), and an official from a bottler that used Ann & Hope water, Dr.
Bourque was reassigned to other duties. [226] She also received a written "gag order" that
prohibited her from speaking about bottled water to the press, water-analysis labs, federal,
state, or local agencies, or bottlers. [227] She and the union that represents state employees
protested, alleging that the reassignment was punitive, but got nowhere. [228] State officials
maintain that the reassignment was not punitive and was unrelated to any discussions
with bottled water companies. Dr. Bourque recently retired.
An investigation by Senator Cheryl Jacques, a state senator who represents Millis,

ensued. Senator Jacques' request for all state records relating to the Ann & Hope affair
was responded to incompletely, with several key documents apparently not provided to
the senator. [229]
It is difficult to know or to document how widespread the bottled water industry's political
arm-twisting may be. Still, it appears clear that even in states with relatively
comprehensive programs for bottled water, there may be serious limitations to state
regulators' ability to vigorously implement the law.
Conclusions about state bottled water programs
A close look at the results of the NRDC surveys of states' bottled water programs makes it
difficult to share FDA's confidence in the states' ability to ensure compliance with federal
requirements, especially when some states lack even rudimentary permit programs. The
reality is that, with few exceptions, state programs lack the necessary resources to
provide adequate oversight and enforcement of the state and federal regulatory scheme.
By and large, most state programs appear to be afterthoughts, tacked onto the backs of
other state regulatory programs, with little, if any, staff and resources dedicated to
ensuring acceptable, healthful bottled water quality. Without the deterrent of consistent,
tough rules and meaningful enforcement, water bottlers have little incentive to comply
with either federal or state requirements.
Our review of bottled water quality in previous chapters suggests that some bottled water
is not of the highest quality. It is likely that a significant amount of bottled water is being
consumed without having been subjected to proper and adequate quality testing, putting
consumers' health at potential risk. This might not be occurring if states in fact had
sufficient resources dedicated to bottled water programs. Moreover, even in states with
resources dedicated to bottled water, such as Massachusetts, it is important that
meaningful outside oversight take place so powerful political interests or bottlers cannot
bend the state agencies to their advantage.
Voluntary Industry Standards, While

Commendable, Are No Substitute for Enforceable
Health Protection Standards
The International Bottled Water Association (IBWA) has long sought to encourage the
industry (particularly the self-proclaimed 85 percent of the industry IBWA claims as its
members) to comply with the IBWA model code, and to accept annual inspections by
IBWA's contractor NSF International.
While these voluntary industry efforts are commendable, they cannot be viewed as an
effective substitute for a strong and enforceable federal regulatory program. IBWA itself
seems to have recognized this fact in that it has often petitioned FDA to adopt the IBWA
Model Code and other important regulations.
The problems with FDA's and the industry's heavy dependence and faith in the
effectiveness of the IBWA voluntary standards are many:
• Voluntary standards apply only to those who agree to them--that is, members of
the industry who choose to be IBWA members. By IBWA's count, about 15 percent
of the industry does not belong to the organization.
• Industry members who choose to leave IBWA to avoid compliance with the IBWA
standards suffer no real consequence.
• Many companies bottle water (such as seltzer, sparkling, or other water) that is not
covered under the narrow definition of "bottled water" adopted by FDA rules and
the IBWA Model Code. Thus, these waters are exempt from the voluntary industry
standards and are not subject to the specific FDA contaminant standards that
apply only to "bottled water" (as that term is narrowly defined).
• While some states (according to IBWA, about 16) have adopted the IBWA
standards as binding and enforceable, most states have not done so.
• The inspection results after NSF inspections are not shared with regulators or the
public, so it is impossible to determine how effective these inspections and IBWA
standards truly are.
Thus, while the voluntary industry efforts are helpful, they cannot be a substitute for
regulatory controls.
Chapter Notes
4a. Some observers have noted that all of the bottled water sold in the United States today is part of a stream of
interstate commerce that begins with the extraction of the raw material for the bottles, often out of state, continues with
the manufacture of the bottles, labels, caps, and shipping materials, moves on to the bottling facilities and the water
extraction itself, the shipping of the water, and ultimately the sale of the water. Each of these steps in producing,
packaging, and shipping water generally involves interstate commerce, and individuals who buy water bottled and sold
in one state may be from out of state. In addition, any problem with the water (such as illnesses) clearly could directly
affect interstate commerce. Interestingly, the IBWA has implicitly argued that FDA's jurisdiction extends to intrastate
sales of bottled water. At a congressional hearing at which the inapplicability of FDA rules to intrastate sales was noted,
IBWA's then-CEO said:
a statement was made this morning which might be confusing, and that is that most bottled water is not in interstate
commerce. To the contrary, most bottled water is, because most of the products that are used in the bottled water
plants, the bottles, the resin, the coolers, the caps, and labels all come from somewhere else, so in the strictest
interpretation, interstate commerce is involved in just about all of our products.
Statement of William Deal, CEO, IBWA, in "Bottled Water Regulation," Hearing of the Subcommittee on Oversight and
Investigations of the House Committee on Energy and Commerce, Serial No. 102-36, 102nd Cong., 1st Sess., p. 107 (April
10, 1991). Therefore, to the extent FDA has interpreted its jurisdiction over bottled water to include only water that
crosses state boundaries, some have argued that FDA's interpretation is unduly narrow.
4b. Acrylamide and epichlorhydrin are chemicals sometimes used in drinking water treatment. EPA requires that any
public water system using these chemicals must meet a "treatment technique" intended to ensure safe use of these
chemicals. FDA has adopted no such requirement.
4c. 40 C.F.R. § 141.30. These tap water monitoring requirements (except for THMs) can sometimes be reduced in
frequency for some small systems, or others that the state finds have been demonstrated not to be vulnerable, and that
did not detect the contaminant in initial rounds of monitoring. See 40 C.F.R. §§ 141.24 & 141.61(a); see also Safe Drinking
Water Act § 1418 (granting monitoring relief in certain cases to small public water systems).
4d. Both EPA and FDA require annual or less frequent testing for most inorganic contaminants. see FDA rules at 21
C.F.R. § 165.110, and EPA rules at 40 C.F.R. § 141.23(c). Additionally, Congress mandated in 1996 that unless FDA issued
standards for nine contaminants (antimony, beryllium, cyanide, dioxin, diquat, endothall, glyphosate, nickel, and
thallium) by August 6, 1998, EPA's tap water standards for these chemicals (including testing requirements) would
automatically apply to bottled water. In May 1998, FDA issued a direct final rule stating it would apply EPA tap water
standards for these contaminants in response to this mandate. 63 Fed. Reg. 25764 (May 11, 1998). That rule said,
however, that rather than tracking EPA's tap water testing regime, FDA would set the monitoring frequency at once per
year (instead of following EPA's rules requiring quarterly testing for some organics, and annual or sometimes less
frequent testing for inorganics). Because water bottlers objected to some of these monitoring requirements as
burdensome, FDA stepped back, saying it could not finalize the monitoring provisions in light of "significant adverse
comments," and instead allowed the law to automatically impose the monitoring by the EPA tap water rules. The EPA
(and now FDA) testing rules also allow waivers -- a provision FDA has not yet explained whether it will use. Thus, how
FDA intends to implement the monitoring requirements for these contaminants is murky. See 63 Fed. Reg. at 42198-99
(August 6, 1998).
Report Notes
103. Statement of William Deal, CEO, IBWA, in "Bottled Water Regulation," Hearing of the Subcommittee on Oversight
and Investigations of the House Committee on Energy and Commerce, Serial No. 102-36, 102nd Cong., 1st Sess., p. 108
(April 10, 1991).
104. Ibid. p. 112.
105. IBWA, "Frequently Asked Questions About Bottled Water," (available at www.bottledwater.org/faq.html), (printed
11/20/1998).
106. Ibid. (emphasis added)..
107. FFDCA § 410, 21 U.S.C. § 349 (1995); later amended by § 305 of the SDWA Amendments of 1996, Pub. L. 104-182
(August 6, 1996).
108. Ibid.
109. Senate Environment & Public Works Committee, Safe Drinking Water Act Amendments of 1995: Report of the
Committee on Environment and Public Works, United States Senate, on S. 1316, Report No. 104-169, 104th Cong., 1st
Sess., p. 96 (November 7, 1995).
110. "Bottled Water Regulation," Hearing of the Subcommittee on Oversight and Investigations of the House Committee
on Energy and Commerce, Serial No. 102-36, 102nd Cong., 1st Sess. (April 10, 1991); General Accounting Office, Food
Safety and Quality: Stronger FDA Standards and Oversight Needed for Bottled Water, GAO/RCED-91-67, pp. 16-17 (March
1991).
111. FFDCA § 410, 21 U.S.C. § 349 (1997).
112. Ibid.
113. The FDA bottled water rules are codified at 21 C.F.R. parts 129 and 165 (1997).
114. Personal Communication with Terry Troxel and Shellee Davis, FDA, September 18, 1997.
115. Personal Communication with Ron Roy, FDA, compliance programs, November 20, 1998.
116. See, e.g., NRDC, Think Before You Drink (1993); NRDC, Victorian Water Treatment Enters the 21st Century (1994);
NRDC, The Dirty Little Secret About Our Drinking Water (1995); NRDC, You Are What You Drink (1995), NRDC, USPIRG,
and Clean Water Action, Trouble on Tap (1995) .
117. Statement of Frank Shank, Director, FDA Center for Food Safety and Applied Nutrition, reprinted in, "Bottled Water
Commerce, Serial No. 102-36, 102nd Cong., 1st Sess. 65, p. 75 (April 10, 1991).
118. FDA, "Beverages; Bottled Water: Final Rule," 60 Fed. Reg. 57,076, at 57120 (November 13, 1995).
119. Ibid., p. 57, 120 (citing FFDCA §§ 301 & 304, 21 U.S.C. §§ 331 & 334).
120. General Accounting Office, Food Safety and Quality: Stronger FDA Standards and Oversight Needed for Bottled
Water, GAO/RCED-91-67, pp. 16-17 (March 1991).
121. FDA Regulations, 21 C.F.R. § 165.110(a).
123. See California Health and Safety Code § 111070(a); see also Appendix C (summarizing state programs and noting
whether they regulate seltzer, etc. as bottled water).
124. Anon., "1996 Alternative Beverages: Still Water Supply Up Sharply, Perrier, Coke, Pepsi, and Suntory Gain Share,
Beverage Digest (April 25, 1997), (www.beverage-digest.com/970425.html), (printed 9/25/1997). (In 1996, there reportedly
were 731 million cases of still waters-- some of which may have been exempt also because they were labeled "filtered
water," etc., -- and 152.2 million cases of sparkling water.)
126. FFDCA § 410, 21 U.S.C. § 349 (1997).
127. Interview with Terry Troxel, FDA, September 18, 1997.
128. 40 C.F.R. § 141.63.
129. See, 21 C.F.R. § 165.110(b)(2).
130. 21 C.F.R. § 165.110(b)(2).
131. 58 Fed. Reg. 52042, at 52045 (October 6, 1993).
132. Personal Communication with Henry Kim, FDA, September 18, 1997.
133. 40 C.F.R. §§ 141.72(a)(4) & (b)(3).
134. 58 Fed. Reg. 52042, at 52047 (October 6, 1993), (emphasis added).
135. 40 C.F.R. § 141.21. However, under EPA's rules, however, smaller tap water systems can test less frequently--so
systems serving under 4,100 people can test once a week or less often for total coliform bacteria. Ibid.
136. 21 C.F.R. § 129.80(g)(1).
137. FFDCA § 410, 21 U.S.C. § 349 (1997).
138. 40 C.F.R. § 141.72.
139. 21 C.F.R. § 165.110.
140. 21 C.F.R. § 165.110(b)(3)(i); under a negotiated rule to be issued in late 1998, the turbidity standard will drop to a
maximum of 1 NTU, with a 95 percentile level of 0.3 NTU. 63 FED. REG. 69477 (December 16, 1998).
141. 40 C.F.R. § 141.73.
142. Studies show a clear link between drinking water turbidity and illnesses. See, R.D. Morris, E. N. Naumova,. and J.K.
Griffiths, "Did Milwaukee Experience Waterborne Cryptosporidiosis Before the Large Documented Outbreak in 1993?"
Epidemiology vol. 9, no. 3 , pp. 264-270 (May 1998). For example, in the Milwaukee Cryptosporidium outbreak turbidity
increases were the only indicator of a water quality problem. Even with turbidity monitoring in Milwaukee, illnesses
already had started by the time a spike in turbidity was noticed and action taken. See, e.g. , W. R. MacKenzie, et al., "A
Massive Outbreak in Milwaukee of Cryptosporidium Infection Transmitted Through the Public Water Supply," New Engl.
J. of Med. vol. 331, no. 3, pp. 161-167 (July 21, 1994). It should be noted, however, that in at least in one Crypto outbreak
in Las Vegas, it was found that people who drank only bottled water had a far lower risk of getting the disease than did
tap water drinkers). S.T. Goldstein, D.D. Juranek, O. Ravenholt, A.W. Hightower, D.G. Martin, J.L. Mesnik, S.D. Griffiths,
A.J. Bryant, R.R. Reich, B.L. Herwaldt, S. Goldstein, "Cryptosporidiosis: An Outbreak Associated With Drinking Water
Despite State-of-the-Art Water Treatment," Ann Intern Med. vol. 124, no. 5, pp. 459-468 (March 1, 1996); S. Goldstein,
National Center for Infectious Disease, Centers for Disease Control, "An Outbreak of Cryptosporidiosis in Clark County,
Nevada: Summary of Investigation," CDC (1995).
143. See, e.g. , W.R. MacKenzie,, et al., "A Massive Outbreak in Milwaukee of Cryptosporidium Infection Transmitted
Through the Public Water Supply," New Engl. J. of Med. vol. 331, no. 3, pp. 161-167 (July 21, 1994); Maryiln Marchione,
"Silent Disaster: Crypto Has Killed 104-And Counting," Milwaukee Journal, p. 1 (March 27, 1994).
145. The CDHS review noted that the bottled water industry in California is "aware of the significance of
cryptosporidiosis and passed a resolution...which would recommend their members to filter water through 1 um
absolute filters." California Department of Health Service, Food and Drug Branch, "Bottled Water--Cryptosporidium,"
(2/14/95). This is similar to national "recommendations" from the International Bottled Water Association to their
members that they are "encouraged" to use effective Cryptosporidium treatment, also not binding. International Bottled
Water Association, "Frequently Asked Questions About Bottled Water," (available at www.bottledwater.org/faq.html),
(printed 11/20/1998).
146. Sylvia Swanson, "IBWA in the Forefront," Bottled Water Reporter 30, p. 37 (December/January 1996).
147. Information Collection Rule, 61 Fed. Reg. 24354 (May 14, 1996); see also, 40 C.F.R. §§ 141.70-141.75.
148. 21 C.F.R. § 165.110.
149. Compare, 40 C.F.R. part 141 with 21 C.F.R. § 165.110(b)(4).
150. Ibid. FDA announced in a 1996 rule that it was "deferring final action" on its proposed DEHP maximum contaminant
level for bottled water after industry commenters objected to the standard. 61 Fed. Reg. 13258 (March 26, 1996).
151. 61 Fed. Reg. 13258, at 13260 (March 26, 1996).
152. Ibid.; Comments of Grace Container Products, dated May 11, 1995, FDA Docket 93N-0085, Document C11.
153. Comments of Grace Container Products, dated May 11, 1995, FDA Docket 93N-0085, Document C11.
154. See, Tyrone Wilson, IBWA Technical Director, Comments on August 4, 1993 FDA Proposed Rule for Bottled Water
Quality Standards at 8 (dated October 4, 1993), FDA Docket 93N-0085.
155. 61 Fed. Reg. 13258, at 13260 (March 26, 1996).
156. FFDCA § 410, as amended by the Safe Drinking Water Act of 1996, codified at 21 U.S.C. § 349.
157. Codified at 21 C.F.R. § 165.110(b)(4)(iii)(A) & (b)(4)(iii)(C).
158. FFDCA § 410, as amended by the Safe Drinking Water Act of 1996, codified at 21 U.S.C. § 349.
159. FDA, "Beverages: Bottled Water: Direct Final Rule," 63 Fed. Reg. 25764-25769 (May 11, 1998).
160. FDA, Direct Final Rule; Confirmation. Beverages: Bottled Water, 63 Fed. Reg. 42198 (August 6, 1998).
161. Ibid.
162. 40 C.F.R. §§ 141.24 & 141.61(a).
163. 40 C.F.R. § 141.40.
164. 40 C.F.R. § 141.28.

Water, GAO/RCED-91-67, p. 8 (March 1991).
166. 58 Fed. Reg. 393, p. 403 (January 5, 1993).
167. 60 Fed. Reg. 57076, p. 57116 (November 13, 1995).
168. 21 U.S.C. § § 331-337; 371.
169. 21 U.S.C. § 349.
170. SDWA § 1419, 42 U.S.C. § 300g-8.
171. 58 Fed. Reg. 393, at 403 (January 5, 1993).
172. 60 Fed. Reg. 57076, at 57116 (November 13, 1995).
173. 21 C.F.R. §§ 129.3(a) & 129.35(a)(3).
174. 21 C.F.R. §§ 129.3(a).
176. S. Marquardt, V. Smith, J. Bell, and J. Dinne, Environmental Policy Institute, Bottled Water: Sparkling Hype at a
Premium Price, p. 3 (1989).
177. Memorandum to Members, Subcommittee on Oversight and Investigations, from John Dingell, Chairman, in "Bottled
Water Regulation," Hearing of the Subcommittee on Oversight and Investigations of the House Committee on Energy
and Commerce, Serial No. 102-36, 102nd Cong., 1st Sess. 5, p. 9 (April 10, 1991).
178. SDWA § 1453, 42 U.S.C. § 300j-13.
179. Ibid.
180. Massachusetts Department of Public Health, Ann & Hope Water Incident Files, 1993-1997; Memorandum from Dr.
Elizabeth Bourque, MDPH, to Paul Tierney, MDPH, December 13, 1996, (MDPH Memoranda Provided to NRDC Pursuant to
Freedom of Information Request), Personal Communication with Dr. Bourque, MDPH, August 1997; Letter from Shellee
Davis, FDA, to Dr. Elizabeth Bourque, MDPH, June 6, 1996.
181. 21 C.F.R. § 165.110(c).
182. New Jersey Department of Health & Senior Services, Report to the New Jersey Legislature, Summarizing Laboratory
Test Results on the Quality of Bottled Drinking Water for the Period January 1, 1995 through December 31, 1996, p. 17
(July 1997).
183. 61 Fed. Reg. 13258, at 13259-60 (March 26, 1996).
184. Ibid.; see also, 21 C.F.R. § 165.110(d).
185. 40 C.F.R. §§ 141.31 & 142.15.
186. Ibid.
187. Ibid. § 142.15.
188. 40 C.F.R. § 141.33.
189. 60 Fed. Reg. 57076, 57118 (November 13, 1995).

190. 60 Fed. Reg. 57076, 57118 (November 13, 1995).
191. 21 C.F.R. § 129.80(h).
192. 40 C.F.R. § 141.33.
195. 21 C.F.R. § 129.80(g).
197. Ibid. at 57108.
198. L. Moreira, P. Agostinho, P.V. Morais, and M.S. da Costa, "Survival of Allochthonous Bacteria in Still Mineral Water
Bottled in Polyvinyl Chloride (PVC) and Glass," J. Applied Bacteriology, vol. 77, pp. 334-339 (1994); P.V. Morais, and M.S.
Da Costa, "Alterations in the Major Heterotrophic Bacterial Populations Isolated from a Still Bottled Mineral Water," J.
Applied Bacteriol., vol. 69, pp. 750-757 (1990); P.R. Hunter, "The Microbiology of Bottled Natural Mineral Waters," J.
Applied Bacteriol., vol. 74, pp. 345-52 (1993); F.A. Rosenberg, "The Bacterial Flora of Bottled Waters and Potential
72-81 (December, 1990); .D.W. Warburton, B. Bowen, and A. Konkle, "The Survival and Recovery of Pseudomonas
aeruginosa and its effect on Salmonellae in Water: Methodology to Test Bottled Water in Canada," Can. J. Microbiol., vol.
40, pp. 987-992 (1994); D.W. Warburton, J.K. McCormick, and B. Bowen, "The Survival and Recovery of Aeromonas
hydrophila in Water: Development of a Methodology for Testing Bottled Water in Canada," Can. J. Microbiol. , vol. 40, pp.
145-48 (1994); D.W. Warburton, "A Review of the Microbiological Quality of Bottled Water Sold in Canada, Part 2: The
Need for More Stringent Standards and Regulations," Canadian J. of Microbiology, vol. 39, p. 162 (1993); A. Ferreira, P.V.
Morais, and M.S. Da Costa, "Alterations in Total Bacteria, Iodonitrophenyltetrazolium (INT)-Positive Bacteria, and
Heterotrophic Plate Counts of Bottled Mineral Water," Canadian J. of Microbiology, vol. 40, pp. 72-77 (1994).
200. Statement of Frank Shank, Director, FDA Center for Food Safety and Applied Nutrition, reprinted in "Bottled Water
Commerce, Serial No. 102-36, 102nd Cong., 1st Sess. 65, p. 76 (April 10, 1991).
201. Personal Communication with Terry Troxel and Shellee Davis, FDA, September 18, 1997; Personal Communication
with Ron Roy, FDA, compliance programs, November 20, 1998.
202. Ibid.; 60 Fed. Reg. 57076, p. 57117 (November 13, 1995).
208. Ibid; General Accounting Office, Food Safety and Quality: Stronger FDA Standards and Oversight Needed for
Bottled Water, GAO/RCED-91-67, at p. 7 (March 1991).
209. Alaska; Arkansas; Delaware; District of Columbia; Georgia; Idaho; Illinois; Iowa; Kentucky; Maryland; Minnesota;
Nebraska; and Pennsylvania. Four states --Michigan, New Mexico, North Carolina, and Tennessee-- either did not
respond to this query or chose not to comment.
210. California (2 FTE, 9 investigators state-wide); Florida (2 FTE); New Jersey (1 FTE); New York (1 - 1 ½ FTE); Ohio
(Approximately 1 FTE); Oklahoma (1 FTE); and Virginia (1-2 FTE).
211. Personal communication with Nancy Napolli, Program Manager, Environmental Sanitation and Food Safety, State of
Alaska, April 7, 1998.
212. Letter from Brock Marlin, Program Manager, Arizona Department of Health Services, to NRDC, November 27, 1995.
213. Personal communication with Mr. James Pyles, Consumer Product Safety Officer, Kansas Department of Health and
Environment, April 21, 1998.
214. General Accounting Office, Food Safety And Quality: Stronger FDA Standards And Oversight Needed For Bottled
Water, GAO/RCED-91-67, at p. 17 (March 1991).
215. Letter from Kenan L. Bullinger, Director, North Dakota Department of Health Services, to NRDC, November 13,1995.
216. Personal communication with Joe Dixon, Evaluations Auditor, Manufactured Foods, Texas Department of Health,
June 12, 1998.
217. Personal communication with Bryan Davis, Program Supervisor, Virginia Department of Agriculture, Consumer
Services, June 3, 1998.
218. Personal correspondence with Ms. Nancy Napolilli, Program Manger, Environmental Sanitation and Food Safety,
Department of Environmental Conservation, State of Alaska, April 7, 1998; accord, Ms. Nancy Napolilli, Comments of the
Alaska Department of Environmental Conservation, Division of Environmental Health, Environmental Sanitation and
Food Safety, on FDA Feasibility Study of Appropriate Methods of Informing Consumers of the Contents of Bottled Water
(dated December 12, 1997), (FDA Docket 97N-0436).
219. California (including whether municipal), Maryland, Massachusetts, Michigan, Nevada, New Hampshire, New Jersey,
New York, Ohio (unless municipal), Pennsylvania (must also list name of public water system), Rhode Island (but only
municipal waters without deionization process must list source), Texas, Vermont, and Wyoming (municipal water must
be listed as "drinking water") reported requiring source listing on bottled water labels.
220. Connecticut ("separate state regulations" for labeling); Hawaii (prohibition against misbranding); Idaho (intrastate
labeling law prohibits misbranding); Maine (if source or end-product exceed MCLs, must be listed on label; must also list
if "altered water quality"); Michigan (declaration of identity & carbon dioxide content); Minnesota (state rules); Montana
(if labeled "organic" must be verified by third party "Organic Certification" group); Nevada (if making any claims such as
low sodium or fluoride content, must list levels found in product); New Hampshire (no misleading brand names); New
Jersey (two year expiration date); New York (nutritional claims must be consistent with FDA regulations; variances must
be listed on label); Ohio (any additives must be listed); Oklahoma (separate state regulations); Texas (chemicals or
bacteria that exceed MCLs must be listed and must state on label "contains excessive bacteria"); and Vermont (must list
finished end-product levels of arsenic, lead, sodium, and nitrates).
221. California, Colorado, Georgia, Illinois, Iowa, Kentucky, Louisiana, Maryland, Massachusetts, Montana, Nevada, New
Hampshire, New Jersey, New Mexico, New York, North Carolina, Ohio, Oregon, Pennsylvania, Rhode Island, South
Carolina, Texas, Utah, Vermont, Virginia, Washington, and West Virginia.
222. Hawaii (available through FOIA request); Maine (listed in database; would require approximately ½ hour to gather);
Nebraska (but data available would have more to do with sanitation violations than analytical results); New Jersey
(annual summary of test results and enforcement & violation data mandated by state statute); Oklahoma (inspection
reports); Oregon (summary report of violations for period 1/1/94 - 12/31/97); South Dakota (computerized database of
violations); Vermont (computerized data base of violations); Virginia (information kept in database; will provide for fee);
and Wyoming (violation data stored in computer database).
223. Elizabeth Watkins, Food Processing Coordinator, Illinois Department of Health. Telephone interview with NRDC,
April 27, 1998.
224. Massachusetts Department of Public Health , Ann & Hope Water Incident Files, 1993-1997; see, e.g. Bourque
Memoranda of 10/31/1996; 12/13/1996; 12/26/1996; 1/28/1997; Bourque Letters of 7/11/1996; 7/19/1996; 7/22/1996;
8/7/1996; 9/16/1996; 9/20/1996; 10/16/1996; 10/21/1996; MDPH Memo of 12/9/1996; D. Talbot, "Bottled Water Flows from a
Troubled Well," The Boston Herald, p. 1 (December 16, 1996).
225. Mass. DPH, Poland Spring HPC file, and Poland Spring excess Chlorine Contamination File; see also Chemical
Contamination and Microbial Contamination chapters.
226. Massachesetts Department of Public Health, Ann & Hope Water Incident Files, 1993-1997; see, e.g. Ridley desk
calendar and agenda for 12/5/1996; Memo of 12/4/1996; Massachusetts Organization of State Engineers and Scientists
12/23/1996 and 3/4/1997 Letters to Milligan and Ridley, respectively; Memo from Richard Waskiewicz. MDPH, 12/9/1996;
Bourque Memoranda of 10/31/1996; 12/13/1996; 12/26/1996; 1/28/1997; Bourque Letters of 7/11/1996; 7/19/1996; 7/22/1996;
8/7/96; 9/16/1996; 9/20/1996; 10/16/1996; 10/21/1996; MDPH Memo of 12/9/1996; D. Talbot, "Bottled Water Flows from a
Troubled Well," The Boston Herald p. 1 (December 16, 1996).
227. Waskiewicz Memo to Bourque, 12/9/96.
228. Massachusetts Organization of State Engineers and Scientists Letter to Mulligan, 12/23/96; MOSES Letter to Ridley
3/4/97; personal communication with Dr. Bourque, August 1997.
229. Compare Letter from Mulligan to Sen. Jacques, January 3, 1997 and attached list of documents, with, MDPH Ann &
Hope files.
Chapter 5
MISLEADING BOTTLED WATER LABELING AND

MARKETING
In 1995, FDA issued "standards of identity" -- essentially labeling rules, in response to a
petition from the International Bottled Water Association (IBWA). [230] These rules were
widely acclaimed as a breakthrough that would prohibit misleading claims by
unscrupulous water bottlers. While the rules do prohibit some of the most egregiously
deceptive labeling practices by bottlers, they have by no means eliminated the problem.
Some Bottled Water Labels Remain Misleading to

Consumers
The Institute of Medicine, an arm of the National Academy of Sciences, found in a 1992
study that deceptive bottled water labeling was a widespread practice, with state
authorities exasperated about FDA inaction in the face of frequent statements and
vignettes indicating or implying that the bottled water was far purer than tap water or came
from specific sources or had purity levels that may not have been justified. [231]
Many of these practices continue. For example, FDA rules allow bottlers to call their
product "spring water" -- which seems to carry cachet with consumers as being especially
natural and pure -- even though it may be brought to the surface using a pumped well, and
even though it may be treated with chemicals. FDA merely requires that the geologic
formation that is tapped by the well must come to the surface somewhere, sometimes, to
allow the water pumped to the surface in a well to be called spring water. [232] Among the
more interesting labels we have run across:
• "Spring water" (with mountains and a lake on the label) actually from an industrial
parking lot next to a hazardous waste site, ruled not misleading. A well located in
the middle of an industrial warehouse facility and next to a state-designated
industrial waste site in Millis, Massachusetts, produced this water, contaminated
with industrial solvents including trichloroethylene at levels above EPA and FDA
standards. The label gracing at least one of the many brands that used this water
depicted a beautiful mountain in a reflection off a lake and was called "spring
water." In response to a request from the state of Massachusetts, FDA opined that
this label was acceptable so long as the water does come to the surface
sometimes (it sometimes does in an unpaved area near the parking lot), and as
long as "there is no claim to the effect that the location pictured in the vignette is
the actual spring, we would not consider the label vignette to be in violation of our
requirements." [233] Apparently, after public disclosure of the true source of the
water and contamination problems, this well is no longer being used for bottled
water.
• "Alasika™ - Alaska Premium Glacier Drinking Water: Pure Glacier Water From The
Last Unpolluted Frontier, Bacteria Free" apparently from a public water supply.
This water actually came from "Public Water System #111241" (a public water
system in Juneau, Alaska), according to documents in Washington State files. The
bottler evidently was told that when it reordered its labels, it had to state that the
water is "from a municipal source" or "from a community water system," in
keeping with FDA rules; the phrase "pure glacier water" was, per documents in
state files, "considered false and misleading." The bottler was required to drop the
"bacteria free" claim, as this was "considered synonymous with sterile and false."
This water no longer claims to be "glacier water" or "bacteria free." However,
NRDC has found several other brands sold as "glacier" water even though they
apparently come from groundwater nowhere near any current glacier.[234]
• Vals Water "Known to Generations in France for its Purity and Agreeable
Contribution to Health...Reputed to Help Restore Energy, Vitality, and Combat
Fatigue." While the IBWA voluntary code prohibits health claims, some bottlers
still make such claims.
In addition to these instances of bottled water labels, far more common -- in fact
exceptionally widespread -- is the use of descriptive terminology that suggests bottled
water is extraordinarily pure and uncontaminated. As an example, our review of the labels
and Web site vignettes and advertising of about 50 IBWA members found the following
terms used:
• "Pure" -- eight bottlers.

• "Purest" or "Purity" -- three bottlers.
• "Pristine" -- five bottlers.
• "Glacial" -- two bottlers.
• "Natural" or "Prepared by Nature" -- eight bottlers.
• "Naturally Purified" or "Naturally Occurring" -- three bottlers.
• "Premium" -- five bottlers.
• "Mountain Water" -- seven bottlers.
• "Clean" -- two bottlers.
• "Good Health" or "Healthy" -- two bottlers
• "For Health Conscious" -- two bottlers
Thus, representations about bottled water purity, premium and natural sources, and
healthfulness remain extremely widespread. The FDA rules seem to have little effect on
bottlers' claims of water purity and cleanliness.
Bottled Water Marketing is Often False or

Misleading
Bottled water marketing seeks to emphasize the supposed purity of bottled water, in many
cases contrasting "pure" and "protected" bottled water with "inconsistent" or
unpredictable tap water quality. In the words of a leading industry consultant, "Water
bottlers are selling a market perception that water is 'pure and good for you'...." [235]
This effort to create a "market perception" of purity is an advertising mandate for the
industry, notwithstanding the fact that just because water comes from a bottle does not
mean that it is any purer than tap water, as we have seen in previous chapters. Among the
common industry claims about bottled water that are of questionable veracity or that are
clearly incorrect are:
• Bottled water contains "no" chlorine or harmful chemicals. This claim is boldly
featured on IBWA fact sheets and its Web site. [236] It clearly is false, as previous
chapters have shown.
• Bottled water is always high quality, whereas tap water is of inconsistent quality.
IBWA often points out that "unfortunately, tap water can be inconsistent --
sometimes it might be okay and other times it is not." On the other hand, IBWA
says, "quality is in every container of bottled water. It's consistent and it is
inspected and monitored by governmental and private laboratories." [237] What
IBWA neglects to point out, however, is that in many cases bottled water does
contain contaminants, that most tap water is required to be monitored more often
than bottled water (and testing must be done by government-certified labs, which
is not the case for bottled water), and that about one fourth or more of the bottled
water sold in the United States is derived from the same tap water IBWA says is of
inconsistent quality.
• No waterborne illness has been traced to bottled water. IBWA claims that
"According to the Centers for Disease Control and Prevention (CDC), bottled water
has never been responsible for an outbreak of waterborne illness." [238] In fact, as
discussed in the Technical Report (print report only) and Appendix B, there have
been waterborne-disease outbreaks traced to bottled water. For example, a bottled
water-related cholera outbreak in U.S. territory in the Pacific was written up in 1996
in CDC's flagship journal, Morbidity and Mortality Weekly Report, and other
outbreaks traced to bottled water in Portugal and elsewhere have been
documented. [239]
• Cryptosporidium cannot get into bottled water. The IBWA's fact sheets and Web
site make the repeated claim that FDA rules "ensure that surface water
contaminants such as Cryptosporidium and Giardia are not present" in bottled
water derived from groundwater, and that all IBWA members using municipal water
"reprocess this water [and] employ methods such as reverse osmosis,
deionization, distillation, and filtration," implying this eliminates any risk. IBWA
also implies that bottled water is safe for the immunocompromised. [240] There is no
evidence that bottled water is truly immune from Cryptosporidium or Giardia
unless it is fully protected and treated with EPA-CDC recognized best available
technologies, and much bottled water does not receive this treatment. Indeed,
internal industry communications highlight that IBWA is well aware that some
bottlers do not use these treatment technologies. [241]
• Imported bottled water must meet all U.S. rules. IBWA states that "any bottled
water sold in the United States must meet all of the same regulations as
domestically produced water." [242] But what is not mentioned is that FDA's Good
Manufacturing Practices, source approval, and source-water-testing requirements
apply at the source or bottling facility and are impossible for FDA to enforce when
such facilities are outside of the United States. FDA does not conduct any foreign
inspections of bottlers, so the degree to which foreign bottlers comply with these
FDA rules is not known. What is clear, however, is that these FDA rules do not
apply equally to foreign bottlers.
Although these claims may not be the most exaggerated of those made by the industry,
they are troubling in that all of them are made by the leading industry trade association.
Also of concern is a major IBWA public relations campaign intended to persuade the
public to drink more bottled water. The campaign, funded by IBWA members, is aimed to
be "a comprehensive campaign to educate third-party groups and the media about the
safety and quality of bottled water." The campaign includes slick advertising and fact
sheets. Also central are briefings of the media, nonprofit health organizations, and groups
representing the immunocompromised and retired persons. The campaign has also taken
other steps, such as the sponsorship of an American Dietetic Association meeting.
Mailings have been made to thousands of advocacy groups, members of the media,
environmental and health groups. Several news stories have been placed, and expanded
briefings in more cities were planned.
Thus, in a well-orchestrated effort, the bottled water industry has made major inroads into
the public psyche, reinforcing perceptions about the purity of bottled water. While this
clearly is within the industry's rights, it is important that bottlers not overstate their case
or mislead the public into believing that bottled water is safer or better protected than is
the case.
Report Notes
230. Codified at 21 C.F.R. Part 165.
231. IOM, Committee on State Food Labeling, Food and Nutrition Board, National Academy of Sciences, Food Labeling:
Toward National Uniformity (1992); 58 Fed. Reg. 389, p. 406 (January 5, 1993).
232. 21 C.F.R. § 165.110(a)(vi).
233. Letter from Shellee Davis, FDA, to Dr. Liz Bourque, MDPH, June 6, 1996.
234. Washington State Department of Agriculture Food Establishment Inspection Report April 17, 1997, and attachments;
WSDA Food Establishment Inspection Report October 4, 1996, and attachments; WSDA Food Processor Licensing
Worksheet and Attachments, and WSDA Food Establishment Inspection Report and Attachments, March 20, 1996.
Personal communication with Shelly Haywood, USDA, Jan. 1999. For other waters claiming to be "glacier" water, see
e.g., "Bottled Water/Carbonated Beverage Files: Current Permitholders," MDPH (January 1999).
235. H.R. Hidell, "Water: The Search for a Global Balance," Bottled Water Reporter, p. 53 (June/July 1995), (emphasis
added).
236. See, e.g., IBWA's Bottled Water FAQs, "www.bottledwater.org/faq."
237. Ibid.
238. Ibid.
239. CDC, "Surveillance for Waterborne-Disease Outbreaks--United States, 1993-1994, Morbidity and Mortality Weekly
Report vol. 45, no. SS-1 (April 12, 1996). See also Appendix B regarding waterborne disease outbreaks.
240. Ibid., and "www.bottledwater.org/facts/immuno.html."
241. As noted in a previous chapter, for example, an article in the IBWA's in-house organ that urged bottlers to upgrade
their treatment to be sure it meets CDC guidelines for removing Crypto, pointed out: "How can we expect health groups
to endorse our product if we don't ALL meet the [CDC Crypto removal] guidelines!" Sylvia Swanson, "IBWA in the
Forefront," Bottled Water Reporter, p. 37 (December/January 1996).
242. See, e.g., IBWA's Bottled Water FAQs, "www.bottledwater.org/faq."
Chapter 6
ENSURING CONSUMERS' RIGHT TO KNOW

ABOUT BOTTLED WATER
Under the 1996 SDWA amendments, tap water suppliers are required to issue annual
reports to all of their consumers, which many call "right-to-know reports." These reports
inform consumers of all contaminants found in their tap water and the standards and
health goals for those contaminants, information on the system's compliance with EPA
rules, and details on their water source. [243]
After a pitched battle in which consumer and environmental groups fought to get a similar
requirement adopted for bottled water, water bottlers were successful at killing a measure
that would have required such right-to-know information from bottlers to be provided to
consumers.
Right-to-Know Information for Tap Water, and

Industry's Opposition to It for Bottled Water
The bottled water industry's opposition to a right-to-know requirement applying to bottled
water is particularly disturbing in light of the industry's frequent citation of tap water
quality problems as a rationale for switching to bottled water. It also is galling because of
the industry's open admission that it has substantially benefited from labelling
requirements for beverages such as diet soda, which have caused concern among many
consumers about the ingredients in these drinks. The IBWA's primary spokeswoman
recently noted, for example, that the recent burst in industry sales is linked in part to soda
labels, which revealed to consumers just what they were drinking. "The more people
realize what's in some of these drinks, the more they turn to water for what it doesn't
have...." [244]
An internal communication from the IBWA executive director, obtained by NRDC, bragged
about the industry's successful effort to keep consumers in the dark about the quality of
the bottled water they are buying:
During the [House-Senate SDWA] conference some members wanted the same "right-to-
know" provision enacted for bottled water. Although IBWA vociferously opposed any type
of right-to-know for bottled water, we were informed by Congressional staff that it was a
non-negotiable part of the discussion. Nevertheless, we then met with the House and
Senate conference staff to communicate the industry's concerns to this type of
notification and were successful in getting...a draft study [evaluating the feasibility of
requiring bottled water right-to-know, rather than instituting a requirement] into the
bill....This has been a great victory for the IBWA and the entire bottled water industry! [245]
Thus, if the bottler finds coliform bacteria, Cryptosporidium, cancer-causing solvents, or

other contaminants in the water, but no violation of FDA's standards is triggered (either
because there is no standard for the contaminant or because it was found at a level below
the standard), there is no specific requirement in the FDA rules that such information be
provided to consumers. [246]
Neither is the bottler required by FDA rules to disclose information about the source of the
water, how well protected that source may be from contamination, or whether an
assessment has been performed to determine its vulnerability to contamination. The
bottler also has no obligation to disclose how and whether the water is treated.
Therefore, as a result of a successful vigorous lobbying campaign by the bottled water

industry against right-to-know requirements for consumers of bottled water, the public
likely will know little or nothing about what contaminants are in their bottled water. The
FDA "feasibility study" to evaluate requiring right-to-know information for bottled water
consumers, referred to by IBWA in the internal communication just quoted, was included
in the SDWA essentially as a consolation prize to consumer and environmental groups. [247]
It has not yet been issued, even in draft, although the law required FDA to publish a draft
by February 1998. FDA issued a Federal Register notice late in 1997 asking for public
comment on the feasibility of requiring some kind of disclosure for bottled water. [248] The
study must be finalized by February 1999, [249] but FDA considers this study to be a low
priority and has no firm date for its completion. [250]
The bottled water industry has continued to fight against applying right-to-know rules to
its product. When FDA asked for comments on the feasibility of providing information to
consumers about bottled water on labels, via the Internet or otherwise, they were
inundated by complaints from IBWA and many individual bottlers. [251] IBWA opposed any
right-to-know rules and charged that FDA had "exceeded its Congressional mandate" by
even asking for comments on the type and contents of reports that might be provided to
consumers about bottled water contaminants. [252] One bottler argued that "only the EPA
can think up something as dopey as applying" right-to-know requirements to a "discretely-
packaged, easily identified, pure food product" [253] like bottled water.
As discussed next, NRDC contends that the time has come for bottled water right-to-know
labeling. If right-to-know requirements are good enough for the tap water industry, they're
good enough for the bottled water industry, which is charging consumers hundreds of
times more for their water per gallon and claiming that consumers should switch from
"unreliable" tap water to safer bottled water.
The Need for Right-to-Know Requirements for

Bottled Water
As President Bill Clinton stated in signing into law the 1996 Safe Drinking Water Act
(SDWA) amendments, [254] the public has a right to know about what is in their drinking
water, and whether it may pose a risk to their health. NRDC asserts that this right to know
applies equally to bottled water as it does to tap water. The National Drinking Water
Advisory Council (the congressionally chartered advisory body to EPA on federal drinking
water policy) concurs. In its November 1998 recommendations, the council urged that EPA
and FDA work together to ensure that information about bottled water be made available in
as complete and readily accessible a form to bottled water consumers as tap water
information is now available to tap water users. [255]
Millions of Americans rely upon bottled water as an alternative or substitute for tap water -
- often as a result of the advertising campaigns of bottlers that tout the purity of their
water and occasionally denigrate the quality of tap water. The 1996 SDWA amendments
require consumers to be directly informed by their tap water supplier about all
contaminants in their water (and the health goals and standards for those contaminants),
their supplier's compliance with applicable standards, and the source of their water. [256]
NRDC strongly concludes that similar information must be made available to bottled water
consumers on the label so they can make an intelligent choice as to what water to drink,
considering their own and their family's health needs. For example, immunocompromised
persons clearly could make use of label information on the microbiological quality of the
water, its source, the treatment processes used, if any, and other relevant information. The
label should include information about contaminants in the water found at levels above
health goals and what health effects those contaminants have, the health goals and
acceptable levels of those contaminants, bottler compliance, fluoride and sodium levels,
key information on the source and treatment of the water, and a note on how consumers
can get more information.
Only if the information is available on the label will consumers be able to make informed
choices among the many brands of bottled water, or between bottled water and tap water.
To put it bluntly, if, as the industry argues, bottled water is so pure and there is nothing for
consumers to be concerned about, why not prove it with full disclosure on the label?
Methods for Conveying Information to Consumers

Several methods should be used to inform consumers about their bottled water, but the
backbone of the effort must be label information.
1. Labels should be used to provide consumer information.
To make information useful to consumers, it must be placed on the label. The label
on bottled water is the most important means for communicating information, to
consumers. The label should be of sufficient size and contain sufficient
information presented in a simple, understandable way, to enable those most at
risk from waterborne disease, such as parents of infants, the elderly, and the
immunocompromised (or those wishing to reduce or eliminate their intake of
carcinogenic or otherwise toxic chemicals) to make informed decisions when
choosing a particular brand of water.
Making information available in a usable and understandable form on the label is

the most effective way to provide informed consumer choice. After all, bottlers
devote an enormous effort and spend millions of dollars to create the wording and
appearance of their labels and bottles, precisely because they know that often this
is the factor that can most effectively influence consumer choice. The point at
which most consumers evaluate products and make final purchasing decisions
generally is at the store when the bottle is purchased.
If the information on contaminants is not included on the bottles, it will not add
much to consumer awareness or better-informed buying. This is precisely the
reason that nutrition information is required by the Nutrition Labeling and
Education Act of 1990 to be prominently placed on food labels.
The alternative methods for providing information to consumers suggested by

FDA in a recent Federal Register notice[257] other than label disclosure -- such as
including a phone number or address that the consumer can use to contact the
bottler for more information -- are unlikely to result in any significant additional
information reaching the vast majority of consumers. If the information is not
available on the label when the consumer is making a purchase, it is far less likely
to inform or influence consumer decision making.
To make this point another way, how many bottlers would be satisfied with selling
their water in plain, unadorned generic bottles and having their florid vignettes,
eye-catching graphics, label language, and attractive bottle shapes available to
consumers only upon request to a toll-free number? The answer is virtually none,
because this would eliminate the impact of the information and advertising on
consumer decision making.
Mere reference to a toll-free number or address of the bottler also will be of little
value, in part due to the pervasive consumer view (fueled by heavy industry
advertising) that bottled water is extremely pure, and thus most consumers
rationally may assume there is no reason to expend the time to learn what is
contained in the bottled water they are about to purchase. If consumers have no
reason to believe there may be contaminants in their water, they will have little or
no motivation to make the extra effort necessary to contact their bottler.
Therefore, we urge that bottled water labels should include the following
information:
• The level, expressed in whole numbers (as required by EPA tap water right-
to-know rules), of any contaminant found in the water at a level in excess of
a health goal,[6a] plus the fluoride level (because of this element's asserted
public-health benefits at low levels and, at high levels, its detrimental
effects), sodium level (to assist those seeking to reduce their sodium
intake for health reasons).
• The health goal and allowable level for those contaminants, and fluoride
and sodium, found in the water, in the same units.
• A statement as to whether the bottler is in substantial compliance with

state and federal regulations (based upon an annual certification sent to
the state and FDA and not disagreed with in writing by either), and, if not,
what violations occurred.
• A one-sentence layperson-readable summary of the health effects

associated with any contaminant found at a level in excess of a health goal
(taken from model language written by FDA and EPA).
• A simplified restatement of the EPA-CDC advice to immunocompromised

consumers about the types of bottled water treatment necessary to avoid
Cryptosporidium contamination, and whether the bottled water meets
those criteria.
• The specific source (e.g., "Houston public water system") and treatment
(e.g., "reverse osmosis and ozonation") of the water.
• An FDA toll-free number for consumers to obtain more information (or a

referral to EPA's drinking water hot line);
• The bottler's street address, phone number, and Web or e-mail address (if
any), for further information.
2. Information should also be available on request and on the Internet.
In addition to labeling, but not as a substitute for it, a more detailed consumer
brochure should be available from bottlers. It should include a summary of all
contaminants tested for and the range of levels found, detailed information on
water treatment and on any source-water assessment and protection, and further
information on the items noted in the first six bullets, above, as well as all other
information that would be required to be provided by a public water system in
public-notification and consumer-confidence reports required under section
1414(c) of the SDWA.
Such brochures could be disseminated on the Internet (World Wide Web and e-
mail response) and in response to written requests or telephone inquiries (e.g., via
a menu-driven phone mail that provides automated mail or faxed responses).
These methods of providing information could be a useful supplement to labeling
but, for the reasons previously discussed, would not be an effective substitute for
product labels.
3. Brochures and labels are needed for delivered water.
Water that is delivered to homes or businesses should include the same

information on a label on the carboy (large bottle), because many people
consuming it (e.g., in an office, school, hospital, or other workplace setting) may
not have access to a mailed or hand-delivered brochure. For example, an
immunocompromised person visiting or working at such a location could benefit
from being able to review that information even if a brochure has been misplaced
or is no longer available.
We do believe, however, that mailing or delivering a detailed water report to the

person responsible for the bill would also be advisable, as that person has the
most influence over which water to purchase and may make important use of the
information.
Feasibility of Appropriate Methods

It is quite clear that labeling of bottled water to include the information previously noted is
feasible. Labels on currently sold bottled water have ample space available to include
such information, and previous industry experience with nutrition-label information has
shown the ability to include more information on such labels.
We are aware that there may be concerns expressed by the industry about the feasibility
of including such information on the labels of bottled water due to space limitations,
costs, or other problems. However, several other factors demonstrate the feasibility of
such labeling:
• Our informal survey of the bottles of water commonly sold in major local stores
indicates that such information clearly could fit on the label. On all bottles now on
the market that we have seen, there is ample free space for additional label
information. In the vast majority of cases, substantially less than half of the bottle's
surface area that could be used to provide written information is used to provide
this under current labeling practices. For every brand we have seen, at least 50
percent of the bottle's surface area, and generally a far greater percentage of the
surface area (our estimate is that on average, less than 25 percent of the surface
area of the average bottle of water is covered with label information), is available
for additional label information.
• In unusual cases in which for some reason labels could not be immediately
changed, temporary stickers could be used, or bottlers could use a bottle neck
hanger (as is currently used by Apollinaris), so long as the sticker or hanger
contains all required information and is required to remain on the bottle until sale.
• If industry assertions of the general purity of bottled water are correct, there
should be very few contaminants found at levels above health goals that would
need to be noted on the label, so little additional space would be required for such
information, or for health-effects information regarding such contaminants. For
example, the International Bottled Water Association says flatly that there are "no"
harmful chemicals in bottled water. If so, little or no label space will be required for
information on contaminants.
• Many bottlers already include substantial information (albeit generally without the
important contextual explanation consumers need to understand the data) on the
levels of total dissolved solids, the minerals found in their water, and the levels of
those minerals in their water. For example, detailed information on the levels of
total dissolved solids, as well as levels of sodium, potassium, calcium,
magnesium, chlorides, sulfate, nitrates, bicarbonate, silica, and pH are included on
the labels for Evian, Naya, Strathmore Mineral Water, Vittel, Volvic, Spa, Aqua Cool,
and many other waters. Other bottlers include selected water-quality information
on their bottle labels, for example: S. Pellegrino (total-dissolved-solid, sodium, and
calcium levels); Fountainhead (lead, arsenic, sodium, and nitrate levels); Gerber
Baby Water (fluoride, arsenic, lead, sodium, and nitrate levels); Quibell (calcium,
magnesium, sodium, pH, and total-dissolved-solid levels); Apollinaris (magnesium,
sodium, and total-dissolved-solid level); Vals (sodium and total-dissolved-solids);
and Solé (total-dissolved-solids, sodium, and pH levels)
• In Europe, mineral water already must include such total-dissolved-solids and

mineral-composition information. It is therefore clearly possible to identify on the
label the levels of what are hoped to be at most a small number of contaminants
found at levels over health goals.
• Some states already require information on the source of the water (e.g.,
Massachusetts) and on arsenic and lead levels (e.g., Vermont), etc., on the label,
and many bottlers already include such information on their labels, so a national
requirement for such information would not add to the burden of many bottlers.
• Many bottlers making claims about low- or no-sodium content include nutritional
information already, information that rivals or exceeds the space requirements
necessary to include the information previously noted.
• The costs of relabeling will be trivial when compared with the profit margin in the
industry. The food-nutrition label has not been a significant burden on the food
industry, and profit margins in this industry are greater. For example, a bottler
selling water taken from a public water supply and then filtered is likely to sell that
water for hundreds of times more per liter than the bottler paid the water supply for
the water, and will have spent a small amount per gallon for treatment.
• If public water suppliers, who are charging far less per gallon of water, can supply
such information to consumers, it is imperative and feasible for bottlers to do so
as well.
Conclusions Regarding Right-to-Know

Information for Bottled Water
Consumers have a right to know about what is in their drinking water and whether it poses
any risk to their health. For this reason, water bottlers should be required to disclose
information about bottled water contaminants, bottler compliance, water treatment, the
source of the water, and health issues on the label. Without such label disclosure,
informed consumer decision making about whether to purchase bottled water will be
seriously undermined.
Chapter Notes
6a. The term "health goal" refers to an EPA Maximum Contaminant Level Goal (MCLG), see SDWA §1412(b)(4)(A)), if any,
or, if there is no MCLG, the lowest EPA Health Advisory Level (HAL), see SDWA § 1412(b)(1)(F)), or if there is no MCLG or
HAL, the lowest EPA human health-based water quality criteria for that contaminant (see Clean Water Act §§ 303-304).
For contaminants with an MCL but no MCLG, it is particularly important for the health-based water quality criteria to be
noted on the label (until an MCLG is published), since such standards (like arsenic) have not been revised since 1942
and thus do not reflect up-to-date science.
Report Notes
243. SDWA § 1414(c)(4).
244. Constance Hayes, "Now, Liquid Gold Comes in Bottles," The New York Times, p. D1 (January 20, 1998).
245. Sylvia Swanson, IBWA Executive Director, "Safe Drinking Water Act Becomes Law," reprinted in Aqua News:
Northeast Bottled Water Association, p. 5 (Summer 1996).
246. While theoretically bottlers are obliged to include on the label a statement that their product "Contains Excessive
Chemical Substances [or Bacteria]" if it violates an FDA standard, the bottler's obligations to disclose under the FDA
rules about end there.
247. SDWA Amendments of 1996, Pub. L. No. 104-182, § 114(b).

248. 62 Fed. Reg. 60721 (November 12, 1997).
249. SDWA Amendments of 1996, Pub. L. No. 104-182, § 114(b).
250. Personal Communication with Henry Kim, FDA Center for Food Safety and Applied Nutrition, November 20, 1998.
251. See, e.g.Sylvia Swanson, IBWA Comments on Bottled Water Study: Feasibility of Informing Consumers of the
Contents of Bottled Water, November 12, 1997 (comments dated December 12, 1997); Kim Jeffrey, Perrier Group of
America, Comments on Bottled Water Study: Feasibility of Informing Consumers of the Contents of Bottled Water,
November 12, 1997 (comments dated December 12, 1997); Jack West, Puro Water Group, Comments on Bottled Water
Study: Feasibility of Informing Consumers of the Contents of Bottled Water, November 12, 1997, (comments dated
December 11, 1997) [FDA Docket 97N-0436].
252. Sylvia Swanson, IBWA Comments on Bottled Water Study: Feasibility of Informing Consumers of the Contents of
Bottled Water, November 12, 1997 (comments dated December 12, 1997).
253. Jack West, Puro Water Group, Comments on Bottled Water Study: Feasibility of Informing Consumers of the
Contents of Bottled Water, November 12, 1997 (comments dated December 11, 1997) [FDA Docket 97N-0436].
254. Pub. L. No. 104-182 (August 6, 1996).
255. Recommendations of the National Drinking Water Advisory Council, November 1998.
256. SDWA § 1414(c).
257. 62 Fed. Reg. 60721 (November 12, 1997)
Appendix A
SUMMARY OF NRDC'S TEST RESULTS

Bottled Water Contaminants Found
Note: To print portions of this chart, in the Print dialogue box choose Properties and Paper
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# on (if Tested
listed)
d) in 10 ppb
cfu/ml ppb)
in
ppb
365 1 Natur Berkel Bottled Not Not Not Not Not Not Not Res 10 SA-
al ey, in Detect Detec Detec Detect Dete Dete Detected ults (comp 711-
Spring CA Austin, ed ted ted ed cted cted not osited) 140
Water TX rece 2
(1.5 ived
liters)
Albertso 1 Natur San Palomar Not Not Not Not Not Not Not 0.8 10 SA-
n's A+ al Diego/ Mtn. Detect Detec Detec Detect Dete Dete Detected (comp 712-
Spring San Spring ed ted ted ed cted cted osited) 039
Water Marco 0
(1 s, CA
liter)
Alhamb 1 Crysta San McKess 45 Not Not Not Not Not Not 0.1 Toluene 3 (1 EQI Toluene and
ra l Franci on Detec Detec Detect Dete Dete Detected detected for -1- o-xylene are
Fresh sco Water ted ted ed cted cted at 12.5 each 27- industrial
Drinki Prod., ppb contam 29 chemicals
ng Pasaden o- inant found at
Water a, CA xylene type) levels below
(1 at 2.7 standards.
gal.) ppb Bottle
claims
"purified
using. .
.filtration,
ozonation,
reverse
osmosis,
and/or
deionization
."
Alhamb 2 Crysta San McKess 56 Not Not Not Not Not Not Res No 10 SA-
ra l Franci on Detec Detec Detect Dete Dete Detected ults toluene (comp 711-
Fresh sco Water ted ted ed cted cted not or osited) 140
Drinki Prod., rece xylene 3
ng Pasaden ived detected
Water a, CA
(1
liter)
Alhamb 1 Sport San McKess Not Not Not Not Not Not Not 0.1 3 (1 EQI
ra Top Franci on Detect Detec Detec Detect Dete Dete Detected for -1 -
Crysta sco Water ed ted ted ed cted cted each 33a-
l Prod., contam f
Fresh Pasaden inant
Drinki a, CA type)
ng
Water
(16.9
fl. oz.)
Alhamb 1 Mount San McKess >5700 Not Not Not Not Not Not Not Colifor 3 (1 EQI HPC
ra*† ain Franci on † Detec Detec Detect Dete Dete Detected Dete ms for -1- bacteria in
Spring sco Water ted ted ed cted cted cted found at each 30- excess of
Water, Prod., >200* contam 32 guideline,
"prepa Pasaden inant and
red a, CA type) coliforms in
using excess of
filtrati FDA
on standards.
and
ozone
" (1
gal.)
Alhamb 2 Mount San McKess 1100† Not Not Not Not Not Not Res No 10 SA- HPC
ra† ain Franci on Detec Detec Detect Dete Dete Detected ults colifor (comp 711- bacteria in
Spring sco Water ted ted ed cted cted not ms osited) 140 excess of
Water Prod., rece detected 4 guideline.
(1 Pasaden ived
gallon a, CA
)
Apollin 1 Sparkl Berkel Bad Not 5.6* Not Not Not Not Not Res Fluoride 10 SA- Arsenic
aris* ing ey, Neuenah Detect Detec Detect Dete Dete Detected ults found at (comp 711- level
Miner CA r- ed ted ed cted cted not 0.37 osited) 140 exceeds CA
al Ahrweil rece ppm, 5 Prop. 65
Water er, ived below level.
(1 German std.
liter) y
Apollin 2 Sparkl No test 7.8* No No No No No test No 10 SA- Arsenic
aris* ing test test test test test (comp 806- level
Miner osited) 207 exceeds CA
al 8 Prop. 65
Water level.
Aquafin 1 Purifi Los Not Not Not Not Not Not Not Not 3 (1 EQI
a ed Angel Detect Detec Detec Detect Dete Dete Detected Dete for -1-
Drinki es ed ted ted ed cted cted cted each LA6
ng contam -
Water inant LA8
-- type)
"Purit
y
Guara
nteed"
Non-
Carbo
nated
(1
liter)
# on (if Tested
listed)
d) in 10 ppb
cfu/ml ppb)
in
ppb
Aquafin 1 Purifi Berkel Laurel Not Not Not Not Not Not Not Res 10 SA-
a ed ey, Bottling Detect Detec Detec Detect Dete Dete Detected ults (comp 711-
Drinki CA Co, ed ted ted ed cted cted not osited) 140
ng Fresno, rece 6
Water CA ived
--
"Purit
y
Guara
nteed"
(1
liter)
Aquafin 1 Purifi Houst City of Not Not 4.1 3.5 0.6 Not 5 ppb (just Not Di(2- 10 298 Pthalate
a ed on, Houston Detect Detec Dete below 6 Dete ethylhe (comp 808- (DEHP) is
Drinki TX Water ed ted cted ppb tap cted xyl) osited) 965 often
ng Supply water adipate (944 present as a
Water standard) found at - result of
0.9 ppb 949) migration
( below from the
standard bottle to the
of 400 water. The
ppb) level
detected is
just below
the EPA tap
water
standard for
this
chemical,
though there
is no bottled
water
standard
(see text).
Aquafin 2 Purifi Houst City of Not No No No No No No test No 10 298- HPC
a ed on, Houston Detect test test test test test test bottles, 808- bacteria test,
Drinki TX Water ed individ 965 none found
ng Supply ually (934 in 10
Water - bottles.
943)
Arrowh 1 Mount San Arrowhe Not 3.2 Not Not Not Not Not 1.2 3 (1 EQI
ead ain Franci ad Detect Detec Detect Dete Dete Detected for -1-
Spring sco MSW ed ted ed cted cted each 37a-
Water Co., contam f
L.A., inant
CA type)
Arrowh 2 Mount Berkel Arrowhe 5 Not Not Not Not Not Not Res 10 SA-
ead ain ey, ad Detec Detec Detect Dete Dete Detected ults (comp 711-
Spring CA MSW ted ted ed cted cted not osited) 140
Water Co., rece 7
(1.5 L.A., ived
liter) CA
Arrowh 3 Mount Los Not Not Not 4.3 1.9 1.6 0.8 Not 1.0 10 SA
ead ain Angel noted Detect Detec Detected (comp 712-
Spring es ed ted osited) 080
Water 7
(5
gallon
)
Arrowh 1 Sparkl San Arrowhe Not 3.1 Not Not Not Not Not 0.8 3 (1 EQI
ead ing Franci ad Detect Detec Detect Dete Dete Detected for -1-
Mount sco MSW ed ted ed cted cted each 34-
ain Co., contam 36
Spring L.A., inant
Water CA type)
(1.5
liter)
Arrowh 2 Sparkl Berkel Arrowhe Not Not 1.1 1.1 Not Not Not Res 10 SA-
ead ing ey, ad Detect Detec Dete Dete Detected ults (comp 711-
Mount CA MSW ed ted cted cted not osited) 140
ain Co., rece 8
Spring L.A. , ived
Water CA
(1.5
liter)
Beechnu 1 Water, San Palomar Not Not Not Not Not Not Not Not Fluoride 10 SA-
t Fluori Dimas Mountai Detect Detec Detec Detect Dete Dete Detected Dete at 0.71 (comp 712-
de , CA n, ed ted ted ed cted cted cted ppm osited) 039
Added bottled 2
(1 by
gallon Famous
) Ramona
,
Ramona
, CA
Black 1 Distill Berkel Black 1000† Not 4 1.4 1.8 0.8 Not Res 10 SA- Level of
Mounta ed ey, Mtn. Detec Detected ults (comp 711- HPC
in† Water CA Wtr.Co., ted not osited) 140 bacteria
(1 San rece 9 exceeds
gallon Carlos, ived guideline.
) CA
# on (if Tested
listed)
d) in 10 ppb
cfu/ml ppb)
in
ppb
Black 2 Distill Not No No No No No No test No No total 10 SA No HPC
Mountai ed Detect test test test test test test colifor (tested 806- bacteria
n Water ed ms individ 207 detected.
ually) 9
Black 1 Fluori Berkel Black 2100† Not 2.4 1.1 1.3 Not Not Res Fluoride 10 SA- Fluoride
Mounta dated ey, Mtn. Detec Dete Detected ults found at (comp 711- above
in† Water CA Wtr.Co., ted cted not 0.93 osited) 141 standard of
(1 San rece ppm* 0 0.8 ppm for
gallon Carlos, ived (exceed added
) CA s fluoride in
standard areas with
in warm average high
areas) temp. of
79.3°F.
HPC
bacteria
over
guideline
level of 500
cfu/ml.
Black 2 Fluori 18,000 No No No No No No test No No total 10 SA 1 bottle of
Mounta dated † test test test test test test colifor (indivi 806- 10 contained
in† Water (1bottl ms dually) 208 HPC level
e) 0 well over
30 (1 guideline
bottle) level.
Not
Detect
ed (8
bottles
)
Black 3 Fluori No test No No No No No No test No Fluoride 4 901- Fluoride
Mountai dated test test test test test test found at (comp 079 above
n Water 1.3 ppm osited) standard of
(exceed 0.8 ppm for
s added
standard fluoride in
in warm warm
areas) weather
areas
(average
high over
79°F).
Black 1 Purifi Berkel Black Not Not 2.3 1.1 1.2 Not Not Res 10 SA-
Mountai ed ey, Mtn. Detect Detec Dete Detected ults (comp 711-
n Water CA Wtr.Co., ed ted cted not osited) 141
(1 San rece 1
gallon Carlos, ived
) CA
Black 1 Spring San Black >5,700 3.6 Not Not Not Not Not 0.2 Total 3 (1 EQI Levels of
Mounta Water Franci Mtn. † Detec Detect Dete Dete Detected colifor for -1- HPC
in*† (1 sco Wtr.Co., ted ed cted cted m count each 19- bacteria
gallon San 27*; contam 20 exceed
) Carlos, Toluene inant guidelines.
CA found at type) Coliforms
8.9 ppb exceed FDA
standards.
Toluene is a
component
of gasoline
or industrial
chemicals.
Black 2 Spring San Black 330 Not Not Not Not Not Not Not No total 10 SA-
Mountai Water Franci Mtn. Detec Detec Detect Dete Dete Detected Dete colifor (comp 712-
n (5 sco Wtr.Co., ted ted ed cted cted cted ms or osited) 084
gal.) San toluene 6
Carlos, detected
CA
Black 3 Spring Berkel Black 80 Not Not Not Not Not Not Not No total 10 SA-
Mountai Water ey, Mtn. Detec Detec Detect Dete Dete Detected Dete colifor (comp 711-
n (1 CA Wtr.Co., ted ted ed cted cted cted ms or osited) 157
gallon San toluene 7
) Carlos, detected
CA
Calistog 1 Distill Berkel Calistog Not Not Not Not Not Not Not Not 10 SA-
a ed ey, a MW Detect Detec Detec Detect Dete Dete Detected Dete (comp 711-
Water CA Co., ed ted ted ed cted cted cted osited) 157
(1 Calistog 8
gallon a, CA
)
Calistog 1 Mount San Calistog Not Not Not Not Not Not Not 0.8 3 (1 EQI
a ain Franci a MW Detect Detec Detec Detect Dete Dete Detected for -1-
Spring sco Co., ed ted ted ed cted cted each 1a-f
Water Calistog contam
(0.5 a, CA inant
liter) type)
# on (if Tested
listed)
d) in 10 ppb
cfu/ml ppb)
in
ppb
Calistog 2 Mount Oakla Calistog 4900† Not Not Not Not Not Not 0.6 10 SA- HPC
a† ain nd, a MW Detec Detec Detect Dete Dete Detected (comp 712- bacteria
Spring CA Co., ted ted ed cted cted osited) 084 found at
Water Calistog 7 levels
(6 a, CA substantially
gal.) exceeding
guideline.
Calistog 3 Mount San Calistog Not Not Not Not Not Not Not 0.5 10 SA-
a ain Franci a MW Detect Detec Detec Detect Dete Dete Detected (comp 711-
Spring sco Co., ed ted ted ed cted cted osited) 157
Water Calistog 9
(1 a, CA
liter)
Calistog 4 Mount Not No No No No No No test No No total 10 SA HPC
a ain Detect test test test test test test colifor (indivi 806- bacteria
Spring ed to 1 ms dually) 208 within
Water cfu/ml 1 guidelines in
all bottles
tested.
Calistog 1 Sparkl San Napa 3 31.8* Not Not Not Not Not 0.1 3 (1 EQI Arsenic
a* ing Franci Valley Detec Detect Dete Dete Detected for -1- level
Miner sco ted ed cted cted each 2-4 exceeds CA
al contam Prop. 65
Water, inant limit.
Origin type)
al
Napa
Valley
(1
liter)
Calistog Sparkl San Napa No test Not No No No No No test No 8 SA- Arsenic
a ing Franci Valley Detec test test test test test (comp 901- retest found
Miner sco ted osited) 079 none
al 7
Water,
Origin
al
Napa
Valley
Calistog 1 Sparkl San Calistog Not Not Not Not Not Not Not Not 10 SA-
a ing Franci a MW Detect Detec Detec Detect Dete Dete Detected Dete (comp 711-
Miner sco Co., ed ted ted ed cted cted cted osited) 158
al Calistog 0
Water a, CA
(1
liter)
Calistog 2 Sparkl No test Not No No No No No test No 10 SA
a ing Detec test test test test test (comp 806-
Miner ted osited) 207
al 8
Water
Canada 1 Club Berkel Cadbury Not Not Not Not Not Not Not 0.6 10 SA-
Dry Soda ey, Beverag Detect Detec Detec Detect Dete Dete Detected (comp 711-
(1 CA es ed ted ted ed cted cted osited) 158
liter) Stamfor 1
d, CT
Canada 1 Sparkl San Cadbury 1.0 Not Not Not Not Not Not Not Fluoride 10 SA-
Dry ing Franci Beverag Detec Detec Detect Dete Dete Detected Dete found at (comp 711-
Water sco es ted ted ed cted cted cted 0.13 osited) 158
(1 Stamfor ppm, 2
liter) d, CT well
below
std.
Castle 1 "Sprin San "The Not Not Not Not Not Not Not Not 3 (1 EQI
Rock g Franci Cascade Detect Detec Detec Detect Dete Dete Detected Dete for -1-
Water sco Mountai ed ted ted ed cted cted cted each 16-
Bottle ns" contam 18
d at inant
the type)
Sourc
e" (1
liter)
# on (if Tested
listed)
d) in 10 ppb
cfu/ml ppb)
in
ppb
Cobb 1 Natur Berkel Cobb Not Not 1.2 Not Not Not Not Not Bromof 10 SA-
Mountai al ey, Mtn. Detect Detec Detect Dete Dete Detected Dete orm (a (comp 711-
n Spring CA Spring ed ted ed cted cted cted trihalom osited) 158
Water Water ethane) 3
(1.5 Co., found at
liter) Cobb, 1.2 ppb,
CA below
standard
Crystal 1 Alpin San CG 460 17.8* Not Not Not Not Not 3 (1 EQI Arsenic
Geyser* e Franci Roxane click Detec Detect Dete Dete Detected for -1- level
Spring sco source, for ted ed cted cted each 26a- exceeds CA
Water Eastern updat contam f Prop. 65
(16.9 Sierra, e inant limit.
oz.) bottled type)
at
Olancha
, CA
Crystal 2 Alpin San CG Not 11* Not Not Not Not Not Not Fluoride 10 SA- Arsenic
Geyser* e Franci Roxane Detect click Detec Detect Dete Dete Detected Dete found at (comp 711- level
Spring sco source, ed for ted ed cted cted cted 0.82 osited) 158 exceeds CA
Water Eastern updat ppm 5 Prop. 65
(1 Sierra, e limit;
liter) Olancha fluoride
, CA level is
below
standard of
1.4 ppm in
warm areas
(if natural)
but above
the warm
area
standard of
0.80 ppm if
added.
Crystal 3 Alpin No test 12* No No No No No test No 10 SA Arsenic
Geyser* e click test test test test test (comp 806- exceeds
Spring for osited) 207 Prop. 65
Water updat 8 limit and
e WHO/EU
standard.
Crystal 1 Napa San Napa 1 35.2* Not Not Not Not Not 0.2 3 (1 EQI Arsenic
Geyser* Valley Franci Valley click Detec Detect Dete Dete Detected for -1- exceeds
Sparkl sco for ted ed cted cted each 25a- Prop. 65
ing updat contam f limit.
Miner e inant
al type)
Water
Bottle
d at
the
Sourc
e (12
fl. oz.)
Crystal 2 Napa No test Not No No No No No test No 10 SA No arsenic
Geyser Valley Detec test test test test test (comp 806- detected.
Sparkl ted osited) 207
ing 8
Miner
al
Water
Crystal 3 Napa No test 14 No No No No No test No No test 10 SA- Arsenic
Geyser* Valley ppb test test test test test (comp 901- exceeds CA
Sparkl click osited) 079 Prop. 65
ing for 8 limit and
Miner updat WHO/EU
al e standard.
Water
Crystal 1 Sparkl Berkel Crystal Not Not Not Not Not Not Not Not 10 SA-
Geyser ing ey, Geyser Detect Detec Detec Detect Dete Dete Detected Dete (comp 711-
Miner CA Water ed ted ted ed cted cted cted osited) 158
al Compan 4
Water y,
(1 Calistog
liter) a, CA
Crystal 1 (1 Chica Not Not Not Not Not Not Not Not 10 297
Geyser liter) go, IL Detect Detec Detec Detect Dete Dete Detected Dete (comp 719-
ed ted ted ed cted cted cted osited) 48
(43-
48)
Crystal 1 (1 Chica Not No No No No No No test No 9 297
Geyser liter) go, IL Detect test test test test test test (indivi 790-
ed dually) 836
(810
-
818)
# on (if Tested
listed)
d) in 10 ppb
cfu/ml ppb)
in
ppb
Dannon 1 Natur San Piedmon 6 Not Not Not Not Not Not 0.8 3 (1 EQI
al Franci t, Detec Detec Detect Dete Dete Detected for -1-
Spring sco Quebec, ted ted ed cted cted each 24a-
Water Canada contam f
(1.05 inant
pint ) type)
Dannon 2 Natur San Piedmon 330 Not Not Not Not Not Not 0.8 10 SA-
al Franci t, Detec Detec Detect Dete Dete Detected (comp 711-
Spring sco Quebec, ted ted ed cted cted osited) 169
Water Canada 6
(1
liter)
Dannon 3 Natur New Piedmon Not Not Not Not Not Not Not 1.2 Di-n- 10 299 Pthalate
al York t, Detect Detec Detec Detect Dete Dete Detected butyl- (comp 863- may be from
Spring City Quebec, ed ted ted ed cted cted pthalate osited) 942 leaching
Water Canada at 7.5 (911 from bottle
ppb; - top or other
Methyle 916) packaging
ne materials;
chloride methylene
at 1.5 chloride of
ppb unknown
(below origin, and
5ppb at 30% of
statanda FDA
rd) standard.
Dannon 4 Natur New Piedmon 2 of 10 No No No No No No test No 10 299 Bacterial
† al York t, bottles test test test test test test (indivi 863- overgrowth
Spring City Quebec, tested dually) 942 was
Water Canada contain (917 observed in
ed - 2 of the 10
HPC 926) bottles
bacteri tested. The
al presence of
overgr a large
owth† number of
noncoliform
HPC
bacteria may
be inhibiting
the detection
of coliform
bacteria
during the
testing. See
text for
discussion
of HPC
bacteria.
Deer 1 Spring New Valley Not Not Not Not Not Not Not Not 10 299
Park Water York View Detect Detec Detec Detect Dete Dete Detected Dete (comp 863-
(1 City Spring, ed ted ted ed cted cted cted osited) 942
liter) Hegins (879
Twp., -
PA 884)
Deer 2 Spring New Valley Not No No No No No No test No 10 299
Park Water York View Detect test test test test test test (indivi 863-
(1 City Spring, ed dually) 942
liter) Hegins (885
Twp., -
PA 894)
Deer 3 Spring Washi Hegin Not Not Not Not Not Not Not Not 10 298
Park Water ngton Townshi Detect Detec Detec Detect Dete Dete Detected Dete (comp 808-
(1.5 DC p, PA ed ted ted ed cted cted cted osited) 965
liter) (879
-
884)
Deer 4 Spring Washi Hegin Not No No No No No No test No 10 298
Park Water ngton Townshi Detect test test test test test test (indivi 808-
(1.5 DC p, PA ed dually) 965
liter) (869
-
878)
Dominic 1 Natur Chica Not Not Not Not Not Not Not 0.6 10 297
k's al go, IL Detect Detec Detec Detect Dete Dete Detected (comp 719-
Spring ed ted ted ed cted cted osited) 48
Water (31-
(1.5 36)
liter)
Dominic 2 Natur Chica Not No No No No No No test No 9 297
k's al go, IL Detect test test test test test test (indivi 790-
Spring ed dually) 836
Water (828
(1.5 -
liter) 836)
# on (if Tested
listed)
d) in 10 ppb
cfu/ml ppb)
in
ppb
Evian 1 Natur San Cachat 21 2.0 Not Not Not Not Not 0.7 3 (1 EQI
al Franci Springs, Detec Detect Dete Dete Detected for -1-
Spring sco, Evian, ted ed cted cted each 21-
Water CA France contam 23
(1 inant
liter) type)
Evian 2 Natur San Cachat 63 Not Not Not Not Not Not 0.8 10 SA-
al Franci Springs, Detec Detec Detect Dete Dete Detected (comp 711-
Spring sco, Evian, ted ted ed cted cted osited) 169
Water CA France 7
(1
liter)
Fiuggi 1 Natur Berkel A.S.T.I. 7 Not Not Not Not Not Not 2.5 10 SA-
al ey, F., Detec Detec Detect Dete Dete Detected (comp 711-
Miner CA Fiuggi, ted ted ed cted cted osited) 169
al Italy 8
Water
(1
liter)
Gerber 1 Baby Berkel AquaPe 2 Not Not Not Not Not Not 0.6 Fluoride 10 SA-
Water ey, nn Detec Detec Detect Dete Dete Detected found at (comp 711-
with CA Springs, ted ted ed cted cted 0.46 osited) 169
Fluori Graysvil ppm, 9
de le, PA below
(1.5 standard
liter)
Gerolste 1 Sprud Berkel Gerolste Not Not Not Not Not Not Not 1.0 10 SA-
iner el ey, in, Detect Detec Detec Detect Dete Dete Detected (comp 711-
Sparkl CA German ed ted ted ed cted cted osited) 170
ing y 0
Miner
al
Water
(1
liter)
Glacier 1 Purifi Miami Not Not 1.6 1.6 Not Not Not Not Alumin 10 304 Aluminum
Springs ed , FL Detect Detec Dete Dete Detected Dete um (comp 085- found at 180
Water ed ted cted cted cted found at osited) 165 ppb, just
(1 180 ppb (150 below the
gallon (std. is - 200 ppb
) 200 155) FDA bottled
ppb) water
standard, set
based on
taste, odor,
and
aesthetic
concerns.
FDA's
standard for
aluminum is
not
applicable to
mineral
water, but is
applicable to
purified
water.
Glacier 2 Purifi Miami HPC No No No No No No test No 10 304 Bacterial
Springs ed , FL bacteri test test test test test test (indivi 085- overgrowth
† Water al dually) 165 was
overgr (304 observed in
owth 156- 1 of the 10
detecte 304 bottles
d in 1 165) tested. The
of 10 presence of
bottles a large
tested† number of
noncoliform
HPC
bacteria may
be inhibiting
the detection
of coliform
bacteria
during the
testing. See
text for
discussion
of HPC
bacteria.
Hawaii 1 Purifi Berkel Menehu Not Not Not Not Not Not Not Not 10 SA-
ed ey, neWater Detect Detec Detec Detect Dete Dete Detected Dete (comp 711-
Drinki CA Co, ed ted ted ed cted cted cted osited) 170
ng Aiea, HI 1
Water
(1.5
liters)
Hildon 1 Miner Berkel Brought Not Not Not Not Not Not Not 5.6 10 SA- Elevated
al ey, on, Detect Detec Detec Detect Dete Dete Detected (comp 711- nitrate level,
Water CA Hampsh ed ted ted ed cted cted osited) 170 though
- ire, 2 below FDA
nated potential
(750 concern--see
ml) text.
Hildon 2 Miner Berkel Brought No test No No No No No No test 5.4 10 SA Retest of
al ey, on, test test test test test (comp 808- elevated
Water CA Hampsh osited) 166 nitrate level;
- ire, 3 below FDA
nated potential
(750 concern--see
ml) text.
# on (if Tested
listed)
d) in 10 ppb
cfu/ml ppb)
in
ppb
Hildon 1 Miner Berkel Brought 200 Not Not Not Not Not Not 5.6 10 SA- Elevated
al ey, on, Detec Detec Detect Dete Dete Detected (comp 711- nitrate level,
Water CA Hampsh ted ted ed cted cted osited) 170 though
-Still ire, 3 below FDA
(750 England standard, of
ml) potential
concern--see
text.
Hinckle 1 (1 Chica Not Not Not Not Not Not Not 1.9 10 297
y gallon go, IL Detect Detec Detec Detect Dete Dete Detected (comp 719-
Schmidt ) ed ted ted ed cted cted osited) 48
(25-
30)
Hinckle 2 (1 Chica Not No No No No No No test No 10 297
y gallon go, IL Detect test test test test test test (indivi 790-
Schmidt ) ed dually) 836
(790
-
799)
Hyde 1 Purifi Miami >5700 Not 2.2 2.1 0.1 Not Not Not 10 304 Level of
Park† ed , FL † Detec Dete Detected Dete (comp 085- HPC
Water ted cted cted osited) 165 bacteria
(1 (101 substantially
gallon - exceeded
) 106) guideline.
Hyde 2 Purifi Miami Not No No No No No No test No 10 304 Retest for
Park ed , FL Detect test test test test test test (indivi 085- HPC
Water ed dually) 165 bacteria in
(304 10 bottles
107- found none
304
116)
Ice Age 1 "Glaci Berkel Alpine 67 Not Not Not Not Not Not Not 10 SA-
al ey, Creek, Detec Detec Detect Dete Dete Detected Dete (comp 711-
Water CA Manitob ted ted ed cted cted cted osited) 170
" (1 a Inlet, 4
liter) Canada
Janet 1 Drinki San Albertso Not Not Not Not Not Not Not 0.7 10 SA-
Lee ng Diego/ ns, Detect Detec Detec Detect Dete Dete Detected (comp 712-
Water San Boise, ed ted ted ed cted cted osited) 039
(1 Marco ID, 3
)
Janet 1 Purifi San Albertso Not Not Not Not Not Not Not Not 10 SA-
Lee ed Diego/ ns, Detect Detec Detec Detect Dete Dete Detected Dete (comp 712-
Water San Boise ed ted ted ed cted cted cted osited) 039
(1 Marco ID, 4
)
Janet 1 Spring San Albertso 41 Not Not Not Not Not Not Not 10 SA-
Lee Water Diego/ ns, Detec Detec Detect Dete Dete Detected Dete (comp 712-
(1 San Boise ted ted ed cted cted cted osited) 039
gallon Marco ID, 5
) s, CA distrib.
Jewel 1 Artesi Chica Not 1.1 Not Not Not Not Not Not 10 297
an go, IL Detect Detec Detect Dete Dete Detected Dete (comp 719-
Water ed ted ed cted cted cted osited) 48
(1 (19-
gallon 24)
)
# on (if Tested
listed)
d) in 10 ppb
cfu/ml ppb)
in
ppb
Jewel 2 Artesi Chica Not No No No No No No test No 10 298
an go, IL Detect test test test test test test (indivi 808-
(1 (800
gallon -
) 809)
Kroger 1 Utopi Houst Indian 1 Not Not Not Not Not Not 0.9 10 298
a on, Springs, Detec Detec Detect Dete Dete Detected (comp 808-
Spring TX Franklin ted ted ed cted cted osited) 965
Water County, (928
(1 TX -
liter) 933)
Kroger 2 Utopi Houst Indian Not No No No No No No test No 10 298
a on, Springs, Detect test test test test test test (indivi 808-
Spring TX Franklin ed dually) 965
Water County, (918
(1 TX -
liter) 927)
Lady 1 Natur San Not Not Not Not Not Not Not Not Toluene 3 (1 EQI Toluene and
Lee al Franci Detect Detec Detec Detect Dete Dete Detected Dete at 13.9 for -1- xylene are
Spring sco ed ted ted ed cted cted cted ppb; o- each 53- constituents
Water xylene contam 55 of gasoline
(1 at 3.0 inant and also
gallon ppb type) used in
) some
industrial
chemicals.
Lucky 2 Natur San Plant 20 Not Not Not Not Not Not Not No 10 SA-
(aka al Franci #06-21 Detec Detec Detect Dete Dete Detected Dete toluene (comp 712-
Lady Spring sco ted ted ed cted cted cted or osited) 002
Lee) Water xylene 5
(1 detected
gallon
)
Lady 3 Natur No test No Not Not Not Not No test No Toluene 10 SA-
Lee al test Detec Detect Dete Dete test at 0.55 (comp 806-
Spring ted ed cted cted ppb, no osited) 208
Water xylene 6
detected
Lady 1 Purifi San Not 6.5* 54.8* 54.8* Not Not Not 0.1 Toluene 3 (1 EQI Arsenic and
Lee* ed Franci Detect Dete Dete Detected at 9.5 for -1- chloroform
Water sco ed cted cted ppb; each 50- at levels
purifie ethyl- contam 52 above CA
d by benzene inant Prop. 65
deioni at 2.0 type) levels.
zation ppb; TTHMs
(1 m/p- above CA
gallon xylene and industry
) at 3.1 standard of
ppb; o- 10 ppb.
xylene Toluene and
at 6.3 xylene are
ppb gasoline
constituents
and also
used in
some
industrial
chemicals.
Lucky 2 Purifi San Plant 1 Not 1.1 1.1 Not Not Not Not 10 SA-
(aka ed Franci #06-21 Detec Dete Dete Detected Dete (comp 712-
Lady Water sco ted cted cted cted osited) 002
Lee) (1 6
gallon
)
Lady 3 Purifi San Not Not Not Not Not Not No test No Methyle 3 (1 SA- Methylene
Lee ed Franci Detect Detec Detec Detect Dete Dete test ne for 808- chloride at
Water sco ed ted ted ed cted cted chloride each 166 level just
purifie at 4.1 contam 6 below
d by ppb inant federal
deioni (std. is type) standard.
zation 5 ppb)
(1
gal.)
Lady 1 Drinki San Not 3.2 91.6* 88.9* 2.7* Not Not 0.1 Toluene 3 (1 EQI THM levels
Lee* ng Franci Detect Dete Detected at 11.0 for -1- in excess of
Water sco ed cted ppb; each 56- CA &
(1 o- contam 58 industry
gallon xylene inant standards;
) at 2.9 type) chloroform
ppb and
bromodichlo
romethane
in excess of
CA Prop. 65
level.
Toluene and
xylene are
gasoline
constituents
and also
used in
industrial
chemicals.
# on (if Tested
listed)
d) in 10 ppb
cfu/ml ppb)
in
ppb
Lady 2 Drinki No test No 29* 29* Not Not No test No Toluene 10 SA- THM levels
Lee* ng test Dete Dete test at 0.5 (comp 806- in excess of
Water cted cted ppb; no osited) 208 CA &
xylene 5 industry
found standards;
chloroform
in excess of
CA Prop. 65
level.
Toluene is a
gasoline
constituent
and used in
industrial
chemicals.
Lucky 3 Drinki San Plant 8 Not Not Not Not Not Not Not No 10 SA-
(aka ng Franci #06-21 Detec Detec Detect Dete Dete Detected Dete toluene (comp 711-
Lady Water sco ted ted ed cted cted cted or osited) 170
Lee) (1 xylene 5
gallon detected
)
Lucky* 1 Seltze San Salt Not Not 30.7* 29* 1.7 Not Not Not Fluoride 10 SA- THM level
r Franci Lake Detect Detec Dete Detected Dete found at (comp 712- exceeds CA
Water sco City, ed ted cted cted 0.84 osited) 002 & industry
(2 UT, ppm* 7 standards,
liters) distrib., and
Am chloroform
Procure level
ment & exceeds CA
Logistic Prop. 65
s level.
Fluoride
level
slightly over
CA warm
weather area
standard of
0.8 ppm if
fluoride
added (if
fluoride is
natural,
warm
weather area
standard is
1.4 ppm);
identical
FDA
standard
does not
apply to
seltzer (not
defined as
"bottled
water").
Lucky* 2 Seltze No test No 20* 20* Not Not No test No n- SA- Chloroform
r test Dete Dete test isoprop 806- level CA
Water cted cted yl- 208 Prop. 65
toluene 7 warning
at 230 level; THM
ppb; level
n-butyl- exceeds CA
benzene & industry
at 21 standards.
ppb; High level
Toluene of n-
at 1.8 isopropyl
ppb; toluene and
elevated
level of n-
butyl-
benzene of
unknown
origin; CA
law
generally
prohibits
levels over 1
ppb of these
VOCs in
source
water, but
may have
been added
in
processing.
Lucky 1 Sparkl San Not Not Not Not Not Not Not 0.2 p- 3 (1 EQI
ing Franci Detect Detec Detec Detect Dete Dete Detected isoprop for -1-
Water, sco ed ted ted ed cted cted yl- each 41-
Sugar toluene contam 43
Free found at inant
Rasbe 5.4 ppb type)
rry
Bev.
(1
liter)
Master 1 Spring New Stockbri >5700 Not Not Not Not Not Not 1.7 10 299 Level of
Choice† Water York dge, VT † Detec Detec Detect Dete Dete Detected (comp 863- HPC
(1.5 City ted ted ed cted cted osited) 942 bacteria
liters) (863 substantially
- exceeded
868) guideline.
Master 2 Spring New 1 of 10 No No No No No No test No 10 299 Bacterial
Choice† Water York bottles test test test test test test (indivi 869- overgrowth
(1.5 City had dually) 878 was
liters) HPC observed in
bacteri 1 of the 10
al bottles
overgr tested. The
owth† presence of
a large
number of
noncoliform
HPC
bacteria may
be inhibiting
the detection
of coliform
bacteria
during the
testing. See
text for
discussion
of HPC
bacteria.
Mendoc 1 Sparkl Berkel Mendoci Not Not Not Not Not Not Not Not 10 SA-
ino ing ey, no Bev., Detect Detec Detec Detect Dete Dete Detected Dete (comp 712-
Miner CA Comptc ed ted ted ed cted cted cted osited) 002
al he, CA 8
Water
(1
liter)
Natural 1 Spring Berkel Nat. 7,300† Not Not Not Not Not Not Not 10 SA- Level of
Value† Water ey, Value, Detec Detec Detect Dete Dete Detected Dete (comp 712- HPC
(1 CA Sacrame ted ted ed cted cted cted osited) 002 bacteria
gallon nto, CA, 9 substantially
) distrib. exceeded
guideline
applied to
bottled
water by
some states.
Naya 1 Canad Los Revelstr Not Not Not Not Not Not Not Not 3 (1 EQI
ian Angel oke, BC, Detect Detec Detec Detect Dete Dete Detected Dete for -1-
Natur es Canada ed ted ted ed cted cted cted each LA
al contam 15-
Spring inant LA
Water type) 17
(1
liter)
# on (if Tested
listed)
d) in 10 ppb
cfu/ml ppb)
in
ppb
Naya 2 Canad San Revelstr Not Not Not Not Not Not Not Not 10 SA-
ian Diego, oke, BC, Detect Detec Detec Detect Dete Dete Detected Dete (comp 712-
Spring CA Canada ed ted ted ed cted cted cted osited) 039
Water 6
(1
liter)
Naya 3 Canad New Revelstr Not Not Not Not Not Not Not Not 10 299
ian York oke, Detect Detec Detec Detect Dete Dete Detected Dete (comp 863-
Spring City B.C., ed ted ted ed cted cted cted osited) 942
Water Canada (927
(1.5 -
liter) 932)
Naya 4 Canad New Canada Not No No No No No No test No 10 299
ian York Detect test test test test test test (indivi 863-
Spring City ed dually) 942
Water (933
(1.5 -
liters) 942)
Niagara 1 Drinki San Irvine, 35 Not 8.5 3.7 3.1* 1.7 Not Not 10 SA- Bromodichl
* ng Diego, CA Detec Detected Dete (comp 712- ormethane
Water CA ted cted osited) 039 found above
(1 7 CA Prop. 65
gallon level.
)
Niagara 2 Drinki No test No 3.1 1.5 1.1 0.5 No test No 1 SA-
ng test test (indivi 901-
Water dual) 080
0
Niagara 3 Drinki No test No 1.6 0.9 0.7 Not No test No 8 SA-
ng test Dete test (comp 901-
Water cted osited) 080
0
Nursery 1 Drinki San Not 4.5 Not Not Not Not Not Not Toluene 3 (1 EQI Toluene and
ng Franci Detect ppb Detec Detect Dete Dete Detected Dete found at for -1- xylene are
Water, sco ed ted ed cted cted cted 12.4 each 47- constituents
sodiu ppb, o- contam 49 of gasoline
m free xylene inant and also
fluori at 3.2 type) used in
de ppb, some
added, styrene industrial
not at 3.0 chemicals.
sterile ppb
, use
as
direct
ed by
physic
ian or
by
labeli
ng
directi
ons
for
use in
infant
formu
la (1
gallon
)
Nursery 2 Drinki No test No Not Not Not Not No test No Toluene 10 SA-
ng test Detec Detect Dete Dete test at 0.57 (comp 807-
Water ted ed cted cted ppb osited) 007
9
Odwall 1 Geoth Berkel Trinity 1 3.8 Not Not Not Not Not Not Fluoride 10 SA- FDA and
a* ermal ey, Springs, Detec Detect Dete Dete Detected Dete found at (comp 712- California
Natur CA Davenp ted ed cted cted cted 1.5 osited) 003 bottled
al ort, CA ppm* 0 water
Spring regulations
Water impose a
(1 maximum of
liter) 1.4 ppm
fluoride in
areas with
annual
average high
temperature
s of >79.3
°F.
Odwall 2 No test 3.9 No No No No No test No Fluoride 10 SA- FDA and
a* test test test test test at 1.6 (comp 807- California
ppm* osited) 008 bottled
0 water
regulations
impose a
maximum of
1.4 ppm
fluoride in
areas with
annual
average high
temperature
s of >79.3
°F.
# on (if Tested
listed)
d) in 10 ppb
cfu/ml ppb)
in
ppb
Opal† 1 Spring Berkel Culver, 510† 2.4 Not Not Not Not Not Not Fluoride 10 SA- Level of
Water ey, OR Detec Detect Dete Dete Detected Dete found at (comp 712- HPC
(1.5 CA ted ed cted cted cted 0.16 osited) 003 bacteria
liter) ppm 1 exceeded
guideline
applied to
bottled
water by
some states.
Ozarka 1 Drinki Houst Houston 1 Not 2.2 1.8 0.4 Not Not Not 10 298
ng on, Municip Detec Dete Detected Dete (comp 08-
Water TX al Water ted cted cted osited) 965
Supply (960
-
965)
Ozarka 2 Drinki Houst Houston Not No No No No No No test No 10 298
ng on, Municip Detect test test test test test test (indivi 950-
Water TX al Water ed dually) 959
Supply
Paloma 1 Mount Los Palomar 2 5.8 Not Not Not Not Not 0.6 3 (1 EQI Arsenic
r* ain Angel Mountai ppb Detec Detect Dete Dete Detected for -1- level
Spring es n, ted ed cted cted each LA3 exceeds CA
Water Escondi contam -5 Prop. 65
(1 do, CA inant warning
liter) type) level.
Palomar 2 Mount Venic Palomar Not Not Not Not Not Not Not 0.6 10 SA-
ain e, CA Mountai Detect Detec Detec Detect Dete Dete Detected (comp 712-
Spring n, ed ted ted ed cted cted osited) 039
Water Escondi 8
(1.5 do, CA
liters)
Palomar 3 Mount Los Palomar No test Not No No No No No test No 10 SA-
ain Angel Mountai Detec test test test test test (comp 808-
Spring es n, ted osited) 166
Water Escondi 4
(1.5 do, CA
liters)
Pathmar 1 Spring New Guelph, 1 Not 2.4 Not Not 0.1 Not Not Bromof 10 299
k Water York Canada Detec Detect Dete Detected Dete orm (a (comp 863-
(1.5 City ted ed cted cted trihalom osited) 942
liters) ethane) (895
was -
found at 900)
2.2 ppb
Pathma 2 Spring New Guelph, 1 of 10 No No No No No No test No 10 299 Bacterial
rk† Water York Canada bottles test test test test test test (indivi 863- overgrowth
(1.5 City tested dually) 942 was
liters) contain (901 observed in
ed - 1 of the 10
HPC 910) bottles
bacteri tested. The
al presence of
overgr a large
owth† number of
noncoliform
HPC
bacteria may
be inhibiting
the detection
of coliform
bacteria
during the
testing. See
text for
discussion
of HPC
bacteria.
Pathmar 3 Spring New Guelph, Not No No No No No No test No 10 299
k Water York Canada Detect test test test test test test (indivi 863-
(1.5 City ed dually) 942
liters) (879
&
885-
893)
Perrier 1 Sparkl San Vergeze 19 Not Not Not Not Not Not 2.8 2- 3 (1 EQI Chlorotolue
ing Franci , France Detec Detec Detect Dete Dete Detected Chlorot for -1- ne of
Miner sco ted ted ed cted cted oluene each 44- unknown
al found at contam 46 origin
Water 4.6 ppb inant
(25 fl type)
oz.)
# on (if Tested
listed)
d) in 10 ppb
cfu/ml ppb)
in
ppb
Perrier 2 Sparkl Los Vergeze Not Not Not Not Not Not Not 2.6 2- 3 (1 EQI Chlorotolue
ing Angel , France Detect Detec Detec Detect Dete Dete Detected Chlorot for -1- ne of
Miner es ed ted ted ed cted cted oluene each LA unknown
al found at contam 36- origin.
Water 3.7 ppb inant LA
(25 fl type) 38
oz.)
Perrier 3 Sparkl San Vergeze Not Not Not Not Not Not Di(2- 4.3 No 10 SA- Exceeds 6
* ing Franci , France Detect Detec Detec Detect Dete Dete ethylhexyl detectio (comp 712- ppb tap
Miner sco ed ted ted ed cted cted )Phthalate n of 2- osited) 003 water
al detected at Chlorot 2 standard for
Water 12 ppb* oluene Di(2-
(1 ethylhexyl)
liter) phthalate
(DEHP), but
there is no
standard for
bottled
water for
this
chemical.
California
does not
allow this
DEHP level
in the source
water for
bottled
water, but
sets no
DEHP
standard for
finished
bottled
water.
Perrier 4 Sparkl San Vergeze No test No No No No No No test 4.1 No test 10 SA- Nitrate
ing Franci , France test test test test test (comp 808- retest.
Miner sco osited) 166
al 2
Water
Poland 1 Natur Washi 750† Not Not Not Not Not Not Not 10 298 HPC
Spring† al ngton, Detec Detec Detect Dete Dete Detected Dete (comp 808- bacteria
Spring DC ted ted ed cted cted cted osited) 965 found at
Water (819 levels
(1 - exceeding
liter) 824) guideline
applied by
some states
to bottled
water.
Poland 2 Natur Washi 5 of 10 No No No No No No test No 10 298 Bacterial
Spring† al ngton, bottles test test test test test test (indivi 808- overgrowth
Spring DC tested dually) 965 was
Water had (809 observed in
(1 HPC - 5 of the 10
liter) bacteri 818) bottles
al tested. The
overgr presence of
owth† a large
number of
non-
coliform
HPC
bacteria may
be inhibiting
the detection
of coliform
bacteria
during the
testing. See
text for
discussion
of HPC
bacteria.
Polar 1 Spring Washi Crystal Not Not 0.1 0.1 Not Not Not 0.8 Toluene 10 298 Toluene is
Water ngton, Springs, Detect Detec Dete Dete Detected detected (comp 808- often an
(1 DC Spring ed ted cted cted at 2.5 osited) 965 indicator of
gallon Grove, ppb, (851 the presence
) VT (well - of gasoline
below 856) or industrial
the chemicals,
standard here of
of 1000 unknown
ppb) origin.
Polar 2 Spring Washi Crystal Not No No No No No No test No 10 298
Water ngton, Springs, Detect test test test test test test (indivi 808-
(1 DC Spring ed dually) 965
gallon Grove, (841
) VT -
850)
Private 1 Drinki Los Not Not 47.1* 16.7* 20.1 10.3 Not 0.1 3 (1 EQI THM levels
Selectio ng Angel Detect Detec * * Detected for -1- violated CA
n* Water es ed ted each LA & industry
(Ralph' (1 contam 26- standards
s) gallon inant LA for bottled
) type) 27 water, and
chloroform,
bromodichlo
romethane,
and
dibromochlo
romethane
exceeded
CA Prop. 65
levels.
Private 2 Drinki Venic Ralph's 66 Not 22.3* 6.6 8.9* 6.8* Not Not 10 SA- THM levels
Selectio ng e, CA LA, Detec Detected Dete (comp 712- violated CA
n* Water distrib., ted cted osited) 039 & industry
) water, and
bromodichlo
romethane,
and
dibromochlo
romethane
exceeded
CA Prop. 65
levels.
Private 1 Natur Los Not Not Not Not Not Not Not 0.1 3 (1 EQI
Selectio al Angel Detect Detec Detec Detect Dete Dete Detected for -1-
n Spring es ed ted ted ed cted cted each LA
(Ralph's Water contam 34-
) (1 inant LA
gallon type) 35
)
# on (if Tested
listed)
d) in 10 ppb
cfu/ml ppb)
in
ppb
Private 1 Purifi San Ralph's Not Not 20.1* 8.4 7.4* 4.3* Not Not 10 SA- THM levels
Selectio ed Diego, LA, Detect Detec Detected Dete (comp 712- violated CA
n* Water CA distrib., ed ted cted osited) 058 & industry
) water, and
bromodichlo
romethane,
and
dibromochlo
romethane
exceeded
CA Prop. 65
levels.
Private 2 Purifi Los Ralph's No test No 10.4* 9.1 1.3 Not Not Not 10 SA- THM levels
Selectio ed Angel LA, test Dete Detected Dete (comp 808- violate CA
n* Water es distrib., cted cted osited) 166 &
(Ralph' (1 plant 5 industry/IB
s) gallon 06-178 WA
) standard for
bottled
water.
Publix† 1 Drinki Miami Not 1.3 45† 41 3.2 0.2 Not 0.8 Acetone 10 304 THM levels
ng , FL Detect Detected found at (comp 085- violate
Water ed 11 ppb osited) 165 industry/IB
(1 (no (085 WA
gallon std.); - standard of
) styrene 090) 10 ppb (no
found at longer
0.6 ppb enforceable
(below in FL)
std. of
100
ppb)
ng nd, FL test test found at (comp 436- violate
Water 14 ppb osite 37 industry/IB
(1 (no sample (36) WA
gallon standard ) standard of
) ) 10 ppb (no
longer
enforceable
in FL).
ng nd, FL test test found at bottle 436- violate
Water 16 ppb 37 industry/IB
(1 (no (37) WA
gallon standard standard of
) ) 10 ppb (no
longer
enforceable
in FL).
Publix 4 Drinki Miami Not No No No No No No test No No test 10 304
ng , Fl Detect test test test test test test (indivi 085-
(1 (304
gallon 091-
) 304
100)
Publix† 1 Purifi Miami 1 Not 15† 14† 0.9 Not Not Not Styrene 10 304 THM found
ed , FL Detec Dete Detected Dete found at (comp 085 at level
Water ted cted cted 0.2 ppb osited) (117 exceeding
(1 (below - 10 ppb
gallon std. of 122) industry/IB
) 100 WA
ppb) standard (no
longer
enforceable
in FL).
Styrene
from
unknown
source.
Publix† 2 Purifi Miami 5 of 10 No No No No No No test No No test 10 304 Bacterial
ed , FL bottles test test test test test test bottles 085- overgrowth
Water tested (indivi 165 was
(1 contain dualy) (304 observed in
gallon ed 123- 5 of the 10
) HPC 304 bottles
"bacter 132) tested. The
ial presence of
overgr a large
owth"† number of
non-
coliform
HPC
bacteria may
be inhibiting
the detection
of coliform
bacteria
during the
testing. See
text for
discussion
of HPC
bacteria.
Puritas 1 Drinki Los Grt. Not 3.2 Not Not Not Not Not Not 3 (1 EQI
ng Angel Sprg. Detect Detec Detect Dete Dete Detected Dete for -1-
Water es Waters ed ted ed cted cted cted each LA1
(1 of contam -
gal.) America inant LA2
, type)
Milpitas
, CA
Puritas 2 Drinki Berkel Grt. 990† Not Not Not Not Not Results Not 10 SA- Level of
† ng ey, Sprg. Detec Detec Detect Dete Dete not Dete (comp 712- HPC
Water CA Waters ted ted ed cted cted received cted osited) 003 bacteria
(1 of 3 substantially
gallon America exceeded
) , guideline.
Milpitas
, CA
# on (if Tested
listed)
d) in 10 ppb
cfu/ml ppb)
in
ppb
Ralph's 1 Mount Los "Califor Not Not Not Not Not Not Not 0.8 3 (1 EQI
ain Angel nia Detect Detec Detec Detect Dete Dete Detected for -1-
Spring es Mountai ed ted ted ed cted cted each LA
Water ns," contam 28-
(1.5 L.A., inant LA
liter) CA, type) 30
distrib.
Ralph's 2 Mount San "Califor 270 Not Not Not Not Not Not 0.6 10 SA-
ain Diego nia Detec Detec Detect Dete Dete Detected (comp 712-
Spring Mountai ted ted ed cted cted osited) 058
Water ns" 3
(1.5
liters)
Randalls 1 Remar Houst Buck Not Not 0.4 Not Not Not Not Not Bromof 10 298
kable on, Springs, Detect Detec Detect Dete Dete Detected Dete orm (a (comp 808-
Drinki TX Jasper, ed ted ed cted cted cted trihalom osited) 965
ng TX ethane) (895
Water found at -
(1 0.4 ppb 900)
gallon
)
Randalls 2 Remar Houst Buck Not No No No No No No test No 10 298 HPC retest
kable on, Springs, Detect test test test test test test bottles 808- found none.
Drinki TX Jasper, ed (indivi 965
ng TX dually) (885
Water -
(1 894)
gallon
)
Randall 1 Deja Houst City of >5700 Not 29.6† 14 12 3.6 Not Not 10 298 Levels of
s† Blue on, Irving † Detec Detected Dete (comp 808- TTHM
Drinki TX Water ted cted osited) 965 exceed
ng Supply (911 IBWA/indus
Water - try standards
(1 916) (not
liter) enforceable
in TX).
Randalls 2 Deja Houst City of Not No No No No No No test No 10 298
Blue on, Irving Detect test test test test test test bottles 808-
Drinki TX Water ed (indivi 965
ng Supply dually) (901
Water -
(1 910)
liter)
Rocky 1 Drinki Los "Deep Not Not Not Not Not Not Not Not 3 (1 EQI
Mountai ng Angel Well Detect Detec Detec Detect Dete Dete Detected Dete for -1-
n Water, es Water" ed ted ted ed cted cted cted each LA
non- contam 31-
carbo inant LA
nated type) 33
(1.5
liter)
Rocky 2 Drinki San Santa Fe Not Not Not Not Not Not Not Not 10 SA-
Mountai ng Dimas Springs, Detect Detec Detec Detect Dete Dete Detected Dete (comp 712-
n Water, , CA CA ed ted ted ed cted cted cted osited) 058
non- 4
carbo
nated
(1.5
liters)
S. 1 Sparkl San San Not Not Not Not Not Not Not Not 3 (1 EQI
Pellegri ing Franci Pellegri Detect Detec Detec Detect Dete Dete Detected Dete for -1-
no Natur sco no, Italy ed ted ted ed cted cted cted each 38-
al contam 40
Miner inant
al type)
Water,
bottle
d at
the
source
(25.3
oz.)
S. 2 Sparkl San San Not Not Not Not Not Not Not Not Fluoride 10 SA-
Pellegri ing Franci Pellegri Detect Detec Detec Detect Dete Dete Detected Dete found at (comp 712-
no Natur sco no, Italy ed ted ted ed cted cted cted 0.37 osited) 003
al ppm 4
Miner (below
al standard
Water )
(1
liter)
# on (if Tested
listed)
d) in 10 ppb
cfu/ml ppb)
in
ppb
Safewa 1 Drinki Berkel Municip 8,500† Not 35.1* 31* 4.1* Not Not Not Fluoride 10 SA- THM found
y*† ng ey, al Detec Dete Detected Dete found at (comp 712- at level
(CA) Water CA Source, ted cted cted 0.81 osited) 021 above CA &
(1 Safeway ppm 4 industry
gallon Inc., (above bottled
) Oakland standard water
, CA, in warm standards;
distrib. weather chloroform
areas) and
bromodichlo
romethane
(BDCM)
found at
levels above
CA Prop. 65
limits.
Fluoride at
level above
FDA & state
limit for
areas with
av. high
temp.
>79.3°F.
HPC
bacteria
above
guideline
adopted by
some states
for bottled
water.
Safewa 2 Drinki 51,000 No 37* 35* 2.3 Not No test No 10 SA THM found
y* (CA) ng † (1 test Dete test (comp 807- at level
Water bottle) cted osited 008 above CA &
12,000 for 1 industry
†(1 chemic bottled
bottle) al water
2-21 (4 analysi standards,
bottles s) and
) 10 chloroform
Not (indivi found at a
Detect dually level above
ed in 4 for CA Prop. 65
bottles bacteri limit.
(see a Retests of
notes) analysi individual
s) bottles that
were
initially
found to
contain
51,000
cfl/mu and
12,000
cfl/mu
found no
HPC and
6,000
cfu/ml,
respectively,
though these
results are
unreliable
since they
were
retested
beyond
EPA-
mandated
"hold time"
after
opening.
Safeway 1 Key San Not Not Not Not Not Not Not 0.5 3 (1 EQI
(CA) Lime Franci Detect Detec Detec Detect Dete Dete Detected for -1-
Sparkl sco ed ted ted ed cted cted each 13-
ing contam 15
Water inant
(1 type)
quart)
Safewa 1 Purifi San >5,700 Not 26.4* 26.4* Not Not Not 0.1 Total 3 (1 EQI Coliforms,
y*† ed Franci † Detec Dete Dete Detected colifor for -1- HPC
(CA) Water sco ted cted cted ms each 7-9 bacteria,
(1 count contam trihalometha
gallon 5*; inant nes, and
) Toluene type) chloroform
found at exceed
8.4 ppb guidelines/st
andards.
Toluene is a
constituent
of gasoline
and
industrial
chemicals
that should
be removed
if treated
with reverse
osmosis.
Label claims
"prepared
by
deionization
and/or
reverse
osmosis."
Could have
been added
during
processing.
Safewa 2 Purifi San Municip 4 Not 42.5* 39* 3.5* Not Not Not Toluene 10 SA- THM levels
y* (CA) ed Franci al Detec Dete Detected Dete not (comp 712- violate CA
Water sco/ Source, ted cted cted detected osited) 058 & industry
(1 Berkel Safeway , 5 standards
gallon ey, , colifor for bottled
) CA Oakland ms not water.,
, CA, detected chloroform
distrib. and
bromodichlo
romethane
exceeded
CA Prop. 65
levels.
Safewa 1 Select Berkel Safeway Not Not 53.3* 50* 3.3* Not Not Not Fluoride 10 SA- THM levels
y* (CA) Club ey, , Detect Detec Dete Detected Dete found at (comp 712- violate CA
Soda CA Oakland ed ted cted cted 0.64 osited) 021 & industry
(2 , CA, ppm, 5 standards
liter) distrib. below for bottled
std. water.
Chloroform
and
bromodichlo
romethane
exceeded
CA Prop. 65
levels.
Safewa 2 Select No test No 25* 24* 0.54 Not No test No 10 SA- Chloroform
y* (CA) Club test Dete test (comp 807- level
Soda cted osited) 008 exceeds CA
2 Prop. 65
level;
Trihalometh
ane levels
over CA &
industry
standards.
Safewa 1 Select Berkel Safeway Not Not 36.1* 34* 2.1 Not Not Not Fluoride 10 SA- THM levels
y*† Seltze ey, , Detect Detec Dete Detected Dete found at (comp 712- violate CA
(CA) r CA Oakland ed ted cted cted 0.83 osited) 021 & industry
Water , CA, ppm* 6 standards.
(2 distrib. above Chloroform
liter) warm level
weather exceeds CA
std. for Prop. 65
added level.
fluoride Fluoride
above 0.80
CA std. for
areas with
av. high
>79.3°F (if
fluoride
added; if
natural,
warm
weather area
standard is
1.4 ppm);
identical
FDA
standard
does not
apply to
seltzer (not
defined as
"bottled
water").
Safewa 2 Select No test No 21* 21* Not Not No test No 10 SA- THM levels
y* (CA) Seltze test Dete Dete test (comp 807- violate CA
r cted cted osited) 008 & industry
Water 3 standards,
chloroform
level
exceeds CA
Prop. 65
level.
Safewa 1 Spring San >5700 Not 56.8* 53.3* 3.5* Not Not Not Toluene 3 (1 EQI Toluene and
y*† Water Franci † Detec Dete Detected Dete found at for -1- o-xylene are
(CA) "Espe sco ted cted cted 14.2 each 10- constituents
cially ppb; contam 12 of gasoline
select o- inant and
ed for xylene type) industrial
its at 3.1 chemicals.
Natur ppb, This water
al both apparently
Purity below was
" (1 standard chlorinated,
gallon s suggesting
) that it could
be tap water
or if it is
spring
water, it was
subjected to
chlorination.
Levels of
TTHMs
exceeded
CA &
industry
standard;
level of
chloroform
exceeds CA
Prop. 65
level; HPC
exceeded
guidelines.
# on (if Tested
listed)
d) in 10 ppb
cfu/ml ppb)
in
ppb
Safewa 2 Spring Berkel Safeway 15 Not 24.9* 23* 1.9 Not Invalid Not Fluoride 10 SA- THM levels
y* (CA) Water ey, , Detec Dete Dete found at (comp 712- violate CA
(1 CA Oakland ted cted cted 0.28 osited) 021 & industry
gallon , CA, ppm, 7 standards.
) distrib. below Chloroform
std.; no level
toluene exceeds CA
or Prop. 65
xylene level.
found
Safeway 3 Spring Berkel Safeway No test No No No No No Not No No test 10 SA Retest for
(CA) Water ey, , test test test test test Detected test (comp 801- phthalate
(1 CA Oakland osited) 036 and
gallon , CA, 4 semivolatile
) distrib. organics,
not
detected.
Safeway 1 Refres Washi Safeway Not Not Not Not Not Not Not 0.7 10 298
(DC) he ngton, Spring, Detect Detec Detec Detect Dete Dete Detected (comp 808-
Natur DC NY ed ted ted ed cted cted osited) 965
al (835
Spring -
Water 840)
(16.9
oz.)
Safeway 2 Refres Washi Safeway 1 of 10 No No No No No No test No 10 298 Bacterial
(DC) he ngton, Spring, bottles test test test test test test bottles 808 overgrowth
Natur DC NY tested (indivi 965 was
al had dually) (825 observed in
Spring overgr - 1 of the 10
Water owth 834) bottles
(16.9 of tested. The
oz.) HPC presence of
bacteri a large
a number of
non-
coliform
HPC
bacteria may
be inhibiting
the detection
of coliform
bacteria
during the
testing. See
text for
discussion
of HPC
bacteria.
Safeway 1 Safew Washi Tower Not Not Not Not Not Not Not Not Toluene 10 298 Toluene is a
(DC) ay ngton, City, PA Detect Detec Detec Detect Dete Dete Detected Dete found at (comp 808- constituent
Spring DC ed ted ted ed cted cted cted 4.7 ppb osited) 965 of gasoline
Water ( below (863 and
(1 the - industrial
gallon standard 868) chemicals,
) of 1000 although its
ppb) source here
is unknown.
Safeway 2 Safew Washi Tower Not No No No No No No test No 10 298
(DC) ay ngton, City, PA Detect test test test test test test (comp 808
Spring DC ed osited) 965
Water (857
(1 -
gallon 862,
) 917)
Sahara 1 Drinki Los 1 Not 37.9* 14.7* 14.9 8.3* Not 1.1 3 (1 EQI THM levels
* ng Angel Detec Detected for -1- violated CA
Water, es ted each LA9 & industry
"Prem contam -11 standards
ium" inant for bottled
(50.7 type) water, and
oz.) chloroform,
bromodichlo
romethane,
and
dibromochlo
romethane
exceeded
CA Prop. 65
levels.
Sahara 1 Mount San Bear Not Not 15.9* 6.5* 6.6* 2.8 Not 2.5 Fluoride 10 SA- THM levels
* ain Diego/ Spec. & Detect Detec Detected at 0.54 (comp 712- violated CA
Spring San Mktg., ed ted ppm osited) 058 & industry
Water Marco San 6 standards
(1.5 s, CA Bernadi for bottled
liter) no, CA, water, and
distrib. chloroform
and
bromodichlo
romethane
exceeded
CA Prop. 65
levels.
Save the 1 Natur Berkel Baxter Not Not Not Not Not Not Not Not 10 SA-
Earth al ey, Springs, Detect Detec Detec Detect Dete Dete Detected Dete (comp 712-
Spring CA CA ed ted ted ed cted cted cted osited) 021
Water 8
(1
liter)
Schwep 1 Club San Cadbury Not Not 7.7 7.7 Not Not Invalid Not Fluoride 10 SA-
pes Soda Franci Bev., Detect Detec Dete Dete test Dete found at (comp 712-
(1 sco, Stamfor ed ted cted cted cted 0.13 osited) 021
liter) CA d, CT ppm, 9
well
below
standard
# on (if Tested
listed)
d) in 10 ppb
cfu/ml ppb)
in
ppb
Schwep 2 Club San Dr. No test No No No No No Not No 10 SA Retest of
pes Soda Franci Pepper/ test test test test test Detected test (comp 801- semivolatile
(1 sco Seven osited) 036 organics,
liter) Up, Inc., 0 including
Dallas, phthalate,
TX found none.
Schwep 1 Seltze Berkel Cadbury Not Not Not Not Not Not Invalid Not Fluoride 10 SA-
pes r ey, Bev., Detect Detec Detec Detect Dete Dete test Dete found at (comp 712-
Water CA Stamfor ed ted ted ed cted cted cted 0.28 osited) 022
(1 d, CT ppm, 0
liter) well
below
standard
Schwep 2 Seltze San Dr. No test No No No No No Not No 10 SA Retest of
pes r Franci Pepper/ test test test test test Detected test (comp 801- semivolatile
Water sco Seven osited) 036 organics,
(1 Up, Inc., 1 including
liter) Dallas, phthalate,
TX found none.
Shasta 1 Sparkl Berkel Shasta Not Not Not Not Not Not Results Not Fluoride 10 SA-
ing ey, Bev., Detect Detec Detec Detect Dete Dete not Dete found at (comp 712-
Club CA Haywar ed ted ted ed cted cted received cted 0.19 osited) 022
Soda d, CA, ppm, 1
(2 distrib. well
liters) below
standard
Shasta 2 Sparkl Berkel Shasta No test No No No No No Not No 10 SA Retest of
ing ey, Bev., test test test test test Detected test (comp 801- semivolatile
Club CA Haywar osited) 036 organics,
Soda d, CA, 5 including
(2 distrib. phthalate,
liters) found none.
Sparkle 1 Crysta Los McKess 3600† Not Not Not Not Not Not 0.1 3 (1 EQI Heterotrophi
tts† l Angel on Detec Detec Detect Dete Dete Detected for -1- c Plate
Fresh es Water ted ted ed cted cted each LA Count
Drinki Prods., contam 12- Bacteri
ng Pasaden inant LA (HPC)
Water a, CA type) 14 exceeded
-- guideline.
"Meet
or
Excee
d all
State
and
Feder
al
Water
Qualit
y
Stand
ards"
(1
liter)
Sparklet 2 Crysta Venic McKess 140 Not Not Not Not Not Not Not 10 SA- HPC level
ts l e, CA on Detec Detec Detect Dete Dete Detected Dete (comp 712- below
Fresh Water ted ted ed cted cted cted osited) 058 guidelines in
Drinki Prods., 7 retest.
ng Pasaden
Water a, CA
--
"Meet
or
Excee
d all
State
and
Feder
al
Water
Qualit
y
Stand
ards"
(1
liter)
Sparklet 1 Distill Venic McKess 190 Not Not Not Not Not Not Not 10 SA-
ts ed e, CA on Detec Detec Detect Dete Dete Detected Dete (comp 712-
Drinki Water ted ted ed cted cted cted osited) 058
ng Prods., 8
Water Pasaden
(1 a, CA
gallon
)
Sparkle 1 Mount Los McKess >5700 Not Not Not Not Not Not 0.6 3 (1 EQI Heterotrophi
tts† ain Angel on † Detec Detec Detect Dete Dete Detected for -1- c Plate
Spring es Water ted ted ed cted cted each LA Count
Water Prods., contam 18- Bacteria
(33.8 Pasaden inant LA (HPC)
oz.) a, CA type) 20 exceeded
guideline.
Sparklet 2 Mount Venic McKess Not Not Not Not Not Not Not Not 10 SA- HPC Not
ts ain e, CA on Detect Detec Detec Detect Dete Dete Detected Dete (comp 712- Detected.
Spring Water ed ted ted ed cted cted cted osited) 058
Water Prods., 9
(1 Pasaden
liter) a, CA
# on (if Tested
listed)
d) in 10 ppb
cfu/ml ppb)
in
ppb
Sparklin 1 (1.5 Chica Not Not Not Not Not Not Not 3.1 10 297
g liter) go, IL Detect Detec Detec Detect Dete Dete Detected (comp 719-
Springs ed ted ted ed cted cted osited) 48
(37-
42)
Sparklin 2 (1.5 Chica Not No No No No No No test 9 297
g liter) go, IL Detect test test test test test (indivi 790
Springs ed dually) 836
(819
-
827)
Vittel* 1 Miner Berkel Vittel Not 11* 9.3 9.3 Not Not Not Not 10 SA- Arsenic
al ey, Bonne Detect Dete Dete Detected Dete (comp 712- level
Water CA Source ed cted cted cted osited) 022 exceeds CA
(1.5 Well, 2 Prop. 65
liter) Vittel, level and
France WHO/EU
arsenic
water limit.
Vittel* 2 Miner San No test 13 No No No No No test No No test 10 SA- Arsenic
al Franci ppb test test test test test (comp 901- exceeds CA
Water sco osited) 079 Prop. 65
9 level and
WHO/EU
water limit.
Volvic* 1 Natur Berkel Clairvic 11 14* Not Not Not Not Results 1.3 Fluoride 10 SA- Arsenic
al ey, Spring, Detec Detect Dete Dete not found at (comp 712- level
Spring CA Volvic, ted ed cted cted received 0.17 osited) 022 exceeds CA
Water France ppm, 3 Prop. 65
(1.5 well level and
liter) below WHO/EU
standard arsenic
water limit.
Volvic* 2 Natur Berkel Clairvic No test 12* No No No No No test No No test 10 SA- Arsenic
al ey, Spring, test test test test test (comp 808- level
Spring CA Volvic, osited) 166 exceeds CA
Water France 7 Prop. 65
(1.5 level and
liter) WHO/EU
arsenic
water limit.
Volvic 3 Natur Berkel Clairvic No test No No No No No Not No 10 SA Retest of
al ey, Spring, test test test test test Detected test (comp 801- semivolatile
Spring CA Volvic, osited) 036 organics,
Water France 2 including
(1.5 phthalate,
liter) found none.
Vons 1 Drinki Los Vons Not Not Not Not Not Not Not Not 3 (1 EQI
ng Angel LA, Detect Detec Detec Detect Dete Dete Detected Dete for -1-
Water es distrib. ed ted ted ed cted cted cted each LA
(1 contam 24-
gallon inant LA
) type) 25
Vons 2 Drinki San Vons Not Not Not Not Not Not Test Not 10 SA-
ng Diego/ LA, Detect Detec Detec Detect Dete Dete invalid Dete (comp 712-
Water San distrib. ed ted ted ed cted cted cted osited) 059
(1 Marco plt. 06- 0
gallon s, CA 2796
)
Vons 3 Drinki Los Vons No test No No No No No Not No 10 SA Retest of
ng Angel LA, test test test test test Detected test (comp 801- semivolatile
Water es distrib. osited) 036 organics,
(1 plt. 06- 3 including
gallon 2796 phthalate,
) found none.
Vons 1 Natur Los Vons Not Not Not Not Not Not Not 0.6 3 (1 EQI
al Angel LA, Detect Detec Detec Detect Dete Dete Detected for -1-
Spring es distrib. ed ted ted ed cted cted each LA
Water contam 21-
(1 inant LA
liter) type) 23
Vons 2 Natur San Vons 1.0 Not Not Not Not Not Not 0.7 10 SA-
al Diego/ Co. LA, Detec Detec Detect Dete Dete Detected (comp 712-
Mount San distrib. ted ted ed cted cted osited) 059
ain Marco 1
Spring s, CA
Water
(1
liter)
Vons 1 Purifi San Vons 1 Not Not Not Not Not Not Not 10 SA
ed Diego/ LA, plt. Detec Detec Detect Dete Dete Detected Dete (comp 712-
Water San 06-2796 ted ted ed cted cted cted osited) 080
(1 Marco 5
gallon s, CA
)
Yosemit 1 Drinki Los Highlan 1100† Not Not Not Not Not Not 1.3 10 SA Level of
e ng Angel d Park, Detec Detec Detect Dete Dete Detected (comp 712- HPC
Waters Water es CA ted ted ed cted cted osited) 080 bacteria
† (5 /Santa 6 exceeds
gallon Monic guidelines.
s) a
Zephyrh 1 Distill Miami Not Not Not Not Not Not Not Not 10 304
ills ed , FL Detect Detec Detec Detect Dete Dete Detected Dete (comp 085-
Water ed ted ted ed cted cted cted osited) 165
(1 (133
gallon -
) 138)
Note: These tests used established FDA- or EPA-approved test methods, but are not necessarily
statistically representative of all bottled water of the brand listed. See text for further discussion.
a Row with bold name indicates level exceeding standard or guideline: asterisk {*} indicates exceeds
enforceable standard; dagger {†} indicates exceeds unenforceable guideline. See text and accompanying
Technical Report (print report only).
b As discussed in the text, the California Proposition 65 ("Prop. 65") levels noted in this table are
derived from the "No Significant Risk" levels established by the California Department of Health
Services, and are based on the CDHS’s rules’ assumption that people drink 2 liters of water per day (the
same assumption used by the U.S. EPA). Thus, for example, the Arsenic Proposition 65 level is 10
micrograms per day, so assuming 2 liters of water consumed per day, the Prop. 65 Arsenic level is 5 ppb.
c There is no enforceable FDA standard for HPC bacteria. We use 500 cfu/ml as an informal guideline.
HPC bacteria are not necessarily harmful themselves but are often used as an indicator of overall
sanitation during bottling. The European Union (EU) has adopted an enforceable bottled water standard
of 100 colonies per 100 ml (at 22oC) at bottling. EPA’s tap water rules provide that water containing
over 500 cfu/ml is treated as a coliform-positive sample absent proof of adequate disinfectant residual.
The International Bottled Water Association recommends plants meet a level of <30 cfu/ml at bottling,
and <200 cfu/ml in 90% of samples tested 5 days after bottling. Massachusetts and New York have an
informal bottled water guideline (unenforceable) of 500 cfu/ml. Other states (such as RI) also have
informal guidelines.
d Federal tap water and bottled water standards for arsenic, originally set in 1942 and not revised since,
is 50 ppb. Congress has required updated standard by 2001. International (WHO/EU) standard is 10 ppb
(see text).
e TTHMs are "total trihalomethanes," potentially cancer-causing chemicals created when organic matter
reacts with chlorine. Recent studies also indicate TTHMs may also be linked to birth defects and
spontaneous abortions. While California and International Bottled Water Association (industry trade
association) standard is 10 ppb, new Federal tap water standard is 80 ppb, and FDA bottled water
standard is 100 ppb (see text).
f BDCM is bromodichloromethane, a type of trihalomethane (see above).
g DBCM is dibromochloromenthane, a type of trihalomethane (see above).
Note re Crystal Geyser: The Crystal Geyser company has provided NRDC with test results indicating
that beginning in April 1999, Crystal Geyser substantially reduced the arsenic levels in its spring water,
in an agreement reached after they were sued (based on NRDC's previous test results) by the
Environmental Law Foundation, a California Public Interest Group. This testing shows that as of April
1999, arsenic is either not found, or, if present, is found at levels between non-detectable (<2 ppb) and
4.8 ppb, maximum. These levels are below the California Proposition 65 arsenic warning level of 5 ppb
and well below current federal standard, but EPA recently has proposed to drop the federal drinking
water standard to 5 ppb.
Appendix B
DOCUMENTED WATERBORNE DISEASE FROM

BOTTLED WATER
The bottled water industry (through IBWA) flatly denies that bottled water has ever caused
a disease outbreak--going so far as to assert that the Centers for Disease Control and
Prevention (CDC) has found that there has never been an outbreak of waterborne disease
from bottled water.1 However, such outbreaks from contaminated bottled water have
indeed occurred and are well documented by CDC and others in the scientific literature.
For example, in a published 1996 study of waterborne disease in the United States, the
CDC reported a 1994 outbreak of cholera associated with bottled water that occurred in
Saipan, U.S. territory in the Marianas Islands in the Pacific.2 FDA bottled water standards
apply to this U.S. territory to the same extent that they would in any U.S. state.3 While there
was not a full epidemiological study of all those who drank the water, CDC reported that at
least 11 were known to have become ill, and 4 were hospitalized with serious cases of
cholera.4 The brand of water involved was not named.5 According to an unpublished
Waterborne Disease Outbreak report on this outbreak filed with CDC by local public-health
officials, approximately one third of the island residents drink water from the company
involved, and "thousands" of people may have been exposed.6 The total number of people
who became ill is unknown.
The bottled water plants producing the water involved in this outbreak reportedly obtain
their water from municipal water (some of the wells used tested positive for fecal coliform
bacteria), but they supposedly then treat the water with state-of-the-art treatment using
reverse osmosis.7 While the bottles used were supposed to have been cleaned by machine
or manually with hot water and a chlorine solution, the bottling plants had, according to
CDC, "occasionally been cited for the cursory handling of returned bottles (e.g., for only
rinsing them with treated water.")8 The CDC reported that during the outbreak, bottled
water tested positive for fecal coliform, but the actual source of the bacterial
contamination in the bottled water was not determined.9
Another well-documented cholera outbreak, which occurred in Portugal, was due to the
use of bottled water from a contaminated source.10 The outbreak occurred in the mid-
1970s, but demonstrates the continuing potential for contaminated bottled water to spread
waterborne disease. According to a study of the affected population, there were 2,467
bacteriologically confirmed hospitalized cases of cholera, of whom 48 died.11 While
apparently bottled water was not the only cause of the outbreak, at least 82 patients had a
history of drinking bottled water from the contaminated source.12 In addition, 36 cholera
victims had visited the spa that was fed with the same source as used for bottled water.13 It
was believed that the limestone aquifer was contaminated by broken sewers from a nearby
village.14
Historically, other cases of illness from bottled water have been documented in the
scientific literature. For example, there are published reports showing that bottled water
was the causative agent not only in the outbreaks of cholera just noted, but also illnesses
from typhoid15 and "traveler's disease."16
Notes
1. See, e.g., International Bottled Water Association, "Frequently Asked Questions," (1997).
2. M.H. Kramer, et al., "Surveillance for Waterborne-Disease Outbreaks -- United States, 1993-1994," Centers for Disease
Control & Prevention Surveillance Summaries, Morbidity and Mortality Weekly Report, vol. 45, no. SS-1, pp. 1-31 (April
12, 1996).
3. See, 21 U.S.C. § 321(a).
4. Ibid.
5. Ibid.
6. Waterborne Disease Outbreak Report Form, filed with CDC by Division of Public Health, Commonwealth of the
Northern Marianas Islands, dated January 3, 1995.
7. M.H. Kramer, et al., "Surveillance for Waterborne-Disease Outbreaks -- United States, 1993-1994," Centers for Disease
Control & Prevention Surveillance Summaries, Morbidity and Mortality Weekly Report, vol. 45, no. SS-1, pp. 1-31 (April
12, 1996).
8. Ibid.
9. Ibid.
10. P.A. Blake, et al., "Cholera in Portugal, 1974. II. Transmission by Bottled Water," American J. Epidemiology, vol. 105,
pp. 344-48 (1977).
11. P.A. Blake, et al., "Cholera in Portugal, 1974. I. Modes of Transmission." American J. Epidemiology, vol. 105, pp. 337-
43 (1977).
12. Ibid.
13. Ibid.
14. .Ibid.
15. D.W. Warburton, "A Review of the Microbiological Quality of Bottled Water Sold in Canada. Part 2. The Need for More
Stringent Regulations," Canadian J. Microbiology, vol. 39, pp. 158-168 (1993), citing R. Buttiaux, "La Surveillance
Bacteriologique Des Eaux Minerales en Bouteilles et en Boites," Ann. Instit. Pasteur Lille, vol. 11, pp. 23-28 (1960).
16. D.W. Warburton, "A Review of the Microbiological Quality of Bottled Water Sold in Canada. Part 2. The Need for More
Stringent Regulations," Canadian J. Microbiology, vol. 39, pp. 158-168 (1993).
Appendix C
SUMMARY: STATE BOTTLED WATER
PROGRAMSa
Surve State Bottle Regs. State Addi Enforc Viola Illne Testing State Conta State Notes
y Staff d More/ Regul tiona ement tions ss & Permit minant Recom
Quest or Water Less ates l Action Data Rep Source Progr Posing mende
ions Budg Surve Strict BW Labe s Repo orte Certifica am? Most d
et y? vs. Not ling Repor rted? d? tion Threat Chang
Dedi FDA? Reg’d Requ ted? Require ? es
cated by ire- ments? Needed
to FDA? ment ?
Bottl s?
ed (FDA
Wate +)
r
Prog
ram?
Alaba <1 No = No No No. No No =FDA Yes No No

ma FTE FDA Two comme recom
volunt nt mendati
ary ons at
recalls this
time.
Alask None No =EPA Intrast No No No No =Fed.; Yes Microb FDA

a IBWA ate, Must iologic needs
,& carbo comply al definiti
FDA nated, with on of
Codes flavor Class A "glacier
; ed drinking water";
Alask waters water Annual
a does regula reqts per chemic
not ted SDWA al &
requir under radiolo
e same gical
annual standa contami
testing rds as nants
for bottle testing
chemi d should
cals & water be
radioa elimina
ctive ted:
conta tests are
minan expensi
ts ve and
not
necessa
ry.
Arizo 1/2 No =+IB Intrast No No No No =FDA; State Known Annual

na FTE WA ate Require Certifi carcino inspecti
Code; regula chemical, cation gens, ons;
= ted radiologi bacteri Need
FDA same cal and a more
as microbial regiona
interst testing; l
ate verified approac
by twice- h to
yearly chemic
inspectio al &
ns biologi
cal
testing
b/c not
all
contami
nants
found
in all
areas.
Arkan None Yes; = Arkan No No No No =FDA; Yes; Colifor Biennia

sas Data FDA sas Bottlers Renew m l
more regula must get ed bacteri inspecti
like tes all approval yearly a, on
lists of bottle on water giardia, (contact
lab d source, other with
results water filtration bacteri FDA).
within & a
state chlorinati
on (or
other
sanitatio
n
method)
Califo 2 Not in Stricte No Must State No Yes[ Stricter Yes; Parasit No IBWA
b]
rnia FTE; last r comm list has access than Renew es, comme Code
9 11/2 (THH ent sourc separat to FDA; ed cryptos nt Stricte
inves years M, from e, e specif Water annuall poridiu r
tigato disinf state inclu investi ic analysis y; m standa
rs ection (but ding gative violati required Water rds &
state- rules) regula muni arm; ons to renew analysi warnin
wide tions cipal; Fines annual s must g
appear Label have license; be labels
to ing been Licenses submit for
cover must impose for plants ted many
such agree d; No and each conta
waters with shutdo source year minant
) sourc wns or are site- s
e recalls specific;
listed Any
changes
must be
submitte
d and
approved
by state
Color <1 No = No No Yes; Small No Bottlers Yes Nitrate Many

ado FTE FDA, Regula # of must s of our
EPA tory violati meet concern
drinki action ons; state s were
ng mostly Data reqts, address
water; for not almost ed
Bottle heavy availa identical w/passa
rs metal ble to EPA ge of
must or drinking latest
keep THMs; water FDA
record No standards labeling
s of "seriou for regs;
requir s" source Before
ed lab enforc water that,
analys ement (includes misbran
is; actions well and ding on
Recor taken; spring labels
ds No construct was a
must shutdo ion) concern
meet wns or
EPA recalls
drinki
ng
water
requir
ement
s
Conne $50,0 No = CT Separ Must Same No No No VOCs None

cticut 00 FDA licens ate request as resp response respon from
+IBW es & state specifi above onse se undergr
A regs regs c ound
Code; all inform fuel
State manuf ation tanks
code acture and
based rs of compa
on non- nies
Fed. alcoho using
Stand lic freedo
ards bevera m of
(21 ges inform
CFR sold ation
129, in law
103) state
and
EPA
Delaw None No No Delaw No No No; No No state No No Pendin No

are active are Any requirem comme g the bottler
regula does violati ents nt start up s in
tory not ons of in- DE
oversi have a would state
ght or state be bottlers,
permit progra record the
progra m for ed in state
m; No bottle home would
separa d state need to
te water develop
state &
code implem
ent a
state
BWP
Distri None No =FDA No No No No No DC reqs No Chemic Proper

ct of bottlers als, labeling
Colu to send bacteri so that
mbia copy of a, labels
most waste are
recent contam accurat
inspectio inants e, not
ns of mislead
water ing;
source in Bottled
DC; water
Agency used for
is new, babies
but will & other
eventuall at-risk
y adopt groups
FDA should
inspectio be
n clearly
policies labeled
Florid 2 Food =FDA Intrast No No Listed No =FDA; Yes; No None IBWA

a FTE Lab. ate in Inspectio Renew comme Code
collect sales record ns and able nt
s s at analytica annuall
rando Dept. l results y
m of conducte
sample Agric. d in field
s from ; No
food datab
shelve ase
s
Georg None Pestici =+FD GA No Yes; GA No GA No No None;

ia dedic de A; GA regula Some worki answ issues answer proble "Bottle
ated analysi regs tes all springs ng on er starter ms d water
speci s on used bottle have datab kits for w/che as a
ficall end- to be d, exceed ase bottlers mical; food is
y to produc much flavor ed for Some probabl
BWP t on more ed, radioac sampl bacteri y one
rando string carbo tive ing ologica of the
m ent nated limits: result l safest
basis water use s; items
denied Sum on the
or mary market"
shutdo of
wn violati
ons
not
feasib
le at
this
time
Hawai <1/5 Yes; =FDA No Yes Not in Info No Source Yes; Microb No <10
i FTE Hawaii ; Used (not past 4 availa must be Renew iologic comme bottler
sample to specif yrs; ble approved able al nt at s in
s have ied) Recalls throu , then every 2 contam this state
bottled stricte in past gh license/ yrs; ination time
water r laws b/c of FOI permit Sampl in
produc than too reque issued e end- source
t on FDA much st produc
regular (IBW colifor t
basis; A m
Test Code) bacteri
for a&
bacteri "filth"
a&
chemic
als
Idaho None No =but Idaho Intras No No; No Must Yes; No None

cover regula tate Only apply w/ Licens comme
intrast tes labeli regula plan e nt
ate; intrast ng te review, renewa
Must ate law intrast pre- ble
compl bottler prohi ate operation annuall
y with s bits bottle al y
Idaho only; misbr d inspectio
drinki FDA andin water ns; Must
ng handle g sales; qualify
water s all Non- under
regula interst critica HACCP
tions ate l prior to
violati getting
ons license;
not Must
record meet
ed; labeling
Sanita requirem
tion ents
violati
ons
not
includ
ed
Illinoi None Yes; 2 =FDA Intrast No Yes; Proba No No state No Microb State
s ; No survey , ate Most bly answ certificati state iologic should
separ s on except bottler enforc availa er on certific al adopt
ate water 1 gal+ s ement ble, process; ation licensin
state bottler must regula actions but Source proces g
BWP s in add ted in would only s; process,
past 5 safety form requir inspected Inspect providi
yrs; seal of e upon ions of ng
Report lettersc great request bottler more
availab deal s control
le of conduc &
throug resour ted leverag
h FOI ces to annuall e
request get y
info.
Indian None No =FDA Intrast No No Inspe Yes[ Testing radiolo No No None

d]
a ; State ate ction =FDA; gical state comme
does sales report State physic permit, nt
not of s does not al & license
have bottle made, certify chemic or
separa d but source; al certific
te water not Private analysi ation
code gather source s of process
ed in needs source
datab satisfacto by
ase; ry state
Woul bacteria/ lab
d before
requir approv
e al
extens
ive
time
&
labor
to
compi
le
Iowa None No =FDA State No Enforc No No Testing= Yes; Microb Need

does ement summ FDA; Licens iologic more
not actions arized Bottlers e al samplin
directl for statist must renewa g for
y food ical sample ble chemic
regula safety, data end- annuall al
te labelin availa product y residue
end- g ble; before s on
produ violati Info license national
ct ons; not issued; level by
from No stored Only FDA &
out of shut- in private it
state downs datab sources should
or ase must do
recalls sample more
actual
testing
Kansa <1 No Less Yes; =FD No Curre No Kansas no No No Would

s FTE string Bottle A; nt answ has statuto comme like to
ent; d Gene comp er ry nt update
No water ral uter authori state
separa is labeli syste zation code
te "food" ng m to to
state & requir could issue similar
regula subjec emen not permit to
tions t to ts of pull s, industr
Kansa Kans out license y
s as F this s, or model
Food &D info certific code
& Act ates for or
Drug BW FDA’s
Act proces regs
sors,
plants,
or
distrib
utors
Kentu None No =FDA Intrast =FD Yes; Only No Intrastate Yes Chemic Specifi
cky ate; A Warni in answ source al c
Out- ng inspec er certified bottled
of- letters tion by water
state issued result Natural regulati
bottler s Resource on
s s&
submi Environ
t most mental
recent Protectio
water n
analys Cabinet;
is, No out-
permit of-state
& source
label certificati
for on
revie
w
prior
to
distrib
ution
in KY
Louisi 1/3 State =FDA Intrast =FD Violati No No Stricter Yes Microb No
ana FTE sample ate A ons than iologic comme
s end- must listed FDA; al, nt
produc get from Out-of- carcino
t every permit routine state gens
3 ; Out- inspect must
month of- ions; register;
s, from state No In-state
both must shutdo must
in- & registe wns, apply for
out-of- r with recalls & obtain
state state, permit
send
water
&
plant
appro
val,
labels,
lab
analys
is
Maine <1/2 No =EPA Intrast Yes; None Listed Non Must Yes; Microb Equaliz
FTE ate If in e submit does iologic e
sales; sourc datab test not al, drinkin
In- e or ase; results, need to nitrate/ g&
state end- Take site map, be nitrite bottled
bottler produ 1/2 copies of renewe water
inspec ct hour labels, d regulati
tions excee to inspectio ons;
annual d gather n reports Source
ly MCL ; prior to listing
s, Sorte state on
must d by certificati labels
be water on
listed syste
on ms
label;
optio
nal
listin
g of
analy
tical
result
s;
must
list
altere
d
water
qualit
y
Maryl None No, =FDA Intrast Yes; Yes[e] Datab Non Stricter Yes Bacteri Has THH
and but ate Sourc ase e than ologica request M=10
bottler sales e of FDA; l ed ppb,
s water Bottlers funding IBWA
require must required & staff code,
d to be to do be 100pp
conduc listed EPA increas b
t on primary ed to chlorin
sampli labels drinking add 2 e;
ng ; water FTE; disinfe
throug Label analysis EPA ction
h s of should
state- must source; add
certifie meet Bottlers cryptos
d lab Nutrit must poridiu
ion pass m to
Label sanitatio drinkin
ing n g water
Act inspectio checkli
requir n st
emen
ts
Massa 1/3 Yes, = Intrast Yes. Denial No No Must get No VOCs None IBWA
chuset FTE annual FDA ate, Sourc s of Dept. respon Code
ts ly +IBW carbo e applica Envtl se
A nated, must tions Protectio
Code all be n (DEP)
nonalc listed approval
oholic
bevera
ges
Michi No State =FDA Intrast Decla "No No No Essential FDA; Annual No No

gan respo sample & ate ration legal (will ly= Annual registra respons respon
nse s SDW sales, of actions provi inspect tion for e se
bottled A carbo identi "4 de for ion by each
water nated, ty, years $200/ indepe brand
on unpro name year) ndent
routine cessed & 3rd
basis, public addre party
at least drinki ss of
once/y ng bottle
ear water, r, and
water decla
dispen ration
sing regar
machi ding
nes carbo
n
dioxi
de
Minne None Yes; =FDA Separ Yes; No No No State Yes; Nitrites State
sota Curren ate State resp does not See & rules
tly state rules onse certify above pesticid need
sampli code & source; es updatin
ng 459 CFR License (spring g (from
sample requir firms water) 1993)
s of emen located
bottled ts in state;
water No
for longer
metals; issue
Sampl permits
es to out-of-
taken state
from firms
retail
stores
Missis 3 Try to =FDA Intrast No Bottled No No Must Yes; No More

sippi FTE sample ate water answ submit See respons FDA
for each regula produc er testing, above; e oversig
all bottled ted ts not geologic re-cert ht
state water same meetin al every 3 needed;
bottli produc as g survey, years FDA
ng t sold interst standar engineer progra
facilit in state ate ds will certificati m
ies on be on & analysis
monthl withdr report, of
y basis awn prelimina state’s
for E. (done ry site bottled
coli & in inspectio water
bacteri past) ns; If progra
a approved m&
, state assist it
issues as
source necessa
certificati ry
on
Misso <1 Yes; =FDA Intrast =FD No No; No Private Yes; No None
uri FTE Annua , ate; A Curre answ source See respons
l except Seltze ntly er only;[g] above e
survey[ state r worki Spring
f]
requir water; ng on source
es All datab must get
pseud bottle ase private
omon d lab
as waters chemical
testing regula &
ted bacteriol
same ogical
as all analysis
other testing;
bevera Source
ges must be
protected
from
surface
contamin
ants
Monta 1/20 Rando More All In- Yes; 3 No No In-state Out- Nitrate FDA’s All in-
na FTE m string bottler state recalls bottlers of- s honesty state
monito ent; s labeli (2 apply to state (greate in bottler
ring State regula ng microb DEQ & must st risk labeling s must
progra monit ted defini ial meet registe to should becom
m at ors under tions contam EPA r& pregna extend e
plant water licensi more ination standards obtain nt to Public
for qualit ng string s, 1 ; Out-of- license women artesian Water
finishe y progra ent; If misbra state (autom ); , spring, Syste
d more ms as labele nding); bottlers atically heavy and ms
produc closel food d& No must renewe metals other (PWS)
t every y; proces organ shutdo provide d & definiti &
2–3 Stricte sors ic& wns certificati annuall bacteri ons of meet
years r must on from y ologica bottled EPA
definit be source unless l in waters drinki
on of verifi state violati terms ng
& ed by public ons); of water
spring 3rd health In- protecti standa
water party agency state ng rds
& & must public
organ apply
ic to
certifi DEQ
catio and
n becom
group e
& PWS;
Licens
e
issued
upon
approv
al as
PWS
(autom
atically
renewe
d
annuall
y
unless
violati
on)
Nebra None No =FDA Intrast No No Yes, Non Testing Yes, Testing Reduce
ska (last ate but e =FDA; see & testing
bottled bottler data Source above; analyti for
water s must availa does not Permit cal unlikel
survey follow ble have to renewe process y
done same would be d is contami
in guidel have certified, annuall effectiv nants;
1991) ines more but y; e at FDA
as to do bottlers Bottler prevent require
interst with must s do ing ments
ate sanita supply not contam should
tion satisfacto need to ination not be
violati ry submit made
ons analytica analyti any
rather l results cal more
than before results stringen
analyt processin to t
ical g begins renew
result permit,
s but
must
have
FDA
test
results
on
hand at
plant;
State
conduc
ts spot-
checki
ng on
rando
m
basis
Nevad $500 No =FDA Intrast Sourc Yes; Violat Non Must Testin Permit Colifor Pretty
a 0 or ate; e, Denial ion e submit g= renewe m; happy
1/10 All name of data detailed FDA, d Bacteri with
FTE bottle & permit kept chemical SDWA annuall ological our
d addre s for in & y; s regulat
waters ss of distrib paper bacteriol Bacteri ions
produ bottle ution files ogical ologica right
ced in r into for analysis l now
state must state local on analysi
are be on withou produ source; s must
covere label; t cers be
d by If meetin only; submitt
variou maki g No ed
s ng chemic data every
portio any al on week if
ns of claim parame out- plant in
state s ters; of- "full"
code such One state operati
as to local violati on
low bottler ons
sodiu had
m or high
flouri bacteri
de a
conte levels
nt, found
must in
list sampli
levels ng,
found resulti
in ng in
produ volunt
ct ary
recall
of end-
produc
t
New <1 No =FDA Intrast Accu Yes; No No Testing= Permitt No More Strong
Hamp FTE , ate; rate Enforc FDA; ing comme money/ label
shire +IBW Licens sourc ement Source progra nt staff in require
A e e letters certified m for some ments
other listin and through source states
waters g (no permit Dept. and
, such misle actions Environ bottlin
as ading ; One mental g
filtere brand recall Services facility
d name and 2 ; Must
waters s) shutdo submit
wns in analyti
last 4 cal &
years hydrog
(no eologic
details al
availab reports
le over ; Plant
phone) permit
s
renewe
d
annuall
y&
analyti
cal
reports
must
be
resubm
itted
with
renewa
l
applica
tion
New 1 Yes =FDA Intrast Sourc Yes; 2 Annu No Testing = Licens No No IBWA
Jersey FTE (annua ; ate; e recalls al FDA & e must particul comme Code;
l). Some Carbo must in summ EPA be ar nt Annua
Spot param nated be 1995– ary of drinking renewe contam l
checks eters water listed 96;[h] test water d inants enforc
of stricte covere on No result standards annuall have ement/
bottled r than d label; shutdo s to ; Must y and consist violati
water federa under Two- wns legisl submit bottler ently on
sold l bottle year within ature analytica s exceed report
and standa d expir last 4 mand l results subject ed manda
produc rds water ation years; ated of source to establis ted by
ed in (=EP rules; date Regula by testing periodi hed state
state; A Other (from tory state showing c standar statute
State drinki types time letters statut complian inspect ds
rules ng of of sent e ce with ions;
require water waters bottli for state Source
periodi standa may ng) various drinking and
c rds) be violati water act end-
submis classif ons, standards produc
sion of ied as primari ; Spring t
sample bevera ly for sources subject
s for ges & unsanit must be to
review regula ary protected mandat
by ted as conditi from ory
state nonalc ons; outside periodi
health oholic No sources c
dept. bevera fines of testing
lab ge or contamin at a
produ penalti ation at DEP
ct es discharge certifie
assesse point d water
d; No testing
actions lab
against
in-state
bottler
s for
violati
ons of
safe
drinkin
g
water
standar
ds
New 1– No Stricte Intrast Must Yes Violat No Testing= State Microb Unifor Standa
York 11/2 (last r (total ate list ion Stricter issues iologic m rds
FTE survey SOCs) regula sourc data monitori certific als labels, may
in ted e, kept ng; ation FDA be
1992) same owne in Source numbe standar waive
as r, paper must be rs; ds = d;
interst certifi files certified Renew EPA; IBWA
ate by cate & meet ed NY’s Code
state; numb standards annuall goal is
Seltze er & in y; All to
r and date building sampli become
carbo water design & ng & more
nated bottle water other consiste
waters d; quality require nt with
not Nutrit (through ments national
regula ional certified must standar
ted claim lab) be ds
under s resubm
bottle must itted
d be upon
water consi renewa
rules stent l
with applica
FDA tion
regs;
Varia
nces
must
be
listed
on
label
North No No = Intrast No Yes No No Testing = No No None at Bacter

Caroli com FDA ate; FDA; In- permit comme this ial
na ment (adopt Seltze state progra nt time conta
ed by r bottlers m minati
refere water must get on
nce consid source incide
into ered a approved nts
state bevera (one- reporte
code) ge & time d
regula approval)
ted ; State
under occasion
differe ally does
nt part unannou
of nced
state inspectio
code ns and
sampling
North <1/4 No, water "much State No No No No "Little Licensi Probabl Should
Dakot FTE but vendi less has if any ng y = EPA
a state is ng string jurisd testing; progra nitrates rules;
consid machi ent" iction " m for State
ering nes if over Bottler facilitie should
conduc time all s do s; adopt
ting & water not Renew regulat
survey resour bottle have to able ory
of ces rs not submit annuall provisi
allow alrea source y ons
dy analysi when
under s; and if
FDA’ Source the
s must deman
jurisd be d
iction "unadu arises;
lterate "Little
d" need"
for an
additio
nal
state
regulat
ory
schem
e
Ohio Appr Yes. =FDA Intrast Must Yes; No No Testing = Licens Bacteri None IBWA
ox. 1 Water ate list Embar FDA; e is a Code
FTE quality regula sourc goed Source renewa
survey ted e if 5- must be ble
on 5- same non- gallon inspected yearly
gallon as muni contain and and all
contai interst cipal; ers declared data/te
ners of ate Any with acceptabl st
bottled additi high e by EPA results
water, ves standar must
but not must d plate be
smalle be count; resubm
r (ice listed No itted
also recalls
survey
ed)
Oklah 1 No = Yes Yes No Yes; No = FDA; Permit Bacteri Truth in IBWA

oma FTE FDA respon Inspe Bottler renewa a labeling Code
se ction must ble
report send annuall
s (not chemical, y;
provi radiologi Renew
ded) cal, & al
bacteriol based
ogical upon
analysis compli
& have ance
contamin with
ant levels regulat
within ions
acceptabl
e
paramete
rs
Orego 1/10 No = State No Yes. Yes "No = FDA Bottler None; Support
n FTE FDA; regula Action (Sum listin plus s Water FDA
State tes all against mary gs must license in change
does water bottler report avail meet d as compli
more and claimi of able state food ance
inspec bevera ng violati " drinking proces with
tions ge source ons water sors; standar
than bottler water for requirem Recipr ds does
FDA s was period ents for ocity not
spring 1/1/94 location, to pose
water – design, bottler any
when 12/31/ construct s to great
it was 97) ion and out-of- risk to
not water state consum
quality bottler ers &
s; our
Licens progra
es m is
renewe adequat
d e to
annuall assure
y compli
ance
Penns None Occasi Stricte Intrast Must Yes (5 Yes No Essential Yes Microb Recipro IBWA
ylvani onal r ate; list permit ly = ials, city Code
a bottled Water sourc s FDA; especia among
water s with e; If revoke Must lly states
quality additi sourc d, 6 submit cryptos as to
survey ves & e is recalls) source poridiu accepti
s in bottle taken ; sampling m& ng
1992; d from Mostly that giardia analytic
Some water "finis inform meets all al
VOC under hed al Maximu results
conta 1/2 water notices m & some
minati gallon sourc to Contami sort of
on regula e," bottler nant standar
found ted by i.e., a s of Levels; dization
Dept. publi violati Once among
of c ons, approved the
Agric water w/set , source differen
ulture syste period need not t states’
m, time to be labs
must correct monitore
list violati d;
name ons; Finished
No product
recalls must be
in 4 tested
years weekly
for
coliforms
Rhode 1/5 Occasi = State Sourc 1 Must No = FDA & Yes; Microb More
Island FTE onally FDA; regula e recall reque EPA; Bottler iologic stringen
RI some tes all must of st Out-of- must als t than
takes sectio bottle be baby from state submit FDA
rando ns of d listed water datab must end- labeling
m state water, unles b/c of ase send produc reqts,
sample code includ s run mold and analytica t& e.g.,
s of more ing throu contam paper l report source specific
end- string carbo gh a ination files and sample location
produc ent, nated; deion ; approval s with & name
t off e.g., If izer Inform letter annual of
retail RI natura (rever al from renewa water
shelve requir l se actions appropria l source;
s& es juices osmo for te state applica Shift
conduc dedica added, sis); other agency; tion focus
ts ted regula Muni inciden In-state away
microb line ted as cipal ts, must from
iologic for soft water includi submit health
al bottlin drink s ng analytica claims
analys g under witho chlorin l report to more
es water differe ut e engineeri accurat
nt part deion contam ng e
of izato ination drawing labeling
state n i with
code proce location
ss of spring
must source &
list everythin
sourc g within
e 1700’
radius
South <1 No More State No Yes; "No No Bottler Yes; Giardia Adopt FDA
Caroli FTE string regula com Enforc major must State & model does
na ent b/c tes ment ement violati submit issues cryptos code; monito
state and actions ons;" plans & permit poridiu Need ring &
follow permit taken All specificat to m (in consiste inspect
s EPA s over SC ions for operate terms nt ion
standa constr past 4 bottle their ; of one- standar
rds for uction years rs design & Curren time ds for
drinki of mostly kept construct tly, exposu all
ng bottlin related on ion for permit re states
water g& to non- water review s need health
treatm permitt syste under not be risk)
ent ed m state renewe
faciliti constru invent code; d;
es & ction ory & Source Regula
monit activiti assign must be tory
or es & ed a tested for change
source unappr water water s will
& oved syste quality most
end- water m likely
produ bottlin numb impose
ct g er a
faciliti periodi
es c
renewa
l
require
ment
in near
future
South <1 State Less Only No No Yes; No All No Since Recom

Dakot FTE conduc string one Comp sources all mend
a ts ent intrast uteriz in SD sources that SD
yearly than ate ed currently are bring
bottled FDA bottler data public munici state
water , base water pal & regs up
survey subjec of sources must to FDA
t to violati & are meet require
state ons approved safe ments
regula upon drinkin
tions verificati g water
only on as require
which municipa ments
are l source anyway
less after , there
string inspectio is no
ent n(munici great
than pal risk to
FDA sources bottled
must water
meet safe consum
drinking ers
water
requirem
ents); No
natural
spring
sources
in SD
Tenne No No = No No Not Not Not Not No No No

ssee respo FDA respon respo provid provi prov provided respon answer answer
nse se nse ed ded ided se
Texas <1 Yes; More All Sourc Yes; Yes No Testing = State Bacteri More IBWA
FTE State string bevera e Bottler (not FDA; license al FDA Code;
(300 inspect ent; ges must fined provi Source s contam oversig Bottle
hundr s each More manuf be approx ded); must bottled ination ht d
ed firm freque acture labele imatel State meet water where Water
bottle individ nt d, d; y keeps non- plants states Certifi
rs) ually inspec packa Chem $1250 copies communi & have cation
& tion ged icals for of ty public vendin inadequ Progra
inspect progra and or operati warni water g ate m
s at m; labele bacte ng ng system machin progra
least Requi d in ria withou letters standards es; ms; Re-
annual res state that t , but & state Renew institute
ly; source are excee certific no issues ed certific
Private labeli regula d ation; summ "Source annuall ation
busine ng & ted as Maxi Recall ary Certificat y; progra
sses certifi food; mum in report ion" Water m
send cation Water Conta Dallas s letter quality
out of vendi mina 1–2 availa (one- analysi
their operat ng nt years ble time) s must
own ors machi Level ago b/c be
quality under nes s of resubm
control Bottle regula must gross itted
people d ted be misbra annuall
to Water listed nding y to
make Certifi (must EPA
sure cation state certifie
finishe Progra on d lab
d m label unless
produc "cont city
t meets ains source
quality exces
standar sive
ds bacte
ria")
Utah <1 No = Intrast No Inform No No Testing = No; Pestici Current

FTE FDA ate al FDA; State des, regulati
bottle hearin Water does fertilize ons on
d g held quality not rs both
waters b/c analysis current state &
regula compa of source ly federal
ted ny not must be approv level
same permitt submitte e adequat
as ed; d; source, e
interst Bottler Bottling but
ate now facility enviro
bottlin inspected nmenta
g before l
water approval inspect
from ions
anothe require
r d
source; before
No compa
recalls, ny
shutdo starts
wns, or operati
other ons
legal
action
Verm <1 Dept. More Intrast Sourc Yes; Yes; No Bottler Permit Microb More
ont FTE has string ate e, Appro Comp must must iologic frequen
request ent sales town x. 4 uter apply for be al & t
ed than of & years data permit & renewe VOCs inspecti
rando FDA: bottle state ago, base submit d every ons of
m State d of bottler of hydrogeo 5 facilitie
sampli has water bottle was violati logical years; s,
ng, but stricte regula r, & fined ons info on Bottler random
has not r ted finish for source, s must testing
occurr labeli same ed using schemati resubm of end
ed ng as produ unappr c it product
requir interst ct oved diagram water &
ement ate; levels source of quality active
s, No of treatment analysi particip
chemi regula chem facility & s& ation &
cal tion of ical engineeri copy support
conta seltzer conta ng of by
minan , mina facility; most FDA;
t carbo nts of Copy of recent FDA’s
levels, nated, arseni labels, license definiti
& or c, chemical & on of
name flavor lead, results inspect "spring
of ed sodiu for ion water"
bottler waters m, & source & progra needs
nitrat finished m to be
es product, less
recall ambigu
plan, list ous
of
foreign
Country
requirem
ents.
Virgin 1–2 State = Intrast No State Infor Will State State Microb Adopt
ia FTE sample FDA ate; enforc matio prov does not does iologic state
s Seltze ement n kept ide issue not al licensin
regular r& actions in for certificati have a contam g or
ly for carbo have data fee on, but permitt inants permitti
bottled nated include base; source ing ng
water waters d Will needs to progra progra
quality regula enforc provi be tested m: m
, but ted ement de for & meet State is which
no same letters, fee standards not would
survey as a with empow enable
in past other formal respect to ered to state to
5 years bottle hearin microbio permit address
d g, and logical of food
waters court quality, license safety
action physical issues
which turbidity, in a
resulte and more
d chemical timely
tempor quality & manner
ary radiologi
shutdo cal
wn; quality;
Will plant
provid inspectio
e for ns every
$235.8 4 months
0
Washi 1/3 Not We Yes No Yes; No No Bottler Licensi (1) No

ngton FTE; sure adopt (same Warni must go ng Bacteri suggest
$20,0 federa as 21 ng through renewe ologica ions
00 l CFR letters source d l–due
regula 129) & approval annuall to post-
tions notices process y; process
verbat of with Water contam
im; correct Dept. of quality ination;
State ions Health, analysi (2)
inspec issued Division s Primar
ts approx of require y
bottle imatel Drinking d per inorgan
d y to 6– Water, CFR ics; (3)
water 10 including schedu VOCs
operat bottler site le, but
ions s; inspectio not in
on Licens n& order
much e chemical, to
more suspen bacterial, renew
freque sion/ci and license
nt vil physical
basis penalty analysis
than issued
FDA against
one
bottler;
Civil
penalty
action
issued
against
one
bottler
West 1/2 No; = Intrast No Yes; Yes; Yes[j WV does Permitt WV State Annua
]
Virgin FTE State FDA; ate; Mainly Infor not have ing has regulati l
ia relies More Flavor for matio separate progra never ons inspect
on string ed & technic n permittin m for really need ions
bottler ent seltzer al stored g faciliti had a updatin
s to do reporti waters permit in program es; proble g to
require ng curren violati hard for Renew m with meet
d requir tly ons, files source; ed either standar
sampli ement regula not for and Chemical annuall in-state ds of
ng in s; ted quality would tests y; or out- most
accord Bottle under violati requir followed Bottler of-state recent
ance rs soft ons; e by on- s must contam CFR
with must drink Formal substa site submit ination regulati
CFR test regula notices ntial physical chemic ons;
reqts weekl tionss based resour inspectio al Current
y for upon ces to n of analysi ly, WV
bacter consu compi plant; s for is
iologi mer le Source both followi
cal compla must be source ng most
conta ints of protected & end- recent
minan mold from produc CFR
ts & growth outside t and regs by
submi ; No contamin have interpre
t their recalls ation at satisfa tation
report point of ctory only
s to discharge physic
state and draw al
agenc area inspect
y by ion to
10th renew
of
each
month
Wisco <1 Yes; = Intrast No State No No Bottles Permit Lead Regulat

nsin FTE State FDA; ate, has (store answ must s ory
statute Excee seltzer had d in er contact renewe scheme
require ds in , some paper DNR & d of state
s some carbo regulat files) have annuall is more
public areas, nated, ory inspector y; than
ation e.g., all dealing s approve Bottler adequat
of some bottle s & verify s must e to
annual state d which source & mainta protect
bottled bottle water have construct in both
water d establi been ion; analysi consum
quality water shmen handle Source s ers &
analysi plant ts d by must be criteria bottling
s facilit regula workin analyzed & facilitie
report y ted g with for testing s
regula under bottler contamin schedu
tions ATCP s ants le to
much (Agric withou renew
more ulture, t license
string Trade further
ent & legal
than Consu actions
FDA mer ; State
requir Protec reports
ement tion) few
s proble
ms
with
bottled
water
faciliti
es; 1
proble
m with
pre-
consu
mer
lead
contam
ination
k
Wyo <1 No; = State Speci No; Yes; No Bottler State Crypto Rules IBWA
ming FTE State FDA; regula fic One Violat must issues sporidi should Code
goes State tes sourc inciden ion submit Food um & be put
by code everyt e t of data proof of Handle giardia in
what is hing must misbra stored approved rs (proble layman
bottles model manuf be nding on source Licens ms in ’s
must ed acture listed in comp from e; munici languag
sample after d in- ; which uter previous Renew pal e to
per IBWA state; Muni source data testing; ed sources increas
CFR code; Out- cipal labeled base State annuall ) e
require Separ of- water as inspects y; volunta
ments ate state must "spring in-state Source ry
state proces be " when sources sampli complia
code sors labele really & ng not nce
adopte must d as tap; processin require
d in apply "drin Bottler g plants d to
Sept. for king s upon renew
1986 distrib water respon initial license
& ution " se was applicati ; Out-
refers permit to find on of-
to ; a state
CFR Contr spring proces
often actual as sors
agree source must
ment submit
with proof
FDA of
to do approv
federa al by
l state
inspec authori
tions ty,
copy
of
labels,
& last
inspect
ion
results
a Information based on NRDC Survey conducted late 1995 -- early 1996, updated with information
publicly available from International Bottled Water Association, 1998, regarding states which have adopted
IBWA’s model code, and, most recently updated with information gathered as a result of a state-by-state
telephone and fax survey conducted April–May, 1998
b While a 11/27/95 letter to NRDC from California Department of Health services indicated "no reports or
listings [of illnesses or poisonings] are available at this time," the state attached a summary of numerous
citizen complaints about adulterated or contaminated water, in which injuries to consumers were reported.
Moreover, a 1985 California Assembly Office of Research found numerous complaints by bottled water
consumers who alleged illnesses. Bottled Water & Vended Water: Are Consumers Getting Their Money’s
Worth? (1985).
c One incident in which firm bottled water from municipal source without boiling during boiled water
order; Resulted in voluntary recall of water product involved; No injuries reported from this incident.
d Indiana State Department of Health reported 3 illness incidents: (1) 1/25/95 "suspect pseudomonas,"
illness reported, from Anita Springs water; (2) Kroger Springdale water, 10/27/94 "off taste/not confirmed,"
illness reported; Hinkley & Schmidt, 12/2/93, "foreign material/not confirmed," illness reported. These
statements were not independently verified by NRDC and should be viewed as unconfirmed.
e Generic descriptions of enforcement actions taken by the state of Maryland over the past four years
include: Detention orders, in which the state retained water bottled under questionable conditions (2–3
times in last four years); Denial of applications due to lack of or incomplete information; Detained water
for failure to renew annual license (approximately 10 occurrences in last four years); Maryland has not
enforced any shutdowns, brought court action, or made any recalls in the past four years.
f Annual survey must include standard plate count, coliform, pseudomonas, yeast, mold, chemical, &
radiological analysis.
g If source is municipal, no certification or testing is required because municipal water already subject to
regulatory requirements.
h Recalls were based upon consumer complaints for alleged presence of mold and involved out-of-state
companies. The two companies reportedly involved were Triton Water Company, Burlington, NC, and
Aquapenn Spring Water Company, State College, PA. No injuries were reported as a result of either one of
these incidents.
i Poland Springs conducted voluntary recall after unacceptable levels of chlorine contamination found in
end-product. At that time, Poland Springs did their own recall. Rhode Island officials found out about the
chlorine and contamination only after the fact from state of Massachusetts. Poland Springs did not notify
Rhode Island. No further action was taken by Rhode Island.
j Illness of two individuals likely caused by "contamination after purchase through absorption through
plastic."
k State detected lead in end-product bottled water while still at bottling facility (lead exceeded Preventive
Action Limits (PAL), but not enforcement standards. The result was that the bottler voluntarily replaced
defective equipment and corrected the problem. There were no injuries or illnesses reported.
Credits
Principal Author
Erik D. Olson, J.D.
With the Assistance of
Diane Poling, J.D.
Gina Solomon, M.D., M.P.H.
Production Supervision
Sharene Azimi
NRDC Director of Communications

Alan Metrick
Copy Editing
Michele Wolfe
Electronic Assembly
Bonnie Greenfield
Cover Design and Photos

Jeff Jenkins/Jenkins & Page
Acknowledgments
NRDC gratefully acknowledges the following donors for their support of this project:
Henry Philip Kraft Memorial Fund of the New York Community Trust, The Town Creek
Foundation, Inc., Susan Kendall Newman, and Kathleen Unger. As with all our work,
publication of this report would not have been possible without the support of NRDC's
400,000 members.
The author is grateful to David Murphy, J.D., for his valuable research during the early
phase of this project, and to Patti Lease, M.S., for her careful fact-checking. The author
appreciates the assistance of Alan Metrick, Sharene Azimi, Bonnie Greenfield, and Michele
Wolf in making this a far better product than it would have been without their help. The
peer reviewers listed below were also extraordinarily helpful. All mistakes are, however,
the author's alone.
Special thanks to my family, Anne, Chris, and Luke, for putting up with this seemingly
eternal project. Thanks also to all those colleagues at NRDC, Clean Water Fund, and
Citizens for a Better Environment, and to many state and federal officials, who helped
make this petition and study possible.
Reviewers
Robert Bourque, Ph.D., J.D., Simpson Thacher & Bartlett; Thomas Cochran, Ph.D., Senior
Scientist, NRDC; Linda Greer, Ph.D., Senior Scientist, NRDC; Jeffrey Griffiths, M.D., M.P.H.,
Associate Director, Graduate Programs in Public Health, Tufts University School of
Medicine; Robert Morris, M.D., Ph.D., Associate Professor, Tufts University School of
Medicine; Lawrie Mott, M.S., Senior Scientist, NRDC; David Ozonoff, M.D., M.P.H.,
Professor and Chair of the Environmental Health Department, Boston University School of
Public Health; Fred Rosenberg, Ph.D., Professor of Microbiology, Northeastern University;
Gina Solomon, M.D., M.P.H., Senior Project Scientist, NRDC; and David Wallinga, M.D.,
M.P.A., Senior Project Scientist, NRDC. Data verification was conducted by Environmental
Data Quality, Inc.
The views presented in this report do not necessarily reflect the opinions of those who
helped to review it.
disodium
hexafluorosilicon
CAS Number 39413-34-8
Chemical Formula F6Na2Si
http://www.neis.com/apps/chemicals?m=s&t=16893-85-9
Synonyms: 12656-12-1, 1310-02-7, 1344-04-3, 16893-85-9, 17084-08-1, 221174-64-7, 39413-

34-8, AI3-01501, Caswell No. 771, Destruxol applex, Disodium hexafluorosilicate, Disodium
hexafluorosilicate (2-), Disodium hexafluorosilicate (8CI)(9CI), Disodium silicofluoride, EINECS
240-934-8, Ens-zem weevil bait, ENT 1,501, EPA Pesticide Chemical Code 075306, Fluorosilicate
de sodium [ISO-French], Fluosilicate de sodium, HSDB 770, Natriumhexafluorosilicat,
Natriumsilicofluorid [German], Ortho earwig bait, Ortho weevil bait, Prodan, PSC Co-Op weevil
bait, Safsan, Salufer, Silicate(2-), hexafluoro-, disodium, Silicon sodium fluoride, Sodium
fluorosilicate, Sodium fluorosilicate [UN2674] [Poison], Sodium fluosilicate, Sodium
hexafluorosilicate, Sodium hexafluorosilicate [ISO], Sodium hexafluosilicate, Sodium silica
fluoride, SODIUM SILICOFLUORIDE, Sodium silicon fluoride, Super prodan, UN2674
|
JANUARY 11 2005
BECHTEL JACOBS COMPANY LLC
New Remediation Contractors at Paducah and Portsmouth
The Department of Energy today named the new remediation contractors at Paducah and
Portsmouth. A link to the DOE news releases is provided below.
North Wind Paducah Cleanup Company LLC has been named the Paducah remediation
contractor. North Wind is a women-owned small business based in Idaho Falls. Additional
information about North Wind, Inc., is available at http://www.nwindenv.com.
The Portsmouth remediation contractor is LATA-Parallax Portsmouth LLC. LATA-Parallax

is owned by Los Alamos Technical Associates, Inc. http://www.lata.com/home.html, a New
Mexico-based engineering, environmental and nuclear operations services company, and
Parallax Inc., http://www.parallaxabq.com/, a Maryland-based engineering, environmental
and nuclear operations services company. LATA is a service-disabled veteran owned
small business and Parallax is a women-owned, minority owned small business.
DOE has not yet announced an award date for the infrastructure contracts.
We now enter a new phase of our work as we begin the transition that will lead to the
turnover of all remediation responsibilities. Your efforts to prepare for this transition has
put us in good stead for the weeks ahead. Our work is not finished, and we must maintain
our professionalism and our commitment to safety as we assist the new team.
In the coming weeks, we will work closely together to lay the foundation for the workforce
transition process. We expect to share additional information through e-mails and
employee meetings in the very near future. This period of change is also a period of
opportunity, and we intend to do everything we can to assist our employees during this
transition. Please ensure that you await direction from our BJC Manager of Transition and
the HR Department prior to initiating specific meetings on transition.
I know that you will respond to the challenge ahead with the determination and dedication
you have shown since Bechtel Jacobs took on this work in April 1998.
Les Hurst
Paducah and Portsmouth Transition
http://www.ohio.doe.gov/pppo_seb/remediation/index.html
HOME |
Bechtel Jacobs Company LLC
Subcontractor / Supplier Information Center
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Security Statement / Privacy Policy
Procurement Web
DRINKING WATER CONTAMINANTS AND THEIR CONTROL
WITH REVERSE OSMOSIS WATER TREATMENT
Nominal Rejection Performance for Thin Film Composite

Reverse Osmosis Membranes at 60 psi Net Pressure and 77° F.1
Inorganic Contaminant
Sodium 90 – 95% 1. This table of nominal rejection performance
Calcium 93 – 98% is for the thin film composite type of
Magnesium 93 – 98% membrane used in drinking water systems
Potassium 90 – 95% operating at a net pressure (feed pressure
Iron2 93 – 98% less back pressure and osmotic pressure) of
Manganese2 93 – 98% 60 psi and 77° F water temperature.
Aluminum 93 – 98%
Copper 93 – 98% The actual performance of systems
Nickel 93 – 98% incorporating these membranes may be less
Zinc 93 – 98% due to changes in feed pressure,
Strontium 93 – 98% temperature, water chemistry, contaminant
Cadmium 93 – 98% level, net pressure on membrane, and
Silver 93 – 98% individual membrane efficiency.
Mercury 93 – 98%
Barium 93 – 98% 2. While iron and manganese are effectively
Chromium 93 – 98% removed by the membrane, they also can
Lead 93 – 98% easily foul its surface with deposits even at
Chloride 90 – 95% low concentrations. Generally, iron and
Bicarbonate 90 – 95% manganese should be removed by other
Nitrate3 85 – 90% treatment methods prior to RO treatment.
Fluoride 90 – 95%
Phosphate 93 – 98% 3. Nitrate removal depends on factors such as
Chromate 90 – 95% pH, temperature, net pressure across
Cyanide 90 – 95% membrane, and other contaminants present.
Sulfate 93 – 98%
Boron 55 – 60% 4. While reverse osmosis membranes
Arsenic+3 70 – 80% theoretically remove virtually all known
Arsenic+5 93 – 98% microorganisms, including virus, they
Selenium 93 – 98% cannot offer foolproof protection when
Radioactivity 93 – 98% incorporated into a consumer drinking water
system. Potential seal leaks and
Biological & Particulate Contaminants4 manufacturing imperfections may allow
Bacteria > 99% some microorganisms to pass into the
Protozoa > 99% treated water.
Amoebic Cysts > 99%
Giardia > 99% 5. The degree of rejection of organic molecules
Asbestos > 99% less than molecular weight (MW) 300
Sediment / Turbidity > 99% depends on the size and shape of the
molecule. Activated carbon is always
Organic Contaminants incorporated along with reverse osmosis to
Organic Molecules with a insure complete removal of these lower
Molecular Weight > 300 > 99% molecular weight organic contaminants.
Organic Molecules with a
Molecular Weight <300 5 0 – 99%
Source: Water Treatment Fundamentals, Water Quality Association, 1996.

Ministry of Transport,
Public Works and Water Management

Institute for Inland Water Management and Waste Water Treatment/RIZA
Dutch notes on BAT

for the phosphoric acid industry
Author(s):
J.H.W. van der Loo (Tebodin, Consultants & Engineers)

M. Weeda (Institute for Inland Water Management and Waste Water Treatment, RIZA)
Contact:
M. Weeda
RIZA
P.O. Box 17
8200 AA Lelystad
The Netherlands
Final document - 3 January 2000

Dutch notes on BAT for the phosphoric acid industry 2
Preface
This document comprises the contribution of the Netherlands to the exchange of information in the European Union
on the use of Best Available Techniques (BAT) to control the environmental impact of industrial processes. This
document concerns the production of phosphoric acid.
On September 24 th 1996, the European Commission passed the Council Directive 96/61/EC concerning Integrated
Pollution Prevention and Control (IPPC Directive), which obliges the Member States to achieve integrated prevention
and control of pollution in the licensing of environmentally relevant industrial installations. The purpose of the IPPC
Directive is ‘to achieve a high level of protection of the environment as a whole’ (Article 1), which should result in the
application of the ‘best available techniques’ (BAT). Here, BAT are those techniques which are ‘most effective in
achieving a high level of protection of the environment as a whole’ (Article 2).
One of the essentials of the Dutch environmental policy is the application of the best available techniques, as stated
in the Dutch Environmental Protection Act. In the situation of an open market with international competition, and with
regard to the transboudary character of environmental pollution, this policy can only achieve goals if international co-
ordination is a part of it. Therefore harmonisation of the ideas on BAT is very important to the Netherlands.
Article 16.2 of the IPPC-Directive, stating that ‘the Commission shall organise an exchange of information between
Member States and the industries concerned on best available techniques, associated monitoring, and developments
in them’, has opened up a useful route towards this harmonisation. It is within this framework that the present
document is drawn up. It is meant to support and feed the process on information exchange.
The document provides information on the production of phosphoric acid and the measures and technologies used to
control and reduce the environmental impact associated with the production processes. In this document the
emphasis is on the so-called wet phosphoric acid production and the phosphogypsum problem, especially on the
current and future situation of the wet phosphoric acid industry in the Netherlands.
The document does not cover the production of phosphoric acid in full detail. This document is more a highlight
document rather than a balanced BAT-document which is valid for the entire industrial phosphoric acid sector in the
European Union. Nevertheless, we hope that this document will prove to be a useful source of knowledge in the
process of drawing up a European BAT-reference document.
Table of contents
SUMMARY 7
1 GENERAL INFORMATION 9
1.1 PRODUCTION ROUTES AND FIELDS OF APPLICATION 9
1.2 EUROPEAN PHOSPHORIC ACID PRODUCTION 10
1.2.1 MERCHANT- GRADE ACID 10
1.2.2 TECHNICAL- GRADE ACID 10
1.3 PREVIOUS WORK ON BAT 11
1.4 INTERNATIONAL DEVELOPMENTS 11
1.4.1 OSLO PARIS CONVENTION (OSPAR) 11
1.4.2 INTERNATIONAL COMMISSION FOR THE PROTECTION OF THE RHINE (ICPR) 12
1.4.3 HELSINKI CONVENTION 12
1.4.4 BARCELONA CONVENTION 12
1.5 SCOPE OF THE DOCUMENT 12
1.5.1 STARTING POINTS DUTCH POLICY 13
1.5.2 PRESENT SITUATION AND OUTLOOK 14
2. DESCRIPTION OF PROCESSES 15
2.1 R AW MATERIALS 15
2.1.1 PHOSPHATE ROCK 15
2.1.2 SULPHURIC ACID 16
2.2 PROCESS PRINCIPLES 17
2.3 WET PHOSPHORIC ACID PRODUCTION PROCESSES 17
2.3.1 DIHYDRATE PROCESS 17
2.3.2 HEMIHYDRATE PROCESS 18
2.3.3 RECRYSTALLIZATION PROCESSES 18
2.4 PHOSPHORIC ACID PURIFICATION PROCESSES 20
3. CONSUMPTION LEVELS AND ENVIRONMENTAL ASPECTS 21

3.1 C ONSUMPTION LEVELS 21
3.2 EMISSIONS AND WASTE 21
3.2.1 FLUORIDE EMISSIONS TO AIR 21
3.2.2 DUST EMISSION TO AIR 22
3.2.3 EMISSIONS OF LIQUID EFFLUENTS TO WATER 22
3.2.4 W ASTE GYPSUM 23
3.2.5 RADIOACTIVITY 25
3.3 D IFFUSE EMISSIONS RESULTING FROM PRODUCT ACID USE 27
4. EMISSION ABATEMENT MEASURES AND TECHNIQUES 28

4.1 GENERAL PREVENTIVE MEASURES 28
4.1.1 APPLICATION OF HIGH- GRADE PHOSPHATE ROCK 28
4.1.2 APPLICATION OF AN HIGH EFFICIENCY PHOSPHORIC ACID PROCESS 28
4.2 SPECIFIC TECHNIQUES AND MEASURES TO MINIMIZE EMISSIONS AND WASTE 29
4.2.1 MEASURES TO PREVENT FLUORIDE EMISSIONS TO AIR 29
4.2.2 MEASURES TO PREVENT DUST EMISSIONS TO AIR 29
4.2.3 MEASURES TO PREVENT EMISSIONS TO WATER 29
4.3 U SEFUL APPLICATION OF PHOSPHOGYPSUM 30
4.3.1 PHOSPHATE ROCK 31
4.3.2 PHOSPHORIC ACID PRODUCTION PROCESS 31
4.3.3 REPULP UNIT 31
4.3.4 REDUCTION OF CADMIUM LEVELS IN WASTE GYPSUM BY CHLORIDE DOSING 32
4.3.5 UPGRADING OF PHOSPHOGYPSUM 32
4.4 THE NITROPHOSPHATE ROUTE: AN ALTERNATIVE PHOSPHORIC ACID PRODUCTION PROCESS 32
5. EMERGING TECHNIQUES 34
5.1 PHOSPHATE REMOVAL FROM WASTE WATER EFFLUENTS 34
5.2 IN -PROCESS PHOSPHORIC ACID PURIFICATION 34
6. PHOSPHORIC ACID PRODUCTION: THE DUTCH SITUATION 35

6.1 PROCESS DESCRIPTION 35
6.1.1 KEMIRA AGRO PERNIS (KAP) 35

6.1.2 HYDRO AGRI ROTTERDAM 36
6.2 C ONSUMPTION LEVELS 37
6.3 EMISSIONS AND WASTE 38
6.4 THE FUTURE D UTCH SITUATION : U SEFUL APPLICATION OF WASTE GYPSUM 39
6.4.1 DESCRIPTION OF GYPSUM UPGRADING INSTALLATION 39
6.4.2 CONSUMPTION LEVELS 39
6.4.3 ENVIRONMENTAL PERFORMANCE 40
7. EVALUATION OF WASTE DISPOSAL METHODS BY MEANS OF SCREENING LCA 41

7.1 STARTING POINTS FOR THE SCREENING LCA 41
7.1.1 GYPSUM DISPOSAL SCENARIOS AND FUNCTIONAL UNIT 41
7.1.2 SYSTEM BOUNDARIES AND DATA USED 42
7.2 R ESULTS OF THE SCREENING LCA AND EVALUATION 42
7.2.1 IMPACT ASSESSMENT 42
7.2.2 NON- NORMALIZED ENVIRONMENTAL PROFILE 42
7.2.3 NORMALIZED ENVIRONMENTAL PROFILES 44
8. CONCLUDING REMARKS AND RECOMMENDATIONS 45
REFERENCES 49
ANNEX 1: THERMAL PHOSPHORIC ACID PROCESS
ANNEX 2: TYPICAL ANALYTICAL FIGURES PHOSPHATE ROCK
ANNEX 3: USE OF GYPSUM AS RAW MATERIAL OR AS PRODUCT
ANNEX 4: PROCESS DESCRIPTION OF THE HDH-1 PROCESS OF KEMIRA AGRO PERNIS (KAP)
AND THE HDH-2 PROCESS OF HYDRO AGRI ROTTERDAM (HAR)
ANNEX 5: EMISSION MONITORING STANDARDS USED IN THE NETHERLANDS

Summary
This document comprises the contribution of the Netherlands to the exchange of information in the European Union
on the use of Best Available Techniques (BAT) for the production of phosphoric acid.
It provides information on the production of phosphoric acid and the measures and technologies used to control and
reduce the environmental impact associated with the phosphoric acid production processes. However, the document
does not cover the production of phosphoric acid in full detail. The emphasis in this document is on the so-called
wet phosphoric acid production and the phosphogypsum problem, with specific attention for the current and future
situation of the wet phosphoric acid industry in the Netherlands. This document is more a highlight document rather
than a balanced BAT-document which is valid for the entire industrial phosphoric acid sector in the European
Union.
In chapter 1 the subject “phosphoric acid production” is introduced. The two principal routes for the production of
phosphoric acid are decribed, and an overview of the production facilities in the European Union is given. Based on
this information the scope of the document is narrowed down to phosphoric acid production according to the so-
called wet-process route. The chapter contains a summary of discussions in several international fora with respect to
BAT for the production of wet phosphoric acid, and ends with an explanation of the specific Dutch approach with
respect to the main environmental problem of the wet phosphoric acid industry, i.e. the production and disposal of by-
product phosphogypsum. In chapter 2, a general survey is given of the raw materials that are used for wet
phosphoric acid production and the type of processes that are applied. In chapter 3 typical consumption levels of raw
materials and utilities are presented together with an inventory of the environmental aspects of wet phosphoric acid
production. In chapter 4 measures and techniques are decribed that are applied to prevent and minimize the
production and need for disposal of phosphogypsum, and to prevent and minimize emissions to air and water.
Emerging techniques that may further improve the environmental performance of wet phosphoric acid processes are
discussed in chapter 5. Subsequently, the production of wet phosphoric acid in the Netherlands is considered in
more detail in chapter 6, with special attention for the developments regarding useful application of the by-product
gypsum. Last but not least, in chapter 7 the results are presented of an integral assessment of the best available
solution for the phosphogypsum problem from an environmental point of view. Concluding remarks are made in
chapter 8.
W et phosphoric acid is produced by digestion of phosphate rock with sulphuric acid. In this process phosphogypsum
(calcium sulphate) is formed as by-product. The disposal of phosphogypsum is the main environmental problem of
wet phosphoric acid production. Basically, three different options exist for handling phosphogypsum by-product, i.e.
discharge into water, dumping on land and useful application of the gypsum. From an environmental point of view, it
is commonly accepted that, the discharge of phosphogypsum into water should be avoided by any means. The
results of a cross-media assessment, based on the principal steps of the so called Life Cycle Assessment (LCA),
indicates that, of the two remaining alternatives, the overall environmental performance of useful application is better
than dumping on land.
Useful application of phosphogypsum is only possible if the quality meets required specifications. In general, this
means that the quality of the phosphogypsum should be comparable to that of other gypsum resources. To enable
useful application, it is important to use a process with a high P2O5-efficiency. With increasing P2O5-efficiency both
the amount of phosphogypsum per unit of P2O5 produced and the level of residual phosphoric acid (a major impurity)
in the gypsum decreases. Efficiencies of more than 98% are possible in recrystallization processes with two filtration
stages. In addition to a high P2O5-efficiency, recrystallization processes also produce phosphogypsum with
considerably lower levels of impurities than single stage reaction processes, like the dihydrate and the hemihydrate
process.
Together with the use of a process with a high P2O5-efficiency, the use of phosphate rock with a low ratio of
impurities to the P2O5-content is essential for enabling useful application of the by-product gypsum. The impurities in
phosphogypsum mainly originate from phosphate rock. The lower the ratio, the lower will be the level of impurities in
the gypsum, and the better will be the chances for useful application.
Additional upgrading of phosphogypsum may be required to be able to meet quality specifications. Upgrading of
gypsum can be achieved by separation of fines (e.g. by means of hydrocyclones), as it appears that many of the
impurities present in phosphogypsum are enriched in the smallest gypsum particles. Another interesting option is in-
process removal of specific impurities. This is not yet possible, but developments for in process removal of impurities
by means of extraction and precipitation techniques are underway. As in-process removal of impurities may yield a
cleaner gypsum as well as a cleaner phosphoric acid this development deserves further attention.
Other environmental problems at the wet phosphoric acid production are the emission of fluorine and dust (from
phosphate rock grinding) to air, and the emission of fluorine and phosphate to water. The emission of dust can be
effectively prevented by using fabric filters. Fluoride can be removed by a number of different gas scrubbing systems
with a removal efficiency of more than 99%. The gas scrubbing systems yield an effluent containing fluorine and
phosphate components. Before discharge, the effluent can be neutralized with lime or limestone to precipitate fluorine
as solid calcium fluoride and phosphate as calcium phosphate.
1 General information
1.1 Production routes and fields of application

Phosphoric acid, H3PO4, is a colourless, crystalline compound, that is readily soluble in water. The main product is
phosphoric acid with a commercial concentration of 52-54% P2O5. After sulfuric acid, phosphoric acid is the most
important mineral acid in terms of volume and value. The greatest consumption of phosphoric acid is in the
manufacture of phosphate salts as opposed to direct use as acid. Markets are differentiated according to the purity of
the acid.
Phosphoric acid is produced commercially by either the wet process or the thermal process. The wet digestion of
phosphate rock with sulphuric acid is the most important process in terms of volume [1, 2]. Wet-process acid is
characterized by relatively high production volume, low cost, and low purity. The share of wet phosphoric acid
amounts to 95% of the total phosphoric acid in Western Europe. It is used primarily in the production of fertilizers
(approximately 80%) and animal feed supplements (8%). Part of the wet-process acid is purified for the manufacture
of technical- and food-grade phosphate salts, usually employing a solvent extraction process.
The thermal process for the production of phosphoric acid starts with the production of elemental phosphorus from
phosphate rock, coke, and silica in an electrical resistance furnace. The elemental phosphorus is subsequently
oxidized to P4O10 after which the acid is generated by hydration of the oxide. Thermal acid is considerably purer than
wet-process acid, but more expensive, and is produced in much smaller quantities than wet-process acid. About 80-
90% of the thermal phosphoric acid produced is used for the production of industrial phosphates, especially the
sodium, potassium, calcium and ammonium salts. Thermal acid is used in metal surface treatment and, in food-grade
quality, for the acidulation of beverages. Table 1 shows comparative analysis of typical wet-process acid, purified
wet-acid and thermal acid [1].
Table 1: Typical analysis of phosphoric acids (wt.%).
Wet-process acid Thermal acid

1)
Component Merchant-grade Technical-grade Technical-grade
(Tennessee Valley Authority) (Extraction Acid) (Monsanto Co.)
(Société Chimique Prayon-Rupel)
P2O5 53.1 57 54.3

CaO 0.06 0.001
F 0.8 0.02 <0.0001
Al2O3 1.7 0.0003
Fe2O3 1.23 0.004 0.0004
MgO 0.58 0.0002
K2O 0.01 0.0007
Na2O 0.12 0.0025
SiO2 0.07 0.0015
SO4 2.2 0.04 <0.002
As <0.005 <0.00005
1)
Depending on the origin and the application of purified, technical grade, wet acid major variations in the composition this acid may occur. Impurity
levels (also heavy metals) similar to that of thermal acid can be achieved by purifying wet acid. However, the low fluoride and sulphate levels in
thermal acid cannot be reached by purifying wet acid.
1.2 European phosphoric acid production
1.2.1 Merchant-grade acid

In the late eighties and the early nineties fertilizer consumption strongly declined in Western Europe, caused primarily
by agricultural policy changes in the European Union where efforts to reduce surplus farm production resulted in a
number of reforms in the Common Agricultural Policy. These changes in policy, and the fact that the economics of
present-day production dictates increasingly that plants should be built where there is cheap access to raw materials
(either at the phosphate mine or at the source of sulphur or sulphuric acid), has had a large impact on the structure
of the European wet phosphoric acid industry. Because of unfavourable economics a large number of relatively small
phosphoric acid production plants in Europe closed down, and as a result the structure has increasingly moved
towards a small number of large production plants. Between 1980 and 1992 the number of plants in Western Europe
reduced from 60 to approximately 20 while the average plant size increased from 80,000 t/a to 180,000 t/a. At
present 10 production sites are left which will have been reduced to 9 by the end of 1999 as Hydro Agri Rotterdam
has announced to close down its phosphoric acid plant in Vlaardingen, The Netherlands. An overview of the
European phosphoric acid production plants is given in table 2 [3].
Table 2: Overview of European phosphoric acid plants in 1994.
Plants Phosphoric acid capacity

[kton P2O5]
Belgium Rhone-Poulenc Chemie 130

Societe Chimique Prayon-Rupel SA 140
Finland Kemira Chemicals Oy 235
France Grand Quevilly 200
Greece Chemical Industries of Northern Greece SA 110

Phosphoric fertilisers industry Ltd. 65
Netherlands Hydro Agri Rotterdam 160

Kemira Agro Pernis 225
Spain Fertiberia S.L 420

FMC Foret, SA 130
1.2.2 Technical-grade acid

Economics have also had a very large impact on the production route used to produce technical grade acid. In
W estern Europe, the production of phosphoric acid using the solvent extraction purifying route has taken over from
the thermal route. The impact of energy cost has caused the proportion of thermal acid to be largely reduced. At
present only Thermphos in Vlissingen, the Netherlands produces phosphoric acid via the thermal route. The
production capacity of this plant amounts to 155,000 t/a (the production in 1995 was 67000 ton P2O5). A short
description of this plant, including the environmental performance is presented in Annex 1. Because of its minor
relevance the thermal route will not further be considered in this document.
1.3 Previous work on BAT

Through the years a vast amount of literature and documents have been published about the production of
phosphoric acid. Although not all documents intend to be a BAT-document a number of them give a comprehensive
overview of new and existing wet phosphoric acid technology and environmental measures. Recommanded
documents are:
• Reduction environmental burdening phosphoric acid process, Best Available Technology, 1994 [4];
• Descriptive analysis of the technical and economical aspects of measures to reduce water pollution cased by
discharges from the fertilizer industry and other industries entailing nutrient discharges,1991 [5];
• Production of Phosphoric Acid, 1995 [6].
Besides these specific reports there are several books that treat the subject of phosphoric acid production in
considerable detail. A few of these titles are given below. Items adressed in these books are raw materials,
production processes, environmental aspects and impact of the phosphoric acid industry, and pollution control in the
phosphoric acid industry:
• Use and disposal of wastes from phosphoric acid and titanium dioxide production, 1988 [7];
• Phosphates and Phosphoric Acid: Raw Materials, Technology and Economics of the Wet Process, Second
Edition, Revised and Expanded, 1989 [8];
• Pollution control in fertilizer production, 1994 [9];
• Fertilizer Manual, 1998 [10].
1.4 International developments

The phosphoric acid industry has received considerable attention in several international fora, because of the
environmental impact of phosfogypsum disposal. The following presents an overview of historic and recent BAT-
developments in some important European fora.
1.4.1 Oslo Paris Convention (OSPAR)

The Paris Commission (Parcom), which was established to administer the Paris Convention for the prevention of
marine pollution from land-based sources has made a proposal for a recommendation for the reduction of marine
pollution originating from the phosphate fertilizer industry (Oslo 22-26 March 1993). The proposal stated that
phosphogypsum should preferably be reused or otherwise be deposited on landfill sites, in conditions which are not
harmful to the environment (geologically-stable site, protection of ground and surface water, etc.) Furthermore,
manufacturing plants should recycle and reuse process water to the greatest extent practicable and must comply with
the following emission factors insofar as concerns their liquid wastes (process water):
Phosphorus (P): 2 kg/ton P2O5

Fluorine (soluble): 2 kg/ton P2O5
Cadmium: 1 g/ton P2O5
The proposal has never become a definitive recommandation. Parcom, nowadays OSPAR (Commission for the
protection of the marine environment of the North-East Atlantic), noted that a study on BAT was in progress in the
ICPR (International Commission for the Protection of the river Rhine) framework. It was agreed to remove this
industrial sector from the working programme of OSPAR to avoid duplication of this work of the ICPR.
Recently, the subject of BAT in the phosphate fertilizer industry has been put on the agenda of the OSPAR working
group on radioactive substances (RAD). The aim is to esthablish BAT with respect to the radioactive aspects of the
fertilizer industry.
1.4.2 International Commission for the Protection of the Rhine (ICPR)

Discussions on BAT in the fertilizer industry, in particular the phosphoric acid industry, are still going on within the
ICPR. These discussions were triggered because of the difference of view of the member states on the discharge of
phosphogypsum. In 1997 a first expert consultation was held on the production of phosphoric acid in order to get a
better understanding on a technical level between the member states. The effort is to minimize the discharge of
phosphogypsum. In June 1999 a second expert consultation was held. At this occasion the state of affairs with
respect to useful application of by-product gypsum was discussed.
1.4.3 Helsinki Convention

The Helsinki Commission (Helcom) which was established to administer the Helsinki Convention for protection of the
Baltic marine environment, has adopted a recommendation entitled ‘Reduction of pollution from discharges into water,
emissions into the atmosphere and phosphogypsum out of the production of fertilizers’ on 12 March 1996
(recommendation 17/6). The recommendation should be implemented by 1 January 1998 for new plants and by 1
January 2002 for existing plants. The Contracting Parties have to report the Commission every three years starting
from 2003. The recommendation should be reconsidered in 2004, especially regarding limit values for the different
product lines and products. The recommandation states that for the production of phosphoric acid the following load
values should not be exceeded as annual mean values:
Waste water discharges:

Phosphate-P: 0.02 kg/ton P2O5
Fluoride: 0.05 kg/ton P2O5
Cadmium: 0.1 g/ton P2O5
Mercury: 0.01 g/ton P2O5
Zinc: 1 g/ton P2O5
Emissions into the atmosphere:

NOx: 500 mg/m3 related to NO2
dust: 50 mg/m3
Fluorine compounds: 5 mg/m3
Chlorine compounds: 30 mg/m3
Waste (phosphogypsum):
Phosphogypsum from the sulphuric acid dissolution should be re-used to the extent possible. If this is not practicable
it has to be disposed of in a disposal facility appropriately equipped. A discharge into waters does not comply with
BAT.
1.4.4 Barcelona Convention

The Barcelona Convention is the convention for the protection of the Mediterranean sea. No information is received
from the Co-ordinating Unit for the Mediterranean Action Plan.
1.5 Scope of the document

In this document information is given on the production of phosphoric acid and the measures and technologies used
to control and reduce the environmental impact associated with the production processes. The document does not
cover the production of phosphoric acid in full detail. The emphasis is on the so-called wet phosphoric acid
production, especially on the current and future situation of the wet phosphoric acid industry in the Netherlands. This
document, therefore, is more a highlight document rather than a balanced BAT-document which is valid for the entire
industrial phosphoric acid sector in the European Union.
1.5.1 Starting points Dutch policy

In the Netherlands the discharge of so-called phosphogypsum from the wet phosphoric acid industry into the Rhine
estuary has been a subject of discussion for years. Besides relatively harmless gypsum, phosphogypsum contains
many substances which, owing to their harmful properties, pose great risks to the environment and to human health.
These substances include amongst others:
• phosphorus;
• fluorine
• heavy metals such as cadmium, mercury and lead;
• radionuclides, in particular radium-226, lead-210 and polonium-210.
The Dutch environmental policy regarding these pollutants is based on the precautionary principle and is aimed at
reducing pollution using the best available techniques. In the case of black-listed, or list I substances, such as
cadmium and mercury, the Dutch policy even requires efforts to reduce discharges to zero. This policy is clear. The
discussion referred to above, therefore, did not concern the neccesity to minimize the discharge of pollutants from
the wet phosphoric acid industry. The discussion concerned the best way to realize minimization of the discharge.
Main starting-point of the Dutch government has been to realize a sustainable solution. The following aspects of
Dutch environmental policy and additional aspects have determined the Dutch approach with respect to the wet
phosphoric acid industry:
• Reducing pollution and industrial waste are basic principles in Dutch environmental policy. Priority is given to
eliminating pollution and waste at the source. This should be achieved preferably by measures that avoid the
formation of pollution and waste rather than by measures that eliminate the problems once they are formed;
• If the production of waste is unavoidable priority is given to reuse or recycle of the material in the process from
which it originates, or useful application of the material elsewhere. Dumping of waste is seen only as the last
alternative if all other alternatives fail to solve the problem;
• Shifting of pollution between the various environmental media should be avoided. In case of the wet phosphoric
acid industry this means that reducing the pollution from by-product gypsum should not lead to an increased
environmental burdening by end products based on the intermediate phosphoric acid;
• Because of a limited load bearing strength of the underground and high ground water tables (large area required;
stringent precautionary measures to prevent serious soil and groundwater contamination), and a high population
density (lack of space, considerable transport distance) storage of gypsum in (a) depot(s) appeared not to be a
viable option, neither permanent nor temporary.
Based on the abovementioned considerations, the Dutch government, in co-operation with the industry (convenant
between the Dutch government and the industry in 1988), developed the following approach to deal with the
environmental problems of the phosphoric acid industry:
• Use of clean high grade phosphate ores (production of gypsum and phosphoric acid with relatively low levels of
impurities);
• Implementation of high efficiency wet phosphoric acid processes (high P-efficiency means less gypsum per unit
of P2O5 produced, and a lower P-concentration in the gypsum);
• Development of useful applications for the by-product gypsum;
• Acid purification: The production of clean pure gypsum should not lead to an increased environmental burdening
by end products based on phosphoric acid. Additional acid purification may be required.
1.5.2 Present situation and outlook

Up till now the by-product gypsum from the wet phosphoric industry in the Netherlands is being discharged into
water. In the past decade, however, the discharge of all pollutants is reduced considerably. Compared to 1985 the
emission of cadmium is even reduced by more than 95%. Moreover, further reductions can be expected in the near
future as due to the quality improvement of the gypsum it is now possible to use the gypsum as a feedstock, for
example in the cement industry and for the production of plaster, plaster board and gypsum building blocks.
2. Description of processes
In this section the raw materials (phosphate rock and sulphuric acid) and the phosphoric acid processes will be
discussed in general. The specific Dutch situation, i.e. the situation of the production sites of Kemira Agro Pernis and
Hydro Agri Rotterdam, will be highlighted in more detail in section 6.
2.1 Raw materials
2.1.1 Phosphate rock

There are two main types of phosphate rock deposits, sedimentary and igneous, which have widely differing
mineralogical, textural and chemical characteristics (table 3). The phosphate minerals in both types of ore are of the
apatite group, of which the most commonly encountered variants are “fluorapatite” [Ca10(PO4) 6(F,OH)2] and
“francolite” [Ca10(PO4) 6-x(CO3) x (F,OH)2+x]. Fluorapatite predominates in igneous rocks and francolite in sedimentary
phosphate rocks. Phosphate ores can vary widely according to their origin. Each rock has its own color, viscosity and
impurities. The impurities are mainly responsible for the individual behaviour of the ore [11]. Specifications for a
number of phosphate rocks are listed in Annex 2.
Tabel 3: Rough composition of main components and trace elements in sedimentary and igneous rocks.
Sedimentary ores Igneous ores
Main constituents (%wt) (% wt)
Phosphate (P2O5) 30 - 37 35 - 40
Calcium (CaO) 46 - 52 48 - 54
Fluorine (F) 3-4 1-4
Trace elements (ppm) (ppm)
Arsenic (As) 10 - 20 1 - 10
Cadmium (Cd) 5 - 50 0-2
Mercury (Hg) < 0,2 < 0,1
Heavy Metals (Pb, Zn, Cu, Ni, Cr) 200 - 800 50 - 150
Rare earth elements (REE) 100 - 900 1400 - 6300
Radioactivity (Bq/kg, Ra-226) 700 - 1400 10 - 110
Generally, the sedimentary deposits are associated with matter derived from living creatures. The apatite is in
admixture with gangue materials such as clay and sand. But even if the gangue materials could be completely
seperated the mineral itself is usually far from pure apatite [12]. It may incorporate silicate, aluminate, sulphate and
chloride in place of the phosphate while calcium may be replaced by other metals such as aluminium, iron,
magnesium, strontium, barium, sodium, potassium, cadmium, and rare earth elements. Due to its origin sedimentary
ores may contain organic material. This material can cause foaming problems during acid production. Compared to
igneous phosphates, sedimentary phosphates contain more carbonates and fluorides, and often more aluminium and
iron. Also they contain higher levels of heavy metals such as mercury, cadmium, arsenic, lead, zinc, copper, nickel
and chromium, and radionucleids such as uranium, radium and polonium. Sedimentary phosphate rock is found in a
large number of countries, amongst others Morocco, Tunesia, United States, Jordan, Israel, Syria, Togo and
Senegal.
Igneous phosphates are normally formed by the extrusion of magmatic material through solid rocks; the hot lava
solubilizes elements contained in the rock as it flows to the surface. Igneous phosphates are usually extremely
heterogeneous. The most common impurities are limestone and dolomite. However, the magmatic solution of other
elements is quite often considerable and the mine can have other mineral whealth besides that of phosphate.
Compared to sedimentary rocks, igneous rocks usually contain relatively high levels of rare earth metals such as
lanthanide and cerium. Igneous phosphate rock is predominantly found in Russia (Kola), Finland, South Africa and
Brazil.
About 85% of the global phosphate reserves is of sedimentary origin. Some 80% of the world phosphate production is
derived from sedimentary phosphate deposits. The phosphate content in currently mined rocks can range from over
40% to below 5%. The mined rock is further processed to remove the bulk of the gangue material and thus upgrade
the rock. Consequently, the rock concentrate contains an increased apatite content of an improved quality. The
beneficiation process usually allows a concentration of around 1.5x but higher ratios up to 9x are possible with some
rocks. After beneficiation, phosphate rock concentrate generally ranges from 26% to about 34% P2O5 and up to as
much as 42% [13]. Consequently phosphate rock usage ranges from approximately 2.5 to 3.5 ton per ton of P2O5.
2.1.2 Sulphuric acid

Sulphuric acid is used for the digestion of phosphate rock to form the product acid and calcium sulphate as by-
product. Sulphuric rock usage is about 3 ton per ton P2O5. There are various types of sulphuric acid:
• acid produced from elemental sulphur (sulphur-sulphuric acid);

• acid produced from pyrite (pyrite-acid);
• fatal acid: by-product acid from non-ferrous metal smelters processing sulfide ores;
• spent acid: acid produced from elemental sulphur, pyrite acid or fatal acid which, after being used, is released as
moderately concentrated acid in large quantities from many processes; this acid is either used directly, or after
concentration and purification;
• regenerated acid: reprocessed spent acid.
The types of sulphuric acid mainly used as raw material in the production of phosphoric acid are acid produced from
elemental sulphur, fatal acid and spent acid. The amounts of impurities introduced into the process by sulphuric acid
are generally low or negligible compared to the amount introduced by the phosphate rock. Only in the case of
mercury and possibly lead, sulphuric acid may contribute significantly, especially when fatal acid is the main type of
sulphuric acid used [14]. Typical mercury contents of fatal acid and acid based on elemental sulphur are presented in
table4. The table shows that the lowest levels of mercury are introduced, when sulphuric acid produced from
elemental sulphur is used. The mercury content of spent acid depends on the type of acid originally used. The
mercury content of other sulphuric acids, in general, lies within the extremes presented in table 4.
Table 4: Typical mercury contents of sulphuric acid
Type of acid Mercury content [ppm]
sulphur-sulphuric acid < 0,01
fatal acid 0,1 – 1

2.2 Process principles

Phosphoric acid is produced from the reaction of phosphate rock with sulphuric acid. In the rock the phosphate is
present in an insoluble form. When the rock is treated with strong sulphuric acid, the rock-lattice is destroyed and the
components pass into solution. In the wet phosphoric acid process phosphate rock may first need grinding to obtain
fine rock particles. The rock is then dissolved in phosphoric acid and sulphuric acid. Besides dissolving the rock,
sulphuric acid is added to precipitate the calcium present as calcium sulphate (reaction). During the reaction cooling
is required as the overall reaction is exothermic. After conversion of the rock the calcium sulphate and phosphoric
acid are separated by filtration. To produce merchant-grade phosphoric acid (52-54%), additional concentration of
the product acid is usually required. The overall reaction can be represented by the following reaction equation:
Ca 10 (PO4 )6 F 2 CaCO 3 + 11 H 2 SO4 → 6 H 3 PO4 + 11 CaSO 4 + 2 HF + CO 2 + H 2 O
Calcium sulphate exists in a number of different crystal forms depending particularly on the prevailing conditions of
temperature, P2O5 concentration in the reaction slurry and free sulphate level. The process operating conditions are
generally selected so that the calcium sulphate will be precipitated in either the dihydrate (CaSO4.2H2O) or
hemihydrate (CaSO4. ½H2O) form; 26-32% P2O5 at 70-80°C for dihydrate precipitation and 40-52% at 90-110°C for
hemihydrate precipitation.
For the production of wet phosphoric acid five principal process routes are available [2, 6, 8, 15, 16, 17, 18]. In
principle, each process type can process all types of phosphate rock. However, each phosphate rock is different and
has its own processing characteristics. A change of rock or rock type may therefore require significant process
adjustments.
2.3 Wet phosphoric acid production processes

In the following paragraphs the five principal process routes are roughly outlined, and their main differences are
discussed. In table 5 the processes are summarised with respect to some important environmental aspects, i.e.
P2O5-efficiency, some important energy aspects and the quality of the gypsum produced.
2.3.1 Dihydrate process

Most phosphoric acid plants in the world operate the dihydrate (DH) process. In this process most phosphate rocks
need particle size reduction, generally through the application of ball or rod mills. The phosphate rock is converted by
reaction with concentrated sulphuric acid. The process produces phosphoric acid of 26-32% P2O5 at 70-80°C. The
reaction temperature is controlled by passing the reaction slurry through a flash cooler or by using an air circulating
cooler. After reaction the slurry is filtered. The most common filtration equipment is of three basic types: tilting pan,
rotary table or travelling belt. In practice filtration is always vacuum assisted. Otherwise no reasonable rate of
separation would be achieved. The initial separation must be followed by thorough washing of the filter cake to ensure
a satisfactory recovery of soluble P2O5. Due to the low strength of the product acid significant concentration is
needed to produce a merchant-grade acid.
DH conditions w ater
T=80°C
phosphate rock reaction

w ater and filter D H - g y p su m
sulphuric acid crystallisation
w eak acid phosphoric acid

26-32%
Figuur 1: Diagram of the dihydrate process

2.3.2 Hemihydrate process

In the hemihydrate (HH) process coarser rock can be used than in the DH process. So grinding may not be
necessary. Apart from that, the process stages of the hemihydrate process are similar to those of the DH process.
The process is operated at temperatures of 90-110°C and a phosphoric acid strength is 40-52% P2O5. The higher
acid strength reduces the need for acid concentration and consequent energy requirements for this stage. Due to a
lower required excess in the reaction stage, in the HH process the sulphuric acid consumption per tonne of rock is
lower than in the DH process. However, the consumption per ton of P2O5 may not be different due to a lower P2O5-
yield of the HH process.
HH conditions w ater
T=100°C
phosphate rock reaction

w ater and filter H H - g y p su m
crystallisation
sulphuric acid
40-52%
Figuur 2: Diagram of the hemihydrate process
A clear disadvantage of the HH process is the low P2O5-efficiency; typically 90-94% compared to 94-96% for the DH
process. This is caused mainly by less favourable filtration conditions; under HH conditions the calcium sulphate
crystals tend to be smaller and the viscosity of the acid is higher than under DH conditions. In addition, water balance
considerations restrict the amount of wash water that can be used. Due to processing at a high acid strength only a
limited amount of filter cake wash water can be reused in the reaction stage.
The quality of the calcium sulphate produced by the hemihydrate process is lower than that produced by the DH
process, not only because of a higher P2O5-content, but also because of a higher level of impurities such as fluorine
and heavy metals. In general, the uptake of impurities in the calcium sulphate HH crystal lattice is higher than the
uptake in the DH form. On the other hand, as less sulphuric acid is used (less free sulphate) and more impurities end
up in the calcium sulphate, the acid produced by the HH process is generally purer than the acid produced by the DH
process.
2.3.3 Recrystallization processes

In the DH- and HH proces 4-10% of the P2O5 is retained in the filter cake. If the calcium sulphate is made to
recrystallise into its other hydrate, some of this loss will again pass into solution and can be recovered when the
recrystallised calcium sulphate is finally separated. Besides P2O5, also part of the impurities will again pass into
solution. Recrystallization, therefore, not only raises the overall process efficiency, but also yields cleaner calcium
sulphate.
2.3.3.1 Hemihydrate recrystallization process (single stage filtration)

In a hemihydrate recrystallization process (HRC-process), or hemi-dihydrate single stage filtration process (HDH-1
process), the first reactor operates under HH conditions. The succeeding reactors operate under conditions favouring
the rehydration of HH to DH (gypsum). After rehydration, or recrystallization, the gypsum and product acid are
separated by filtration and the filter cake is washed. The product acid from the HRC process is no more concentrated
than that from the DH process, but the gypsum is considerably purer.
HH conditions DH conditions w ater

T=100°C T=80°C
phosphate rock reaction re-

w ater and crystallisation filter D H - g y p su m
sulphuric acid crystallisation

30-32%
Figuur 3: Diagram of the hemihydrate ReCrystallization process (a HDH-1 process)
2.3.3.2 Hemi-dihydrate process (double stage filtration)

In a HDH-2 process it is possible to produce a concentrated acid directly (40-52% P2O5). In this process reaction
takes place under HH conditions. The HH and product acid are separated by filtration before recrystallization to DH.
After recrystallization the DH is filtered and washed. The acidic filtrate from the second stage is reused as washing
fluid in the first stage.
HH conditions DH conditions w ater

T=100°C T=80°C

sulphuric acid and filter crystallisation filter D H - g y p su m
crystallisation
w eak acid
phosphoric acid
40-52%
Figuur 4: Diagram of a Hemi-diydrate process (HDH-2)
2.3.3.3 Di-hemihydrate process (double stage filtration)

The DHH process produces a relatively pure gypsum and a moderate strength phoshoric acid (32-35% P2O5). In this
process initial reaction takes place under DH conditions, after which DH and product acid are separated in the first
filtration stage. Subsequently, the DH is recrystallised to HH. This conversion requires the input of heat (by steam).
Finally, the HH is filtered and washed in a second filtration step.
DH conditions HH conditions w ater

T=80°C T=100°C

sulphuric acid and filter crystallisation filter H H - g y p su m
crystallisation
w eak acid
phosphoric acid
32-38%
Figuur 5: Diagram of a Di-hemihydrate process (DHH)

Table 5: Some operating characteristics of phosphoric acid processes.
Process type Efficiency Energy aspects Gypsum quality
DH 94-96% P2O5 acid strength 26-32% P2O5, requires Impure DH

1)
evaporation (0,75% P2O5)
may require rock grinding
HH 90-94% P2O5 acid strength 40-52% P2O5, Impure HH
(1,1% P2O5)
may use coarse rock
HDH - 1 stage 97% P2O5 acid strength 30-32% P2O5, Relatively pure DH
lower H2SO4 consumption fine rock grind required
HDH - 2 stage 98.5% P2O5 acid strength 40-52% P2O5, Relatively pure DH
(0,19% P2O5)
low H2SO4 consumption may use coarse rock
DHH 98% P2O5 acid strength 32-38% P2O5, Relatively pure HH
lower H2SO4 consumption requires rock grinding
requires steam for gypsum conversion, DH
to HH
1) The main product is phosphoric acid with a commercial concentration of 52-54% P2O5.
2.4 Phosphoric acid purification processes

W et process phosphoric acid is purified by numerous methods and to a wide variety of standards depending on the
further application of the acid [2, 8, 9, 10, 19]. The most basic method, and the one which all suppliers of merchant-
grade acid carry out before shipment, is clarification, by settling or other mechanical means, to remove suspended
solids. In case the acid is used for the production of fertilizers usually no further treatment is applied.
Chemical purification methods can be employed if the acid is to be used for specific purposes, not requiring a high
quality. Active carbon treatment is the usual means of removing organic impurities. Fluorine is removed by adding
reactive silica and distilling off silicon tetrafluoride. Phosphate rock or lime may be added to the impure acid to
remove excess sulphate. Metals ions can be selectively precipitated by various chemicals. By adding a Na2S solution
to the acid arsenic can be precipitated as arsenic sulphate. Removal of other cationic impurities, especially Fe, Al, Mg
and Ca can be achieved by neutralizing the acid with sodium hydroxide or caustic soda. However, since the
phosphoric acid in this proces is converted to a phosphate salt solution, its uses are limited.
More elaborate techniques involving (organic) solvent treatment are used to obtain purer acid such as that required
for animal feed supplements (mainly cadmium removal) and especially the food industry. Liquid/liquid extraction
processes are most commenly used. Processes are operated for the separation of single components (e.g. uranium
and cadmium) as well as of practically all impurities in wet phosphoric acid. The quality of such purified acid equals
that of thermally produced acid. Besides liquid/liquid extraction processes also precipitation processes are being
employed. An example of such a process is the separation of cadmium by means of a complexing agent (an
alkyldithiophosphoric acid alkyl ester) as operated by Tessenderloo Chemie in Belgium.
All extraction and precipitation processes are supplementary processes and therefore only affect the acid quality.
Purification techniques integrated in the wet phosphoric acid process would give the possibility also to improve the
gypsum quality. Thus far, no such processes exist, but developments are in progress (see section 5.1).
3. Consumption levels and environmental aspects
In this section reference levels of input requirements (raw materials and utilities), emissions to air and water, waste
gypsum production and radio-nuclides releases are presented.
3.1 Consumption levels

Inputs for the phosphoric acid production consist of the raw materials phosphate rock and sulphuric acid, as well as
utility requirements, such as process water and cooling water, electric power and steam. Typical input requirements
for the production of phosphoric acid are presented in table 6 [6]. The specific consumptions depend mainly on the
composition of the rock used and the process used (need for rock grinding; required reaction temperature and acid
concentration; process efficiency; need for acid concentration, heating as well as cooling).
Table 6: Typical input requirements for the product of merchant-grade wet phosphoric acid.
Inputs Consumption [per ton P2O5]
Phosphate rock 2,6 - 3,5 ton
Sulphuric acid 2 - 4 ton

1) 3
Process water 4-7m
2) 3
Cooling water 100 - 150 m
Electric power 120 - 180 kWh

2)
Steam 0.5 - 2.2 ton
1)
not including scrubber water
2)
per ton of P2O5 produced as concentrated acid
3.2 Emissions and waste

The main environmental aspects of wet process phosphoric acid production are:
• the emission of gaseous fluorides to the atmosphere
• the emission of dust (secondary aspect)
• the discharge of effluent from off-gas treatment containing phoshorus and fluorine
• the disposal of the waste gypsum
• radioactivity
3.2.1 Fluoride emissions to air

Origin
Fluoride is present in most phosphate rocks to the extent of 2 - 4%; 20 - 40 kg/ton rock or about 60 - 120 kg/ton
P2O5. During the process fluorine is distributed between the product acid, the gypsum and the vapours generated in
the reactor and the acid concentration section. Initially, fluoride is released in the reaction as hydrogen fluoride (HF),
but in the presence of silica this reacts readily to form fluosilicic acid (H2SiF6), and compounds such as MgSiF6 and
H3AlF6. The fluosilicic acid may decompose under the influence of heat to give volatile silicon tetrafluoride and
hydrogen fluoride. The reactions involved are:
4 HF + SiO 2 → SiF4 + 2 H2 O
3 SiF 4 + 2 H 2 O → 2 H 2 SiF6 + SiO2
H 2 SiF 6 → SiF4 + 2 HF
In a dihydrate process the temperature is usually to low to cause the decomposition of fluosilicic acid. The majority of
the fluorine compounds will be evolved with the evaporator vapours during concentration of the weak phosphoric acid.
In the hemihydrate process most of the fluoride is released during the reaction. Fluoride will leave the reactor with the
vacuum cooler condenser water or with the cooling air, depending on the cooling system applied (flash cooler or air
circulating cooler). A typical fluoride distribution in the dihydrate and the hemihydrate processes is shown in table 7
[6].
Table 7: Typical fluorine distribution in dihydrate and hemihydrate processes
Dihydrate process (%) Hemihydrate process (%)
Acid 15 12
Gypsum 43 50
Reactor off-gas 5 8
Flash cooler vapour 3 30
Concentrator vapour 35 -
Impact
Fluorine is emitted to the atmosphere either as silicon tetrafluoride or hydrogen fluoride. Due to their accumulation in
plants, fluorine containing vapours may cause harm to the surroundings. A fluorine concentration of 0,02 mg/m3 in
the air may already be harmful for the vegetation, e.g. fruit trees [5].
3.2.2 Dust emission to air

Origin
The emission of dust originates from the unloading, handling and grinding of phosphate rock. Phosphate rock is
generally supplied by ship. It is unloaded by cranes and further transported to storage and grinding section by
conveyor belts or trucks.
Impact
Size of the dust particles is generally divided into two principal groups: coarse particles larger than 2.5 µm and fine
particles smaller than 2.5 µm. Especially inhalation of small particles, which have air dispersion characteristics similar
to gaseous compounds, may cause lung function problems. Inhalation of dust may also result in enhanced exposure
to radiation since phosphate rock generally contains enhanced levels of radioactive substances like 226Ra, 210Pb and
210
Po. In addition dust may be a troublesome nuisance for the surrounding area of the plant location as it contributes
to objects getting dusty through deposition, which may also lead to pollution of soil and water, either directly or via
washing away of deposited dust with rain.
3.2.3 Emissions of liquid effluents to water

Origin
Liquid emissions mainly consist of effluents originating from vacuum cooler condensors and gas scrubbing systems
which are used for cleaning and condensation of the vapours that evolve in the various stages of the process. These
vapours, and consequently the effluents, contain mainly fluoride and a small amount of phosphoric acid. The
effluents, therefore, are acidic.
Impact
The most serious effect of an acidulous discharge is the change in pH. This can affect most species of fish, aquatic
life and vegetation. Soluble fluorine may have toxic effects on aquatic life and humans (fluorosis). The phosphate may
contribute to the overfertilisation (eutrophication) of water systems which results in enhanced algae growth.
3.2.4 Waste gypsum

Gypsum is an unavoidable by-product in wet phosphoric acid production; for every ton of phosphoric acid (P2O5)
around 4-5 ton of gypsum is produced. Phosphate rock contains a range of impurities (see table 3). In the process
the impurities are distributed between the product acid and the calcium sulphate. Table 8 shows a typical distribution
of the impurities for a hemihydrate recrystallization process [20, 21]. In HDH-2 and DHH processes the amount of
impurities that end up in the gypsum is slightly less, while in DH and HH processes the amount of impurities that end
up in the gypsum is usually larger. In general, mercury, lead and the rare earth metals end up mainly in the gypsum.
This also holds for the radioactive components radium-226 (226Ra), lead-210 (210Pb) and polonium-210 (210Po).
Arsenic and the other heavy metals like cadmium, zinc, nickel and chromium end up mainly in the acid. Also uranium-
238 (238U) almost completely ends up in the acid. Apart from these general characteristics, the exact distribution of
the impurities is determined by type of process and the phosphate rock used. The possibilities to influence the
distribution are limited.
Table 8: Typical distribution of impurities between waste gypsum and product acid for a hemihydrate
recrystallization process.
type of impurity % impurity in gypsum % impurity in acid

Cadmium 0-5 95 - 100
Mercury 100 0
Arsenic 0-5 95 - 100
Lead 100 0
2)
Copper 30 - 60 40 - 70
Zinc 0-5 95 - 100
Nickel 0 - 10 90 - 100
Chromium 0-5 95 - 100
1)
rare earth elements 90 - 100 0 - 10
uranium-238 0 100
radium-226, lead-210, polonium-210 100 0
1)
The elements scandium, yttrium, lanthaan, cerium, praseodymium, neodymium, samarium, europium, gadolinium, terbium,
dysprosium, holmium, erbium, thulium, ytterbium, lutetium; underlined are the elements that are the most abundant.
2)
The distribution of copper, zinc, nickel and chromium usually lies in the same range. However, deviations may occur as a result
of the phosphate rock used.
Because of the size of the gypsum production and the type and level of impurities in the gypsum, this by-product
constitutes a serious environmental problem. Basically, three options exist to deal with the problem:
• discharge into water;

• storage on land;
• useful application.
Discharging into water and storage on land are the common methods of gypsum disposal. Local conditions determine
usually the type of disposal. Important factors are the scale of the operation, geographical and geological factors, the
local population density and the local perception of risk, and local usage of ground water [22]. Up till now only very
limited use is made of phosphogypsum as a resource because of quality restrictions, usually related to the relatively
high level of radioactive substances and residual phosphorus in the gypsum. At this moment, 20 - 25% of the
phosphogypsum of the Prayon-Rupel plant in Engis (Belgium) is used for the production of plaster (Knauf). In
addition, small amounts of the gypsum of the Kemira plant in Siilinjarvi (Finland) is used for various applications.
Table 9 gives an overview of the European phosphoric acid plants and the method of gypsum disposal employed [5,
7, 23].
Table 9: Overview of gypsum disposal methods in Western-Europe phosphoric acid plants
Plants Phosphate rock used Type of Method of gypsum Comments

process disposal
Netherlands
Hydro Agri Rotterdam Jordan (sedimentary) HDH-2 Discharge into sea Agreement with authorities to re-use gypsum with
minimum 90%, or to reduce the gypsum contaminants,
Kemira Pernis Kovdor (igneous)/ HDH-1 Discharge into sea based on heavy metals and radio-nuclides, with 70-
Jordan (sed.) 90%, within 10 years. For the re-use of gypsum a pilot
recovery plant is in use. Market study of commercial
use of gypsum (as building materials) indicates
positive results
Spain
Fertiberia S.L Mainly Moroccan rock, ? Stockpiled on land Local authorities have issued instructions, constraints
also Togo and Senegal (discharge of run-off and deadlines to meet environmental regulations
FMC Foret, SA rock (all sed.) ? into sea)
Belgium
Rhone-Poulenc Chemie Phalaborwa (ign.) ? Stockpiled on land Reuse without further ipgrading of gypsum is
investigated. Results were negative because of
contamination of gypsum.
Societe Chimique Prayon- Phalaborwa (ign.)/ DHH Stockpiled on land and Sells 20-25% of its gypsum for use in building products
Rupel SA Bucraa (Morocco sed.) partial reuse
and/or Kola
(ign.)/Jordan (sed.)
Finland
Kemira Chemicals Oy Siilinjarvi (igneous) HH Stockpiled on land Partial use of gypsum for the production of wood-chip-
gypsum wall plates and paper coating applications
(1991)
France
Grand Quevilly Moroccan rock (sed) ? Stockpiled on land Closed cycle pond system
Greece
Chemical Industries of ? ? Stockpiled on land Removal of gypsum by truck. There is no double
Northern Greece SA filtration process. The still acidic gypsum is brought to
suitable land, which is filled and covered with
Phosphoric fertilisers ? ? Stockpiled on land agricultural earth.
industry Ltd.
3.2.4.1 Impact of phosphogypsum discharge into water

Besides relatively harmless gypsum, phosphogypsum contains many substances which, owing to their harmful
properties (acidity, eutrophication, toxicity, persistency, accumulation), pose great risks to the aquatic environment.
The main substances and effects are:
• residual acidity (Phosphoric acid): most species of fish, aquatic life and vegetation are sensitive to changes in
pH;.
• phosphate: contributes to eutrophication resulting in enhanced algae growth.
• fluoride: soluble fluoride compounds contribute to acidity, while fluoride itself has harmful effects (flourosis), (The
discharge of fluoride is mainly harmful in surface water. At the pH-value of sea water fluoride will precipitate as
calcium fluoride);
• heavy metals (Cd, As, Hg, Pb, Cu, Zn, Ni, Cr): toxic, persistent and are known to accumulate in organisms;
• rare earth elements : toxic, persistent, and there are indications for accumulation in aquatic organisms (The
solubility of REE compounds in water is very low. In the Netherlands this has led to considerable debate on the
subject of the bio-availability of rare earth metals. In general the riks associated to REE are considered low.);
• radionuclides: radiological exposure (radio-toxicity).
3.2.4.2 Impact of phosphogypsum storage on land

For the design of land based phosphogypsum disposal sites, local geology, permeability of surface layers and the
flow of the local ground water are important aspects. Two methods for landfill disposal are being used [5, 6, 24]:
1. The gypsum is mixed with water from the acid process and pumped as a slurry to settling ponds. The acidic
overflow water, which also contains considerable levels of contaminants (fluoride, heavy metals), may be
recycled to the plant, resulting in a reduction in the loss of phosphorus and a reduction in water consumption.
The alternative is to discharge this water into a river or the sea.
2. The gypsum is transported in dry form from the plant to the disposal site (amongst others at Kemira in Finland).
The advantage of this method is that the phosphoric acid plant water balance is independent of the gypsum
transport requirements, and does not lead to discharge of contaminated process water into a river or the sea.
To avoid soil pollution, and the pollution of ground water and surface water by acidic and contaminated
phosphogypsum leachate and run-off (process water and rain water), serious preventive measures are necessary,
such as seepage collection ditches, intercept wells, natural barriers, lining systems and immobilisation of soluble
P2O5 and trace elements by neutralisation [6, 24, 25]. Besides control during the built-up of a gypsum stack, the run-
off from gypsum stacks will require treatment for many years after the acid plant has ceased production [26, 27].
W aste gypsum piles are a source of radon emission to the environment [26, 28]. Humans (and animal live) living in
the vicinity of a phosphogypsum stack may be exposed to enhanced levels of radiation. The gypsum contains
enhanced levels of 226Ra. The major concern of materials which contain 226Ra is the production of radon-222 (222Rn),
an inert noble gas that does not form any chemical bonds and can escape into the atmosphere. Radon with a
relatively short half-life of 3,8 days, decays further into short lived radioactive solid products. These ionic products
attach rapidly to aerosols and dust particles in the air, and can thus be inhaled and deposited in the lungs, thereby
increasing the risk of lung cancer. A problem related to the emission of radon is the possible dust emission of a
gypsum stack as a result of erosion. The dust itself, containing radium, can be inhaled, but can also emit radon.
3.2.4.3 Useful application of phoshogypsum

In principle, phosphogypsum can be used for the same purposes as natural gypsum or gypsum originating from flue
gas desulphurisation (FGD). However, apart from economic considerations, useful application of phosphogypsum is
only possible if its quality meets required specifications. In general, this will come down to the production of
phosphogypsum with a quality comparable to that of other gypsum resources. This can be done by adjusting the
process so that high quality gypsum is produced directly, or by upgrading of gypsum that does not meet the
specifications (Further details on useful application of phosphogypsum are given in sections 4.3, 6.4 and Annex 3). In
case all phosphogypsum can be applied usefully there will be no gypsum disposal problems as above. If only a part
can be used, the remaining will still have to be discharged into water or dumped on land.
3.2.5 Radioactivity
Origin
All natural materials contain naturally occurring radioactive nuclides (radionuclides). The source of these
radionuclides are uranium-238 (238U), uranium-235 (235U) and thorium-232 (232Th) which have very long half-lives.
238
U, 235U and 232Th (the so-called mother radionuclides) decay via a chain of daughter radionuclides (which may have
relatively long half-lives) to stable nuclides. 238U is the most abundant one of the three mother radionuclides. It
amounts up to approximately 10 times the amounts of 232Th and 235U.
Consequently, the radioactivity of phosphate rock is mainly caused by radionuclides from the radioactive decay series
238
U. In the undisturbed crust of the earth a radioactive decay series is (expected to be) in equilibrium. This means
that the activities of all members of the series are equal to that of the long-lived parent, i.e. 238U. 238U decays via
seven different chemical elements and ends with a stable lead isotope (206Pb). The radionuclides emit α- or β -
radiation as they decay to other radionuclides. The radionuclides radium-226 (226Ra), radon-222 (222Rn), lead-210
( 210Pb) and polonium-210 (210Po) are part of the 238U decay series.
The radionuclides content in phosphate rock strongly depends on the origin of the rock. Sedimentary rock contains
more 238U and its daughter radionuclides than igneous rock. During the phosphoric acid production process the
radionuclides will be divided mainly between the product acid and the by-product gypsum, although other emission
sources may also contain limited amounts of radionuclides. For the by-product gypsum the radionuclides 226Ra, 210Pb
and 210Po are important. 238U, on the other hand, will almost completely end up in the product acid. 222Rn, as a decay
product from 226Ra, is generated as a gas which is emitted to the air. The diagram below indicates the flows that may
cause exposure of humans to radionuclides from a phosphoric acid plant.
dust emission (U-238) dust emission (U-238)

Ra-226
phosphate rock phosphate rock phosphoric acid phosphoric acid

(U-238) storage plant (U-238)
Ra-226 other w ast e (Ra-226): scale (maintenance), piping

gypsum (226-Ra)
Figuur 6: Diagram showing the flows from a phosphoric acid plant that may cause exposure of humans to
radionuclides
Impact
The presence of 238U and its daughters 226Ra, 222Rn, 210Pb and 210Po causes radiological exposure of humans. The
exposure of humans can be divided into exposure of workers and exposure of the public. Radiological exposure of
workers can occur by phosphate rock storage, handling and grinding of phosphate rock and storage of the end
products (the fertilizers), and to a much lower extent by transhipment of phosphate rock. Radiological exposure of the
public can occur by exposure to the discharge of the by-product gypsum and to a lower extent by direct exposure to
the stored phosphate rock and emissions of dust originating from phosphate rock transhipment, storage and grinding.
However, for waste gypsum discharge more potential pathways of radiological exposure may be considered. When
phosphogypsum is discharged into water, 226Ra is partially dissolved in the water phase and partially bound to
suspended material. When 226Ra ends up in sediment, it remains a source of other nuclides lower down the uranium
series. A potential pathway for exposure of humans is the use of contaminated mud originating from dredging the
harbour for construction purposes (it is common practice in the Netherlands to use this material for terrain elevation).
In this case, increased levels of 222Rn gas (226Ra decay product) in indoor air may occur.
Another potential pathway for exposure is by 210Pb and 210Po (226Ra decay products). These radionuclides pose a
radiological problem as they are strongly accumulated by several aquatic organisms (e.g. fish) which may be
consumed by humans.
When phosphogypsum is stored on land, there are four potential pathways for exposure of humans to radionuclides:
• Direct exposure from the gypsum stack;
• Exposure caused by accumulation of radionuclides by aquatic organisms from gypsum stack rainwater run-off;
• Exposure by emissions of dust caused by wind;
• Exposure by 222Rn gas inhalation emitted from the gypsum stack.
3.3 Diffuse emissions resulting from product acid use

In wet phosphoric acid processes the bulk of the heavy metals, among which cadmium, do not end up in the waste
by-product, but in the phosphoric acid itself. Eventually, these impurities end up diffusively in the environment
through the use of end products, mainly fertilizers, based on the intermediate phosphoric acid (see also table 8) [29,
30]. This may lead to soil pollution and ground water pollution in area’s where fertilizer repeatedly and intensively
used. Through uptake by crops, these impurities may be introduced into the foodchain and may be harmful to
humans. With regard to these aspects cadmium has received considerable attention [5, 31, 32]. It has led authorities
in several countries to propose or implement Cd limits for P fertilizers. These limits are shown in table 10 [30].
Tabel 10: Proposed or implemented Cd limits for P fertilizers in several countries.
Country Cd limit mg/kg P Effective year Country Cd limit mg/kg Effective year
P
Australia 450 in effect Germany 200 voluntary
350 1995 Japan 340 in effect
300 2000 Norway 100 in effect
Austria 120 in effect 50 1995
1)
Belgium 200 voluntary Sweden 100 in effect
Denmark 150 1988 Switzerland 50 in effect
110 1995 The Netherlands 35
Finland 50 in effect
1)
In addition, Sweden has imposed an tax on fertilizers with Cd concentrations between 5 and 100 mg Cd/kg P.
4. Emission abatement measures and techniques
In this section measures and techniques are considered to prevent or reduce emissions to air and water, and to
minimize waste. First, general preventive measures are discussed (before pollution arises). These measures concern
the choice of phosphate rock and the type of process to be used. These measures affect all environmental impacts of
phosphoric acid production. Next, a number of specific techniques and measures (end-of-pipe) are discussed which
are applied to deal with specific environmental aspects of phosphoric acid production such as fluorine and dust
emissions to air. Useful application of phosphogypsum and the use of the nitrophosphoric acid process as an
possible alternative to the wet phosphoric acid process are discussed separately.
4.1 General preventive measures
4.1.1 Application of high-grade phosphate rock

From the phosphoric acid producer’s point of view, the best possible phosphate rock would consist entirely of
tricalcium phosphate, Ca3(PO4) 2. The impurities in phosphate rock are mostly undesirable for an assortment of
reasons - economic, technical and environmental.
The most basic objection to anionic impurities is that, by taking the place of phosphate, they increase the CaO/P2O5
ratio of the phosphate rock. An increase in this ratio means an increase in the amount of acidulating agent required
per ton of P2O5 processed, and thus impairs the economics of the process. Per ton of P2O5 it also means an increase
in the mass of calcium sulphate produced requiring disposal. For producers in some areas, like in the Netherlands,
calcium sulphate disposal is the most serious problem that they have to face. Apart from these problems, most of the
individual impurities cause problems arising out of their chemical properties. They can give rise to environmental and
toxic hazards as discussed in the previous chapter. Furthermore, they can interfere in the phosphoric acid reaction
system (scaling, corrossion) or influence the filtration (crystal size and shape, slurry viscosity), affecting the
efficiency of the phosphoric acid production process. Also, they may impair the quality of the product(s), particularly
for use in downstream processes [11, 12]. If dealing with the gypsum disposal problem requires finding useful
application for the gypsum, this latter aspect does not only hold for the acid product but also for the gypsum by-
product; clean, pure gypsum offers more and better opportunities for useful application than highly contaminated
gypsum. So, for an assortment of reasons it is preferable to use phosphate rocks with a high P2O5 content and a low
impurity content.
4.1.2 Application of an high efficiency phosphoric acid process

The P2O5 recovery efficiency of a phosphoric acid plant is an important environmental parameter. With increasing
efficiency, the consumption of a particular phosphate rock per ton of P2O5 produced will decrease, thus reducing the
amount of impurities that will enter and will have to leave the process. An increase in efficiency means that per ton of
P2O5 less sulphuric acid is required and less gypsum is produced. Furthermore, a cleaner gypsum will be produced,
especially with respect to P-content, thus enhancing the possibility to find a useful application for the gypsum.
With respect to P2O5 recovery efficiency, the data shown in table 5 in section 2.3 clearly show that the
recrystallization processes (HDH-1, HDH-2 and DHH) are to be preferred over the more straightforward dihydrate
and hemihydrate processes.
P2O5 which leaves the process with the gypsum consists both of small undissolved phosphate rock particles and
phosphoric acid still adhering to the gypsum after filtration. With respect to the latter type of loss a further
optimisation can be obtained by an end-of-pipe repulp filter [6, 22]. By re-slurrying and washing the gypsum, followed
by an extra filtration step, most of the free acid which is not removed in a previous filtration step, can be removed in
this filter, resulting in a higher P2O5 efficiency and a higher grade gypsum.
4.2 Specific techniques and measures to minimize emissions and waste
4.2.1 Measures to prevent fluoride emissions to air

Fluoride in the form of HF and SiF4, which evolves during the digestion of phosphate rock and during the
concentration of phosphoric acid to 54% P2O5, can be removed by a number of different scrubbing systems. The
fluorine scrubber is normally an unpacked spray tower made of rubber-lined steel, which is operated at atmospheric
pressure. Other types such as packed bed, cross-flow venturi and cyclonic column scrubbers are also extensively
used [6, 18, 33,].
Many companies recover the fluorine as fluosilicic acid (H2SiF6) which can be used for the production of aluminium
fluoride, and other fluorine compounds such as sodium and/or potassium fluosilicates. In this case a dilute solution of
fluosilicic acid is used as the scrubbing liquid. The reaction to fluosilicic acid results in the formation of free silica. By
carefully controlling the strength of the fluosilicic acid the deposition of silsica is controlled. The silica is removed by
filtration. Usually, a product containing 20-25% fluosilicic acid is recovered in the fluoride recovery system. With two
or more absorbers a recovery efficiency of 99% or more can be achieved. According to EFMA [6] achievable fluoride
emission levels for new plants are 5 mg/Nm3 (40 g/ton P2O5). In The Netherlands, emission levels in the order of 1-5
mg/Nm3 are achieved in the existing plants [34, 35].
To minimize fluosilicic acid contamination with P2O5, or just to minimize contamination of the scrubber effluent,
vapours from vacuum flash coolers and vacuum evaporators are usually first led through a separator for the removal
of phosphoric acid droplets that are entrained with the vapours. If the fluorine is not recovered the scrubber effluent
will be discharged. Before discharge the effluent can be neutralized with lime or limestone to precipitate fluorine as
solid calcium fluoride. As an alternative sea water can be used as scrubbing liquid. Also in sea water fluoride reacts
to the harmless substance CaF2.
4.2.2 Measures to prevent dust emissions to air

The spread of phosphate rock dust from unloading of ships and transportation is commonly prevented by using
covered conveyor belts and indoor storage [6]. Further dispersion of phosphate rock dust (by wind or rain) can be
prevented by good housekeeping measures such as frequently cleaning/sweeping the plant grounds and the quay.
Dust originating from phosphate rock grinding can be recovered by passing the dust containing air through fabric
filters. In general, dust emission levels of 10 mg/Nm3 can be achieved by fabric filters. However, rock particles are
rather sticky and therefore easily stick to the filter cloth. This has a negative effect on the recovery efficiency of a
fabric filter. According to EFMA [6], the achievable dust emission level of fabric filters in new phosphoric acid plants
is: 50 mg/Nm3. By use of fabric filters, in The Netherlands, dust emission levels of less than 30 mg/Nm3 are achieved
in the existing plants [34, 35].
4.2.3 Measures to prevent emissions to water

Emissions to water are mainly formed by the effluents from the fluorine scrubbers and the direct contact condensors.
In phosphoric acid plants, in the systems operating under vacuum, direct contact condensors are normally used to
condense the vapours from the the flash cooler or the evaporator, so as to maintain a vacuum (vacuum pumps are
used to remove the non-condensable gases). The vapours are led through the condensor either directly or after
treatment in a fluorine scrubber.
4.2.3.1 Fluorine emissions

As described above many companies recover the fluorine as fluosilicic acid (H2SiF6). If the fluorine is not recovered,
or cannot be recoverd for technical reasons (excessive silica formation resulting in plugging of the scrubber), the
scrubber effluent will be discharged. Before discharge the effluent can be neutralized with lime or limestone to
precipitate fluorine as solid calcium fluoride. As an alternative sea water can be used as scrubbing liquid. Also in sea
water fluoride reacts to the harmless substance CaF2.
To prevent fluoride emissions with condensor water, the application of an indirect condensation system may be
considered, instead of a direct contact condenser, thus avoiding that condensor water becomes contaminated with
fluoride [6].
4.2.3.2 Phosphate emissions

To minimize contamination of the scrubber effluent with P2O5, vapours from vacuum flash coolers and vacuum
evaporators are usually first led through a separator for the removal of phosphoric acid droplets that are entrained
with the vapours [6, 33].
Despite the use of a separator, gas scrubber and condensor effluents may contain low levels of phosphoric acid.
Phosphate removal can be achieved by magnesium ammonium phosphate (struvite) or by calcium phosphate
precipitation [36, 37]. Although several phosphorus recovery plants have been implemented, phosphate removal has
not been practiced yet in phosphoric acid plants. These techniques are, therefore, outlined in section 5: Emerging
techniques.
4.3 Useful application of phosphogypsum

Depending on local conditions there are two basic disposal options for phosphogypsum; disposal to sea or disposal
on land. The gypsum contains a wide range of impurities, some of which are considered a potential hazard to the
environment and public health (see section 3.2.4). Because of this, there is a large pressure to end the practice of
gypsum diposal in the sea. In Europe, where most phosphoric acid plants discharged waste gypsum to the sea,
much of the industry chose the option of closing down, because the alternative option of land disposal was in most
cases impracticable, mainly as a result of agricultural policy changes and bad economies of scale (see section 1.2.1).
Locally, the disposal on land, however, also holds potential hazards for the environment and public health. Many of
the important considerations in the design and construction of gypsum disposal areas are therefore based on the
necessity to keep both the gypsum and the acidic stack effluent within a closed system [24, 25]. To avoid pollution of
the subsoil and ground water pollution by acidic and contaminated phosphogypsum leachate and run-off (process
water and rain water), severe preventive measures are necessary, such as seepage collection ditches, intercept
wells, natural barriers and lining systems. Furthermore, to prevent or minimize pollution of the surrounding area and
watersystems, it is necessary to make provisions for effluent overflow. The effluent requires appropriate treatment,
such as immobilisation of soluble P2O5 and trace elements by neutralisation, before it can be released from the
system. Besides control during the built-up of a gypsum stack, the run-off from gypsum stacks will require treatment
for many years after the acid plant has ceased production [26, 27].
A third and interesting way of dealing with the phosphogypsum disposal problem is to improve the quality of the
gypsum, so that it can be used as a resource like natural gypsum and flue gas desulphurization gypsum. Many
examples of phosphogypsum usage exist [7, 23, 27, 38, 39, 40]. Table 11 gives an overview of phosphogypsum
applications. It should be noted that different commercial applications require different types of gypsum. A short
description of the possible applications is outlined in Annex 3. In Europa, at this moment, only phosphogypsum
produced by Prayon Rupel (Belgium) is used on a commercial scale (20-25% of the total production). The gypsum is
used as plaster. In Finland (Kemira), some phosphogypsum is applied in the paper industry (see table 9). In the
Netherlands, the application of phosphogypsum (Kemira) in a variety of gypsum building products (plaster, building
blocks, plasterboard) has been demonstrated on a pilot scale, with positive results.
In the past, not all efforts to use the gypsum have been succesful, mainly because of quality considerations. In most
cases the radioactivity aspects of the gypsum formed a problem. Also the residual acidity or P2O5 content of the
gypsum is an important factor. Application of phosphogypsum requires the production of a clean pure gypsum.
Measures that contribute to achieve this goal are outlined below.
Table 11: Overview of phophogypsum applications
Application Anhydrite, AH (CaSO4) Dihydrate, DH (CaSO4.2H2O) Hemihydrate, HH (CaSO4.½H2O)
Construction floor screed Cement (as setting regulator) plaster (stucco)

cement (as setting regulator) plasterboard
ceiling tiles
gypsum blocks
floor screed
Agriculture soil conditioner soil conditioner as a source of calcium and sulphur

as a source of calcium and sulpher carrier and filler in insecticides
carrier and filler in insecticides as filler in the production of fertilizer
as filler in the production of fertilizer
Industrial filler / pigment in variety of applications filler / pigment in variety of applications filler / pigment in variety of applications
uses/Other production of ammonium sulphate and
sulphuric acid
4.3.1 Phosphate rock

The production of clean gypsum requires the use of phosphate rock with low levels of impurities. Regarding size and
economy, construction materials, in particular in-door building products, are an important area of application for the
by-product gypsum. To enable this, it is important that the gypsum contains only low levels of radioactive
components, especially radium. The possibilities for useful application of phosphogypsum therefore will largely be
enhanced if phosphate rock with low levels of radionuclides are used.
4.3.2 Phosphoric acid production process

In the DH- and HH proces 4-10% of the P2O5 is retained in the filter cake. If the calcium sulphate is made to
recrystallise into its other hydrate, some of this loss will again pass into solution and can be recovered when the
recrystallised calcium sulphate is finally separated. Besides P2O5, also part of the impurities will again pass into
solution. Recrystallization, therefore, not only raises the overall process efficiency, but also yields cleaner calcium
sulphate.
In recrystallization processes with two-stage filtration phosphoric acid is separated from the gypsum before
recrystallization. Thus a substantial part of the impurities is removed from the system before recrystallization takes
place. This is not the case in recrystallization processes with single-stage filtration. Because of this the levels of
impurities in gypsum from two-stage filtration processes are generally lower than in gypsum from single-stage
filtration processes.
4.3.3 Repulp unit

With respect to P2O5 removal from the gypsum, a further optimisation of single-stage filtration processes can be
obtained by extending the process with an extra filtration step, or repulp filter unit [6, 24]. In this unit the gypsum is
re-slurried, washed and filtered thus removing most of the free acid which is not removed in the previous filtration
step.
4.3.4 Reduction of cadmium levels in waste gypsum by chloride dosing

If the cadmium content of phosphogypsum is a problem, the addition of chloride in the acidulation stage may be
considered [4, 16]. Chloride forms complexes with cadmium which are not incorporated in the gypsum crystals, but
stay in the acid. Consequently the phosphogypsum produced contains less cadmium. The addition of chloride may
put a strain onthe choice of construction materials because of an increase of corrosion.
4.3.5 Upgrading of phosphogypsum

It appears that many of the impurities present in phosphogypsum are enriched in the smallest gypsum particles [41,
42]. Among these impurities are mercury, the common heavy metals, the radionuclides and the lanthanides. By
separating a particle size fraction with the smallest particles the quality of the remaining gypsum can, therefore, be
improved substantially. Separation can be achieved by passing the gypsum through a hydrocyclone, as has been
demonstrated on a pilot scale by Kemira and Hydro Agri in The Netherlands. In this case only 4% of the total amount
of gypsum was separated as fines. Production on a commercial scale should be no problem as this does only require
more hydrocyclones and not a larger one.
Additional advantages of separation of the smallest particles from the gypsum slurry can be an improvement of the
washing and filtering characteristics of the gypsum. Pilot plant test of Kemira and Hydro Agri in the Netherlands
showed that upon washing and filtration of the remaining slurry after particle size separation by means of a
hydrocyclone, still a substantial amount of P2O5 was removed from the gypsum despite the fact that Kemira employs
a repulp filter in its regular process. Although not yet anticipated, it should be possible to return these P2O5-values to
the process thus increasing the P2O5 efficiency. After vacuum filtration a gypsum cake remains with a moisture
content of less than 10%. Such a value is required by the gypsum industry for further processing of the gypsum to
products.
The fines that are separated in the hydrocyclone are released as a dilute slurry (0.5-1 wt%). Because of the relatively
high impurity content of the fines it will not be easy to find a useful application for this fraction [43]. What remains are
the two basic options for disposal discussed above, namely discharge to sea or storage on land. In the latter case the
fines will first have to be recovered from the slurry, for instance by means of filtration.
4.4 The nitrophosphate route: an alternative phosphoric acid production process

The sulphuric route has become established as the industry standard for the production of phosphoric acid,
principally for economic reasons and because it provides a high flexibility in the range of (fertilizer) products that can
be made of the acid. The main alternative to the sulphuric route is the nitrophosphate route, in which nitric acid rather
than sulphuric acid is used for the digestion of phosphate rock [44, 45, 46]. Around 10-15% of the world phosphate
fertilizer production use the nitrophosphate route. The main advantage of the nitrophosphate route is that no gypsum
is produced, thus avoiding waste gypsum disposal problems. A diagram with the principal process steps of a nitro-
phosphoric acid process is shown in figure 7.
w ater and nitric acid

T=60-70°C T=0-20°C
phosphate rock filtration cooling/ Ca(NO 3) 2.5H2O
60% nitric acid reaction Ca(NO 3) 2- filtration slurry
(insolubles) crystallization
nitro-phos. acid
return acid to NPK fertilizer
insoluble matter production
Figuur 7: Diagram of a Nitro-phosphoric acid process
Use of nitric acid gives calcium nitrate tetrahydrate as a by-product. This can be upgraded to calcium nitrate
fertilizers or converted to ammonium nitrate and calcium carbonate. When using nitric acid it is, however, not
economically possible to remove the calcium, nitrate and certain dissolved impurities to the standard required for
making phosphoric acid as a commercial product. After removal of the calcium, therefore, nitro-phosphoric acid is
always turned into fertilizers on the spot.
A disadvantage of the nitro-route is that the acid will always contain calcium and nitrate ions resulting in limitations in
water-soluble P2O5 (recombination with phosphate to water-insoluble dicalciumphosphate during fertilizer
manufacture), and the N/P2O5 ratio of the products that can be made of the acid. Under reaction conditions calcium
nitrate is soluble. To remove calcium nitrate, generally, the reaction liquor is cooled so that calcium nitrate partially
crystallizes. About 60% of the calcium nitrate comes out of solution at 20 ºC. At -5 ºC this is about 85-90%.
Furthermore, the nitro-phosphoric acid is more dilute so that more energy is required to remove the water. A specific
environmental disadvantage is the release of NOx from the digestion unit. With respect to environmental impact it is
further noticed that in the nitro-route all phosphate rock impurities end up in the acid, and will finally end up in the
environment diffusively through the use of end product fertilizers.
5. Emerging techniques
5.1 Phosphate removal from waste water effluents

W aste water from phosphoric acid plant may contain considerable concentrations of phosphates, in particular the
effluents from gas scrubbers. Phosphates in solution can be precipitated by the addition of flocculating agents, such
as iron and aluminium salts. However, this method will generally preclude recycling of the phosphate as the resulting
iron or aluminium compounds are not compatible with the technologies currently used in the phosphate industry. A
better prospect for recycle of phosphates from waste water lies in processes that precipitate crystalline products of
reasonable purity, that could be used as a substitute raw material in standard phosphate fertilizer production
technology or directly as fertilizer material. Several processes of this nature have been developed [36, 37]. Main
products are usually either (insoluble) hydroxy-apatite or soluble magnesium ammonium phosphate (struvite). In most
of these processes phosphate recovery takes place in fluidised, agitated or fixed bed crystallization columns. Usually,
sand or phosphate rock particles are used as seed material. Hydroxy, calcium and magnesium ions are usually added
to the process to facilitate precipitation.
Several pilot and full scale processes already operate in different countries, recovering phosphates from waste water
streams through calcium phosphate formation:
• DHV Crystalactor process at the waste water plants of Westerbork (12,000 pe demonstration plant), Heemstede
(35,000 pe) and Geestmerambacht (230,000 pe) in the Netherlands;
• pilot plant developed by DHV and Essex and Suffolk Water at Chelmsford sewage works, UK;
• pilot plant developed by Karlsruhe University at Darmstad Süd sewage works in Germany;
• demonstration plant (50,000 pe) developed by Sydney Water Board at Warriewood, Australia;
• three plants constructed by Kurita, Japan
• a fixed bed precipitation installation (160 m3/hr) is operational at the Mercedes motor car factory at Gagenau,
Germany.
Full scale processes which recover phosphate as struvite are already operational or being built in Japan and in the
Netherlands:
• the DHV Crystalactor fluid bed process is used in a full scale struvite recovery installation at the AVEBE potato
processing plant in the Netherlands (150 m3/hr);
• the Unitika Ltd (Osaka) struvite precipitation process (Phosnix process) is already in application at the Ube
Industries Sakai plant (industrial waste waters) and at the Shimane Prefecture sewage works in Japan;
No examples are available for phosphate recovery from waste waters of phosphoric acid plants. Kemira Agro Pernis
(Netherlands) has investigated the fluidised bed process of DHV (Crystalactor process) for phosphate removal from
the effluents of the gas scrubber systems. In the process phosphate and also fluoride would precipitate and
crystallize on seed material (phosphate rock) under the controlled addition of lime (CaO). The process would produce
a slurry which can be recycled to the phosphoric acid process (solids roughly consist of 45% calciumphosphate, 45%
calciumfluoride and 10% phosphate rock). The treated effluent could be recycled to the gas scrubber system, thus
creating a closed loop system. Unfortunately, the installation appeared not to be economically feasible at the time
(1991).
5.2 In-process phosphoric acid purification

At the Technical University of Delft (the Netherlands) a process is being developed for removal of heavy metal ions
from process streams under conditions typically encountered in wet phosphoric acid processes, especially during
conversion of gypsum from hemihydrate to dihydrate in recrystallization processes. In-process removal of impurities
will yield a cleaner phosphoric acid as well as a cleaner gypsum thus enhancing the chances for useful application of
gypsum, also when phosphate rocks with relatively high levels of impurities are used. The process is based on the
liquid membrane or liquid-liquid extraction technique. An experimental transverse flow hollow fiber module has been
designed and built. Lab-scale tests have shown positive recovery results for lead, mercury, copper, cadmium and
cerium from actual plant acid (1% gypsum, 70 ºC) [40, 47]. Further research is aimed at optimization and scale-up of
the test module, the finding of better extraction liquids and the specific removal of radium (other techniques, e.g.
specific precipitation with of radium with barium salts), as this appears to be the most limitative element for useful
application of phosphogypsum.
6. Phosphoric acid production: the Dutch situation
In previous sections, general background information is presented concerning wet phosphoric acid production. In this
section the specific Dutch situation is described in brief, including the plans for a plant to upgrade waste-gypsum to a
purity that is acceptable for the gypsum to be used as a raw material, for example for the production of building
products.
Since the mid-eighties the objectives of the policy pursued by the Dutch authorities with respect to the wet
phosphoric acid production are:
• substantial reduction of the amount of contaminants discharged with the phosphogypsum to the sea;
• substantial reduction of the cadmium content of phosphoric acid following concern of build-up of cadmium in soils
as a result of phosphoric acid based fertilizer use (The target for fertilizers in the year 2000 was set at 15 mg
Cd/kg P2O5. The actual cadmium content at that time amounted to more than 60 mg Cd/kg P2O5. );
• useful application of at least 90% of the phosphogypsum produced.
Since then many adjustments have been carried through with respect to use of raw materials, the phosphoric acid
process and process management (good housekeeping, etc.), which have resulted in major reductions of emissions.
In addition a specific research program has been executed with the aim to realize useful application of the gypsum.
Pilot plant tests have demonstrated the technical feasibility of the production of a gypsum product that meets all
specifications required for application of the gypsum in (in-door) building products like plaster, plasterboard and
gypsum building blocks. The gypsum can be produced for a price which is comparable to the price for natural
gypsum.
6.1 Process description
6.1.1 Kemira Agro Pernis (KAP)

Kemira Agro Pernis produces phosphoric acid at the Pernis location, situated in the Rotterdam harbour. The
production capacity of the plant is 225 kton per year. Kemira employs a hemi-dihydrate recrystallization process with
single stage filtration. The main process consists of two reaction systems and a single filtration system. The process
is extended with an extra gypsum washing and filtration step (repulp filter unit) for further removal of P2O5 which still
adheres to the gypsum after filtration and washing. A diagram of the process is presented below [48].
In the first reaction system phosphate rock, diluted sulphuric acid (75%) and return acid (20% phosphoric acid
coming from the filtration section) are mixed, and react at a temperature of 90°C to form hemihydraat gypsum and
phosphoric acid. In the second reaction system the reaction slurry is cooled to 60°C by blowing air through the
mixture. During cooling the hemihydrate recrystallizes to dihydrate. After recrystallization the dihydrate and
phosphoric acid are separated by means of filtration. The phosphoric acid (28%) subsequently is passed through a
desulphatation section (lowering sulphate/sulphuric acid concentration of the acid), a settling tank (settling of small
gypsum particles), and finally an evaporation section where the acid is concentrated in four steps to 54% P2O5. After
filtration, the dihydrate gypsum cake is treated in a repulp filter unit before being reslurried and discharged into the
Nieuwe Waterweg, a Rhine estuary close to the sea. A somewhat more detailed description of the process is given in
Annex 4.
p h o sphate rock
grind mill d u st filter d u st to air
water water fluorine to air

sulphuric acid
reactors scrubber fluorine and phosphate to water
flash cooler
return acid water fluorine to air
recrystallisator scrubber fluorine and phosphate to water
water
filter repulp filter g y p su m t o w a t e r
desulfatation
p h o sp. acid
storage fluorine and
water water p h o sp h a t e t o
water
st e a m evaporator separator scrubber condenser
seal vac.pump
p h o sphoric acid product fluosilisic acid by-product
Figuur 8: Diagram of the HRC-repulping process of Kemira Agro Pernis
6.1.2 Hydro Agri Rotterdam

The phosphoric acid plant of Hydro Agri Rotterdam is located in Vlaardingen, opposite to that of Kemira at the other
side of the river. The production capacity of the plant is 160 kton per year. Hydro Agri employs a a hemi-dihydrate
recrystallization process with double stage filtration. The main process consists of two reaction systems and two
filtration systems. A diagram of the process is presented below [35, 49].
In the first reaction system phosphate rock reacts with concentrated sulphuric acid (96%) and return acid (weak
phosphoric acid coming from the filtration section) to form hemihydraat gypsum and phosphoric acid. The phosphoric
acid is separated from the hemihydrate gypsum by means of filtration. Subsequently, in the second reaction system
sulphuric acid and a SiO2-containing slurry are added to stimulate the recrystallization of hemihydrate to dihydrate.
The recrystallization liquid and the dihydrate are separated by means of filtration. The liquid phase is reused as wash
water in the hemihydrate filtration step and finally ends-up as return acid in the first reaction system. After washing
the dihydrate is reslurried and discharged into the Nieuwe Waterweg. The process produces a 42% phosphoric acid.
The acid is concentrated to 54% P2O5 by means of vacuum evaporators. During evaporation a SiO2 containing
solution is added to stimulate de-fluorisation of the phosphoric acid. A somewhat more detailed description of the
process is given in Annex 4.
p h o sphate rock
water
water flash cooler fluorine to air
sulphuric acid
reactors scrubber scrubber effluent
(fluorine and phosphate)
return acid
water
scrubber effluent
filter scrubber (fluorine and phosphate)
recrystallisator vapour water
filter g y p su m t o w a t e r
p h o sp. acid
storage
water water
steam evaporator scrubber condenser

scrubber effluent
Figuur 9: Diagram of the Hemi-dihydrate process (HDH-2) of Hydro Agri Rotterdam
6.2 Consumption levels

In table 12 typical consumption figures, i.e. raw materials and utility requirements, are shown for the production of
concentrated phosphoric acid by Kemira Agro Pernis and Hydro Agri Rotterdam [20, 34, 48, 49, 50].
Tabel 12: Typical consumption figures for the production of merchant grade phosphoric acid by Kemira Agro Pernis
and Hydro Agri Rotterdam
Inputs Kemira (per ton P2O5) Hydro Agri (per ton P2O5)
Phosphate rock 2.8 ton 3.1 ton
Sulphuric acid 2.6 ton 2.6 ton

1) 3 3
Process water 51 m 52 m
2) 3 3
Cooling water 101 m 40 - 50 m
Electric power 173 kWh 167 kWh
Steam 2.2 ton 1.0 ton

1)
including scrubber water
2)
cooler and condensor water
6.3 Emissions and waste

Table 13 presents data which give an impression of the emission reductions (absolute emissions) that have been
achieved in the last decade by carrying through adjustments with respect to the phosphoric acid process and the
type of phosphate rock used, and by improving the management of the process. Furthermore table 13 contains data
with respect to the actual (1996/1997) specific emissions (per ton P2O5 produced) [20, 34, 49, 49]. Most of the data
presented is based on measured values. The emission values have been estabished according to standardized
measurement procedures. The procedures used are listed in Annex 5.
Tabel 13: Reduction of emissions (total emissions per year) achieved since 1985 and actual emissions factors
realized during production of phosphoric acid by Kemira and Hydro Agri in 1996/1997
Emission reduction since 1985 specific emissions 1996/1997
Kemira Hydro Agri Kemira Hydro Agri

% % per ton P2O5 per ton P2O5
emissions to air
1)
fluorine (F) 70 6.1 2.8 g
2)
dust 75 12 19 g
liquid emissions to water

phosphate (P) 1.3 0.7 kg
fluorine (F) 15 31 kg
3) 4)
cadmium 0.03 0 g
3)
mercury 0 0.01 g
3)
arsenic 0.02 1.9 g
3)
heavy metals 1.9 2.8 g
solid emissions to water

gypsum 4000 4700 kg
phosphate (P) 65 87 8.1 5.8 kg
fluorine (F) 53 39 33 45 kg
cadmium 96 98 0.5 1.4 g
mercury 61 74 0.2 0.5 g
4)
arsenic 72 100 0.7 0 g
7)
heavy metals 33 88 53 27 g
8) 5) 6)
rare earth metals (17) 2200 360 g
6)
radium-226 45 1.4 2.3 MBq
6)
polonium-210 40 1.4 2.3 MBq
6)
lead-210 50 1.4 2.1 MBq
1) 3
fluorine concentration <1 mg/Nm
2) 3
dust concentration 30 mg/Nm
3)
estimated values based on input-output calculations
4)
all values measured are below detection limit
5)
increase instead of decrease
6)
decrease since 1992 (no data of 1985 available)
7)
lead, copper, zinc, nickel and chromium
8)
mainly lanthanum, cerium, praseodymium, neodymium
6.4 The future Dutch situation: Useful application of waste gypsum

The current situation of wet phosphoric acid production in the Netherlands is characterized by the use of highly
efficient processes with respect to P2O5-recovery, efficient prevention of fluorine and dust emissions to the air, and
the production of clean gypsum and low cadmium phosphoric acid through the use of clean phosphate rocks, i.e.
phosphate rocks which are low in heavy metal content and concentrations of radionuclides. As in the Netherlands
land disposal of the by-product gypsum produced appears to be impracticable for a number of reasons, the current
situation can be regarded as “best available”. However, the discharge of phosphogypsum to the sea is not acceptable
from an environmental point of view, and therefore is not regarded as an alternative for disposal of the gypsum.
Useful application of the gypsum is seen as the solution. Pilot plant tests have demonstrated the technical feasibility
of the production of a gypsum product that meets all specifications required for application of the gypsum in (in-door)
building products like plaster, plasterboard and gypsum building blocks [51, 52, 53]. There are no technical limitations
for full-scale production. Furthermore, the gypsum can be produced for a price which is comparable to the price for
natural gypsum [47]. In the Dutch situation, therefore, the useful application of by-product gypsum is regarded as
best available technique. Plans have been developed to start-up gypsum production in 2000, reaching full-scale
operation in the year 2006 [48].
6.4.1 Description of gypsum upgrading installation

Instead of being discharged, the gypsum slurry from the wet phosphoric acid process is transported to the gypsum
upgrading installation. Research has shown that many of the impurities present in the gypsum are enriched in the
smallest gypsum particles. In the gypsum upgrading process the gypsum is separated in a fine particle fraction
(about 4% of the total gypsum) and a coarse particle fraction (about 96wt%) by means of a two-stage hydrocyclone
system. Subsequently, the coarse particle fraction (roughly >15µm) is filtered, washed and dried by means of
vacuum filtration. In this way a large clean fraction is obtained that can be usefully applied. The fraction still contains
the bulk of the impurities, especially the radionuclide, but the levels of impurities in the gypsum are similar to those
found in natural gypsum and other raw materials used for building products. At this moment no practicable solutions
for useful application or land disposal of the fine particle fraction exist. The fines, which leaves the hydrocylones as a
very dilute slurry (<1% dry weight), will be discharged to the sea. Although enriched relative to the unfractionated
gypsum, the total amount of impurities discharged is much less than in the present situation. A diagram of the
upgrading unit is presented below.
w ater
slurry from phosacid process hydrcyclone vacuum filter
discharge gypsum fines effluent gypsum product
Figuur 10: Diagram of the phosphogypsum upgrading unit
6.4.2 Consumption levels

In table14 typical consumption figures, i.e. raw materials and utility requirements, are shown for the production of
concentrated phosphoric acid and an a gypsum product called ProGips, which can be usefully applied [34, 54]. Data
are shown for Kemira Agro Pernis only. No data for Hydro Agri Rotterdam are shown as this plant will be closed at
the end of 1999.
Tabel 14: Typical consumption figures for the production of merchant grade phosphoric acid and gypsum (ProGips)
by Kemira Agro Pernis.
Inputs Kemira (per ton P2O5)
Phosphate rock 2.8 ton
Sulphuric acid 2.6 ton

1) 3
Process water 55 m
2) 3
Cooling water 118 m
Electric power 207 kWh
Steam 2.8 ton

1)
including scrubber water
2) cooler and condensor water
6.4.3 Environmental performance

Table 15 shows the emissions per ton P2O5 due to discharge of the gypsum in the present situation and in the case
of full scale operation of gypsum upgrading is achieved. Other emission to air and water are not show as useful
application of the gypsum does not affect these issues [48].
Tabel 15: Emissions due to the discharge of gypsum, in the present situation and in the future situation with full scale
upgrading and useful application of the gypsum.
Kemira - 1996 1) Kemira - 2006 2)
per ton P2O5 per ton P2O5
solid emissions to water

gypsum 4000 470 kg
phosphate (P) 8.1 2.3 kg
fluorine (F) 33 4.4 kg
cadmium 0.5 0.04 g
mercury 0.2 0.2 g
arsenic 0.7 0.04 g
heavy metals 53 16 g
rare earth metals 2200 450 g
radium-226 1.4 0.4 MBq
polonium-210 1.4 0.7 MBq
lead-210 1.4 0.2 MBq
1)
actual values based on emission data (measurements) and production figures
2)
values based on estimates used in the application for a permit; actual values are generally lower
7. Evaluation of waste disposal methods by means of screening LCA
When identifying BAT according to the IPPC Directive, an integrated approach is required. In practice, this appears
to be a difficult task, as the integral assessment of BAT is hampered by the complexity of cross-media assessment.
To solve this problem the Netherlands propose to use a transparent and structured assessment based on the
principal steps of the so called Life Cycle Assessment (LCA). The LCA method is a standardized and internationally
accepted method, and is known as a useful decision-supporting tool for product policy and environmental product
development. There are no methodological restraints to apply the principles of LCA also for the environmental
assessment of processes. Because of the complexity of the life cycle of products (from cradle to grave) and the
accompanying need for data, LCA often gives the impression of being a complex and intensive way of analyzing the
environmental burden. However, by well-considered adjustment of system boundaries to production processes (from
cradle to gate, or from gate to gate), a more simplified and less time-consuming method can be obtained.
The disposal of the phosphogypsum represents by far the most serious environmental aspect of wet-process
phosphoric acid production. Recently, some detailed LCA studies have been carried out for the Dutch phosphoric
acid industry [55, 56]. Based on data originating from these studies a screening LCA is performed to get insight in the
environmental effects of different waste disposal scenario’s for this branch of industry [57]. The main results of the
screening LCA study are presented in this chapter. Thereby it is assumed that the principles of the LCA method are
known. For a more detailed description of the LCA method, the reader is kindly referred to existing literature on this
subject.
7.1 Starting points for the screening LCA
7.1.1 Gypsum disposal scenarios and functional unit

As mentioned before, there are three alternatives for disposal of phosphogypsum: discharge into water, storage on
land and useful application. Based on these three options the following scenarios have been worked out. The
scenarios are graphically represented in figures 11, 12 and 13.
• Production in 1998, with discharge of all gypsum.

• Production in 2006, with landfill of all gypsum.
• Production in 2006, with useful application of most of the gypsum in the building industry.
The scenarios for disposal of phosphogypsum are compared on the basis of the production of 225 kton1 fertilizer
grade phosphoric acid at Kemira Agro Pernis (KAP)2 and production of an amount of gypsum suitable for building
products, equivalent to the amount of ProGips that KAP will produce in 2006 (functional unit).
1
The maximum annual quantity that KAP is allowed to produce.
2
Since the recent decision by Hydro Agri Rotterdam to stop producing phosphoric acid at it’s Rotterdam facility, KAP is the only
remaining producer in the Netherlands.
7.1.2 System boundaries and data used

The system boundaries are chosen “from cradle to gate”. This means that the environmental impact (per functional
unit) includes the environmental burden from the process itself and from the use of raw materials and energy. The
most important starting points regarding the system boundaries are:
• The system boundary for the phophoric acid production lies just after the production of concentrated (merchant
grade) phosphoric acid.
• The production and use of fertilizers (resulting in diffuse emissions) are not included.
• In the case of gypsum production (upgraded phosphoric gypsum or ProGips, flue gas desulphurization gypsum
and natural gypsum), the boundary is drawn just after drying dihydrate. Calcination to produce hemihydrate and
the production, use and waste treatment of building products are not included.
• In the case of landfill dewatering of the gypsum, transport of the gypsum to the landfill site and leaching of
contaminating substances from the gypsum at the landfill site are included. It is assumed that 1% of all
contaminating substances eventually leaches to the environment (soil and groundwatersystem).
• The energy use and use of chemicals for groundwater control and emission control are not included. Also the
emissions of radioactive substances to the air are not included.
Based on data from the Dutch phosphoric acid industry, the Dutch gypsum industry, (public) databases and
literature, environmental impact sheets were made for the different activities involved with the production of merchant
grade phosphoric acid and gypsum suitable for building products. The analysis is based on the actual production
characteristics of Kemira Agro Pernis (type and composition of phosphate rock used, sulphuric acid used, emissions
and specific consumption figures) which have been extrapolated to the maximum annual production capacity of the
plant. A more detailed description of the starting points regarding system boundaries and data used are presented
elsewhere [57].
7.2 Results of the screening LCA and evaluation
7.2.1 Impact assessment

With the aid of the environmental impact sheets, the potential environmental effects were calculated based on so
called “equivalence factors”. These factors translate the emissions, waste and energy demand in potential
environmental effects on several environmental themes, such as greenhouse effect, ozone depletion, acidification,
eutrophication, nutrification, aquatic ecotoxicity and (non-)toxic solid waste. The result of this characterization is a list
of scores on environmental themes for the three alternative disposal scenarios. The list of scores is called the
environmental profile.
The results of the characterization may be presented as non-normalized and as normalized. By normalization, the
importance of the various environmental themes for the scenarios studied are calculated by relating the scores to the
total environmental burden of that theme for a certain area in a certain period of time. In this study the results of the
screening LCA have been related (normalized) to the total environmental burden caused by:
• all anual economic activities on the Dutch territory in 1993
• all annual economic activities on the Westen European territory in 1990 to 1994 (no complete set of data for one
particular year is available)
7.2.2 Non-normalized environmental profile

The non-normalized characterization scores are presented in figure 14. For presentation purposes the highest score
per theme is put at 100%. The results show that the performance of the different disposal scenarios is very similar
for most environmental themes. The reason for this is that the scores on these themes are mainly caused by energy
conversion and transport processes, which do not differ much for the different disposal scenarios.
100
90
80
70
60
discharge
50 landfill
reuse
40
30
20
10
0
global warming
energy demand
ozone layer depletion
resources depletion
nutrification
acidification
land use
non-toxic waste
summer smog
toxic waste
human toxicity
aquatic ecotoxicity
Figuur 14: Characterization scores of the three phosphogypsum disposal scenarios
The differences in effects between the three disposal scenarios mainly occur for the environmental themes aquatic
ecotoxicity, nutrification potential, land use and non-toxic solid waste. In this case the latter two themes are strongly
correlated as the main sources of land use are mining of raw materials and landfill of both mining waste and
phosphogypsum. To avoid counting impacts twice, only waste will be considered further. The reason for choosing
waste, and not land use, is that in Annex 4 of the IPPC Directive waste is explicitely mentioned as one of the items to
be taken into account when determining best available techniques.
Figure 15 shows that the reuse scenario has a better performance on aquatic ecotoxicity, nutrification and waste than
the discharge scenario. Especially the environmental impact on aquatic ecotoxicity (80% less) and nutrification (60%
less) are much lower. The performance of the landfill scenario on aquatic ecotoxicity and nutrification is even better
than that of the reuse scenario. The landfill scenario, however, scores worse on waste, both compared to the reuse
scenario and the discharge scenario. As non of the three scenarios scores best on all the environmental themes it is
not possible on the basis of the characterization scores to decide which of the scenarios is most favourable from an
environmental point of view.
7.2.3 Normalized environmental profiles

Normalized environmental profiles are shown in figure 15. These profiles clearly shows that the slightly larger score
on nutrification and aquatic ecotoxicity of the reuse scenario in comparison with the landfill scenario is completely
outweighed by the scores on waste. The difference between the scores on waste is more than 1 order of magnitude
larger than the difference on the other themes. This is especially the case in the Dutch situation, where, because of a
strict waste policy, the total amount of waste is relatively small, and therefore the contribution of the studied
scenarios is relatively large. In the Western European situation, the differences between the various environmental
themes are smaller, but still significant. Because of the dominance of waste, it is concluded from this screening LCA
analysis that the overall environmental performance of the reuse scenario is better than the landfill scenario, both in
the Dutch and in the Western European situation3.
Dutch situation European situation
0,35 0,006
discharge discharge
0,3 0,005
landfill landfill
0,25 reuse reuse
0,004
0,2
(eq/yr)
(eq/yr) 0,003
0,15
0,002
0,1
0,05 0,001
0 0
aquatic nutrification non-toxic aquatic nutrification non-toxic
ecotoxicity waste ecotoxicity waste
Figuur 11: Normalized environmental profiles of the three phosphogypsum disposal scenarios for the main
distinguishing environmental themes. The characterization scores are normalized by relating them to the total annual
environmental burden on the Dutch and Western European territory.
3
In addition to the normalization, it is possible to weigh the different environmental themes, and achieve an overall performance for each
process. Weighing means that if an environmental theme is considered more important than another, this theme is assigned a higher
weighing factor. Although no weighing step is carried out in this study, it is assumed that, because of the dominance of waste by more
than 1 order of magnitude, the reuse scenario overall has the best environmental performance. Applying a difference of more than 1
order of magnitude in the interpretation of the normalized results means that it is assumed that the ratio between the most and least
important environmental theme is smaller than 10. In the Dutch approach of integral assessment of BAT by the screening LCA method
it is advised to use the ‘ratio 10’as a first approximation as long as no clear results can be derived from the normalized environmental
profile and no societal preferences are available.
8. Concluding remarks and recommendations
W et phosphoric acid is produced by digestion of phosphate rock with sulphuric acid. In this process phosphogypsum
(calcium sulphate) is formed as by-product. The production of 1 ton of merchant grade phosphoric acid (54%P2O5)
roughly requires 1.5 ton of phosphate rock and 1.5 ton of sulphuric acid, and yields approximately 2.5 ton of
phosphogypsum. The disposal of phosphogypsum is the main environmental problem of wet phosphoric acid
production. It is, however, not the gypsum that is the problem, but the impurities present in the gypsum such as
residual acid, fluoride, mercury, cadmium and other heavy metals, rare earth metals and radionuclides such as 226Ra,
210
Po and 210Pb.
The impurities originate mainly from phosphate rock or from the production process (residual acidity). The amount of
impurities introduced into the process by sulphuric acid are generally low or negligible compared to the amount
introduced by the phosphate rock. Only in the case of mercury, and possibly lead, sulphuric acid may contribute
significantly, especially when fatal acid is the main type of sulphuric acid used
Basically, three different options exist for handling phosphogypsum by-product, i.e. discharge into water, dumping on
land and useful application of the gypsum. From an environmental point of view, it is commonly accepted that, the
discharge of phosphogypsum into water should be avoided by any means. The results of a cross-media assessment,
based on the principal steps of the so called Life Cycle Assessment (LCA), indicates that, of the two remaining
alternatives, the overall environmental performance of useful application is better than dumping on land. The most
practicable option, however, will depend on the local conditions, among which the phosphoric acid technology applied
and the type of phosphate rock used.
In the assessment of BAT for the production of phosphoric acid, the P2O5-efficiency should be a dominant factor.
With increasing efficiency, less phosphate rock and less sulphuric acid is required per unit of acid produced. At the
same time the amount of phosphogypsum decreases per unit of acid produced. Efficiencies of 98% and more are
possible in recrystallization processes with two filtration stages. In addition to a high P2O5-efficiency, these processes
also produce phosphogypsum with considerably lower levels of impurities than the conventional processes.
Consequently, the potential environmental hazards associated with the disposal of phosphogypsum are lower, and the
possibilities for useful application of the gypsum are better.
With respect to recrystallization processes, the following should be noticed. Impurities introduced into the process
are divided between the phosphoric acid product and the phosphogypsum by-product. If a smaller part of the
impurities ends-up in the phosphosgypsum, a larger part will end-up in the phosphoric acid. Eventually, these
impurities will end-up in the environment through the use of fertilizers based on the intermediate phosphoric acid.
This can be avoided by purification of the acid before further processing.
As impurities in phosphogypsum mainly originate from phosphate rock, the ratio of impurities to the P2O5-content of
the phosphate rock is an important parameter. The lower the ratio, the lower will be the content of impurities in the
phosphogypsum. Together with the use of a process with a high P2O5-efficiency, the use of clean phosphate rock,
therefore, is the most important preventive measure to reduce the potential environmental hazards associated with
the disposal of phosphogypsum, and to enhance the chances for useful application of the gypsum.
Useful application of phosphogypsum is only possible if the quality meets required specifications. In general, this
means that the quality of the phosphogypsum should be comparable to that of other gypsum resources. Besides
applying clean phosphate rock in a recrystallization process, this may require upgrading of gypsum that does not
meet the specifications, and/or in-process removal of specific impurities that particularly hinder the application of
phosphogypsum. Upgrading of gypsum can be achieved by separation of fines (e.g. by means of hydrocyclones), as
it appears that many of the impurities present in phosphogypsum are enriched in the smallest gypsum particles.
Developments for in-process removal of impurities by means of extraction and precipitation techniques are underway.
As in-process removal of impurities may yield a cleaner gypsum as well as a cleaner phosphoric acid this
development deserves further attention.
Other environmental problems at the wet phosphoric acid production are the emission of fluorine and dust (from
phosphate rock grinding) to air, and the emission of fluorine and phosphate to water. The emission of dust can be
effectively prevented by using fabric filters. Fluoride can be removed by a number of different gas scrubbing systems
with a removal efficiency of more than 99%. The gas scrubbing systems yield an effluent containing fluorine and
phosphate components. Before discharge, the effluent can be neutralized with lime or limestone to precipitate fluorine
as solid calcium fluoride and phosphate as calcium phosphate.
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
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von ProGips im Hinblick auf die Verwendung zur Herstellung von Baustoffen, Intron/Hydro Agri Rotterdam B.V./Kemira
Agro Pernis B.V., 1999 (in German).
[53] Radiation Performance of Progips Products, Bosmans and Leppers, Intron B.V. report no. 980556, Sittard, the
Netherlands, 1999.
®
[54] Environmental impact statement ProGips production Kemira Agro Pernis B.V. and Hydro Agri Rotterdam (Milieu-
®
effect rapport productie ProGips Kemira Agro Pernis B.V. en Hydro Agri Rotterdam B.V.), van Veen and de Graaf-
Bremmer, Tauw report no. 3613097, Deventer, the Netherlands, 1999 (in Dutch).
[55] LCA ProGips backing study for the benefit of environmental impact statement ProGips (LCA ProGips ondersteunende
studie t.b.v. MER ProGips), R. Seijdel, publication PRC Bouwcentrum, Bodegraven, the Netherlands, November 1998
(in Dutch).
[56] LCA phosphoric acid production system, R. Seijdel, PRC Bouwcentrum publication, Bodegraven, the Netherlands, May
1999.
[57] Cross-media assessment of gypsum disposal scenario’s for the phosphoric acid industry, R. Seijdel (PRC
Bouwcentrum BV), Institute for Inland Water Management and Waste Water Treatment RIZA, report no. 99.138x,
Lelystad, the Netherlands,1999.
Dutch notes on BAT for the phosphoric acid production
Annex 1: Thermal phosphoric acid process
In this section, the production of thermal phosphoric acid by Thermphos International (Vlissingen, the Netherlands) is
outlined. The process description and the environmental performance is considered.
Process description
The production of thermal phosphoric acid is carried out in two stages. First elemental phosphorus is produced from
phosphate rock. Then the elemental phosphorus is oxidized with air to P2O5, which is subsequently hydrated to
produce phosphoric acid. A schematic overview of the process is shown in the accompanying block diagram [1, 2].
Typical data on consumption of raw materials and utilities, and formation of by-products in the process are presented
in table 1 [2, 3]. Typical data on emissions and waste of the process are shown in table 2 [3].
Production of elemental phosphorus

Elemental phosphorus is obtained from phosphate rock. Thermphos uses a mixture of sedimentary rock and igneous
rock. The process starts with grinding of the phosphate rock. The ground phosphate rock is mixed with a slurry
consisting of water, clay and various phosphorus containing waste streams, to produce pellets in a granulator. The
pellets are sintered in a furnace at a temperature of about 800°C.
Phosphorus is released from the sintered pellets by heating the pellets to about 1500°C in an electric resistance
furnace together with cokes (to provide a reducing environment) and gravel (slag formation). The overall reaction can
be summarized as follows:
2 Ca 3 (PO4 )2 + 6 SiO2 + 10 C → P 4 + 10 CO + 6 CaSiO3
The process mainly produces gaseous phosphorus, carbon monoxide and a liquid slag. The gas phase is first passed
through an electrofilter to remove dust (Cottrell dust). Subsequently gaseous phosphorus is recovered completely
through condensation. The remaining gas phase mainly consists of carbon monoxide. This gas is used as fuel gas on
the site (e.g. in the sinter furnaces) and is sold to the nearby power plant. The left-over gas, if any, is flared. The
liquid slag is tapped from the furnace in batches, and yields a phosphorus slag (the major part) and a ferro-
phosphorus slag (a minor amount) by-product. After further processing the former is used as foundation material in
large construction works, while the latter is used as steel additive in the iron and steel industry. The P-recovery
efficiency of the phosphorus process is about 94%. The remaining phosphorus will mainly end up in the furnace slag
(as unreacted phosphate). Minor amounts end up in ferrophosphorus (as alloy) and the Cottrell dust.
The production of phosphoric acid

At present only about 20% of the phosphorus produced is converted into phosphoric acid. In the past a considerable
amount of thermal phosphoric acid was used for the production of sodium phosphate salts. More and more however,
thermal phosphoric acid is being replaced (on the basis of economics) by purified wet phosphoric acid. Thermal
phosphoric acid is almost exclusively produced for specific applications which require a very pure acid such as metal
surface treatment in the micro-electronics industry and the acidulation of beverages.
To produce phosphoric acid from elemental phosphorus, first the phosphorus is brought into a reaction vessel
together with air, after which the phosphorus oxidizes to P2O5. The heat evolving from this reaction is used for the
generation of high pressure steam. Subsequently, the P2O5 is contacted with diluted phosphoric acid, and reacts with
the water present in the acid to form phosphoric acid. Two configurations for this process are used. In one case the
absorption of P2O5 by diluted phosphoric acid is carried out in the same reaction unit as where oxidation of the
phosphorus takes place. In the other, preferential, case, the reaction of P2O5 to phosphoric acid is carried out in a
separate absorption tower, allowing energy recovery as high-pressure steam. The production of phosphoric acid from
elemental phosphorus is represented by the following reactions:
P 4 + 5 O2 → 2 P 2 O5
P 2 O5 + 3 H 2 O → 2 H 3 PO4
Dutch notes on BAT for the phosphoric acid industry
Main environmental aspects

The environmental performance of the thermal acid plant is presented in table 2 [2, 3]. Main sources of emissions
and waste in the production of phosphorus and phosphoric acid from elemental phosphorus are:
• Sintering of the phosphate rock pellets and drying of cokes in the sinter furnace. The off-gas from the sinter
furnace contains a wide range of pollutants such as dust, fluoride, phosphate, heavy metals, radionuclides and
SO2 and NOx. The off-gas from the ovens is cleaned in two-stage scrubber systems with closed water circuits,
before being emitted to the air. To prevent accumulation, pollutants are removed from the recirculating wash
water stream through neutralisation followed by flocculation and separation of the solids. The solids obtained are
returned to the process either via the slurry station or via the phosphate rock (after drying).
• Calcination of Cottrell dust, flaring of fuel gas and drainage of liquid slag from the phosphorus furnace:
– The gas phase produced in the phosphorus furnace contains a considerable amount of dust (so-called
Cottrell dust) which is removed through an electrofilter. As a result of closed loops (reuse of waste streams)
in the process, the dust is enriched in heavy metals (mainly zinc) and radionuclides (such as 210Po and
210
Pb). The dust is mixed with water and recycled to the slurry station. However, due to the high zinc
content in the dust, part of it is removed to prevent excessive accumulation. The dust is calcined (emission
of dust, F and P2O5 to the air) and stored. In the near future storage will be replaced to a special storage
facility for all kinds of radioactive waste.
– After recovery of phosphorus from the gas, the remaining gas mainly consists of carbon monoxide. This gas
is used as fuel gas on the site (e.g. in the sinter furnaces) and is sold to the nearby power plant.The left-
over gas, if any, is flared, which contributes to SO2 and NOx emissions to the air.
– Vapours released at drainage of the liquid slags from the phosphorus furnace, are being removed, and
washed with water in a venturi scrubber before being emitted to the air;
– Process effluents that have been in contact with phosphorus are sent to the waste water station. After
treatment (sedimentation followed by neutralisation, flocculation and separation of the solids formed), 70 to
90% of the water is recycled to the process. The remaining water is treated with lime for further P2O5-
removal and is subsequently treated in an biological wastewater treatment plant before being discharged to
the sea. All solids are recycled to the process.
• Oxidation of phosphorus in the acid plant and removal of arsenic from the acid:
– The off-gas from the acid towers is contaminated with traces of P2O5 and phosphoric acid. To minimize
emissions the off-gas is cooled and washed with recirculating acid and water, and subsequently treated in a
venturi scrubber (diluted acid) and a demister. The bleed of the recovery system is reused either in the wet
phosphoric acid purification plant or the slurry station. The emissions of the acid plant are small compared
to the emissions of the sinter plant and the phosphorus plant.
– Due to the specific fields of application (e.g. additive to foodstuff and beverages) traces of arsenic present
in the phosphoric acid have to be removed. To this end sodium hydrogen sulphide (NaHS) is added to the
acid, upon which arsenic is precipitated as arsenic sulphide (As2S3). After separation and further
processing, the latter is obtained in concentrated form and stored as hazardous chemical waste.
References
[1] License application for Pollution on Surface Water Act (Vergunningaanvraag Wvo), Thermphos International B.V.
Vlissingen, The Netherlands, June 1997 (in Dutch)
[2] SPIN-document Hoechst, K. Huizinga and A. Hoogenkamp, RIVM report no. 773006155, RIZA report no. 92.003/55,
September 1993 (in Dutch).
[3] Environmental & Safety Annual Report 1998, Thermphos International B.V. Vlissingen, March 1999 (in
Dutch).
phosphate rock
grind mill
clay
emissions to air granulator slurry station wet acid process

filter cakes
gas scrubber sinter oven

sinter
phosphate
filter calcinate (solid waste)
Cottrell slurry
air emissions fuel gas
coke gas- w a ste water
silica furnace gases electrofilter condensation scrubber station
emission to air effluents
slag tapping furnace slag

scrubber drainage emission to water
emission to air cakes to furnace filtration
cooling
furnace slag and ferro-phosphorus by-product
phosphorus
air
water
c o m b u stion
to air chamber *
steam
off-gas water
recovery
absorption sulfide
tower *
acid to process
cooling precipitation phosphoric acid
product
arsenic values (solid waste)

* process w ith separate combustion, including steam generation, and absorption
Figuur 12: Diagram of the phosphorus and thermal phosphoric acid production at Thermphos
Tabel 1: Typical data on raw material and utility consumption, and formation of by-products for the production of
thermal phosphoric acid.
ThermPhos - 1998 1)
Per ton P2O5
Inputs
Phosphate rock 3.0 - 3.4 ton
Clay 0.2 - 0.3 ton
Gravel 1.2 - 1.3 ton
Cokes 0.5 - 0.6 ton
3
Process water 40 m
3
Cooling water 120 m
Electric power 5700 - 6000 kWh
3
Natural gas n.a. Nm
Steam n.a. ton
Outputs: by-products
1) 3
Fuel gas 1500 - 1600 Nm
Phosphorus furnace slag 3.2 ton
1)
In 1998 about 20% of this gas was flared
Tabel 2: Emissions factors realized during production of elemental phosphorus and phosphoric acid by Thermphos
in 1998.
ThermPhos - 1998 1)
Per ton P2O5
Emissions to air
Phosphate (P) 0.6 kg
Fluorine (F) 0.1 kg
Dust 0.4 kg
Cadmium 1.0 g
Lead 6.0 g
Zinc 5.9 g
Polonium-210 3.5 MBq
Lead-210 0.3 MBq
Emissions to water
Phosphate (P) 0.7 kg
Fluorine (F) 0.7 kg
Cadmium 0.2 g
Mercury <0.01 g
Arsenic <0.07 g
Heavy metals 14 g
Polonium-210 0.05 MBq
Lead-210 0.06 MBq
Waste
Cottrell dust 3.2 kg

Arsenic sulphide filter cake 0.1 kg
1)
The figures presented in the table are based on the total emissions of the sinter plant, the phosphorus plant and the acid plant, and the amount
of phosphate rock processed in 1998 assuming a P2O5 content of 33% and an overall P-recovery efficiency of 94%. In 1998 only about 20% of the
phosphorus produced was converted into phosphoric acid on site. The remaining was sold as phosphorus.
Annex 2: Typical composition of various phosphate rocks
The specifications in the table are an indication of the composition of the various phosphate rocks. Different
specifications my be found for the same type of phosphate rock. Both the quality of the rock and the level of
impurities may vary. This is caused mainly by the variation in composition which is present by nature, but may also
be caused by different results of analyses.
Sedimentary phosphate rock Igneous phosphate rock
Morocco Morocco Jordan Israel Florida Senegal Togo Russia Russia S.Africa
K11 Bucraa Eshydia Zin Taiba Kola Kovdor Phalaborwa
main constituents (wt%)
P2O5 31,1 36,4 33,0 32,4 32,9 37,5 36,1 38,1 37,0 40,2
CaO 50,2 50,9 49,5 52,0 48,9 51,0 50,8 51,8 52,5 54,1
F 3,9 4,0 3,8 3,6 3,8 3,8 3,5 3,6 0,8 2,6
Org. C 0,3 0,2 0,2 0,2 0,3 0,6 0,2 0,09 0,2 0,03
SiO2 1,1 3,7 4,0 1,3 1,5 2,7 3,0 1,4 2,0 0,4
Fe2O3 0,2 0,2 0,3 0,1 1,0 1,1 1,4 0,3 0,2 0,2
Al2O3 0,6 0,4 0,2 0,1 1,2 1,1 1,1 0,7 0,1 0,1
MgO 0,4 0,1 0,2 0,3 0,3 0,02 0,1 0,05 2,1 0,4
trace elements (ppm)
Cd 9 35 5 22 6 62 52 <1 <1 0,2

Hg 0,05 0,04 0,02 0,01 0,1 0,2 0,05 0,001 0,01 0,01
As 10 13 5 7 7 18 15 2 2 11
Pb 4 4 3 5 17 5 9 4 3 20
Zn 180 75 120 400 81 320 20 5 6
Cu 40 11 9 25 13 45 37 30 90
Ni 32 8 10 70 21 28 39 2 2 18
Cr 360 87 65 75 47 6 8 1 3 1
Co 2 12 20 2 1 7 2 2
V 205 32 60 200 63 72 30 10
Ti 245 33 30 230 900 170 29
Mn 15 151 170 12 110 170 250 74
1)
REE 900 415 110 135 610 6300 1400 4800
radioactivity (Bq/kg)
238
U 1415 750 740 1325 1500 35 30 110
232
Th 18 16 16 92 37 90 30 360
226
Ra 1370 750 720 1325 1300 35 12 110
210
Po 1425 750 630 1325 1300 35 13 110
210
Pb 1230 750 645 1325 1300 35 8 110
1)
Rare earth elements: scandium, yttrium, lanthaan, cerium, praseodymium, neodymium, samarium, europium, gadolinium, terbium, dysprosium,
holmium, erbium, thulium, ytterbium, lutetium; underlined are the elements that are the most abundant.
Annex 3: Use of gypsum as raw material or as product
Potential uses for gypsum fall into the three broad categories:
• Uses for agricultural purposes;
• Uses in construction and building materials;
• Industrial uses.
Uses for agricultural purposes
Direct use
Gypsum is useful as a fertilizer for calcium- and sulphur-deficient soils, such as those found in Brazil and other
countries. It is also effective as a soil conditioner for acid soils rich in active aluminium (Al3+ ), which tend to have
adverse effects on plant roots. Acid soils may predominate in nearly 30% of the total farmland in the world. Gypsum
can supply calcium to plants and can also reduce the adverse effect of aluminium by forming AlSO4+ .
In India, Coromandel Fertilizers and EID Parry dispose of all their gypsum for agricultural purposes. This was also the
case in the United States. In 1992, The Environmental Protection Agency (EPA) banned the use of gypsum
containing more than 360 Bq/kg of radium equivalency for soil applications.
Conversion to ammonium sulphate or potassium sulphate

Conversion of gypsum to ammonium sulphate can be done for the fertilizer industry. In this process ammonia, carbon
dioxide and gypsum form ammonium sulphate and calcium carbonate. Calcium carbonate can be used in cement or
as fertilizer as well. Potential environmental hazards can be expected with the use of calcium carbonate, because of
the radioactivity levels. Full scale plants, with natural gypsum as raw material, are operational in Austria, Italy, India
and Indonesia.
For potassium based fertilizers, usually potassium sulphate is produced (Sulphate of Potash). In this process
potassium chloride and gypsum form potassium sulphate and calcium chloride. Calcium chloride precipitates and has
to be disposed of. With the use of phosphogypsum the gypsum disposal will be substituted with an impure calcium
chloride disposal, with comparable environmental problems.
Uses in construction and as building materials

There are three main possible uses for by-product gypsum as construction and building material:
• Uses as a road based material;
• Production of plaster and related products;
• Cement additive.
Uses as a road based material

Phosphogypsum can be used in road construction as a road base material. Phosphogypsum stabilised with cement
or flyash can replace and upgrade secondary roads constructed of clay and sand. A possible environmental hazard
from phosphogypsum is leaching together with other possible impurities from cement or fly ash. Pollution to the soil
or groundwater may occur. Immobilisation techniques, such as washing or thermal treatment may be necessary
before usage. An experimental road was constructed in Florida (United States) and has been open for traffic since
1986.
Production of plaster and related products

The processes used for converting phosphogypsum into plaster and related products are essentially the same as
when using natural gypsum. The majority of plasters are based upon the hemihydrate form of calcium sulphate, since
this rehydrates more quickly than the anhydrate form and is therefore quicker setting. One of the major uses of
plasters is in the manufacture of prefabricated plaster products. Plasterboards, for example, are manufactured by
reslurrying dry plaster which is than encased in durable paper liners. To manufacture blocks, the slurry is poured into
moulds to set and then cut into the required size. For these products a rapidly setting plaster is desirable
(hemihydrate gypsum).
Gypsum can be dehydrated (from dihydrate to hemihydrate) either by dry calcination (under pressure in an autoclave)
or in aquous suspension. Calcination at a temperature of about 150°C converts most of the gypsum into calcium
sulphate hemihydrate. The product contains about 5-6% water.
Phosphogypsum contains a number of impurities which can affect the properties of the plaster: Residual acid
reduces the setting rate and increases the corrosiveness towards building structures, sodium and potassium salt
cause crystalline bloom on the plaster surface. Organic substances discolor the gypsum, etc. The limiting factor in
the use of phosphogypsum is the level of radioactivity (radium content). Because the levels are higher than in natural
gypsum, application of phosphogypsum as plaster product in indoor houses is not acceptable in the Netherlands
without gypsum purification.
With regard to regulation on radioactivity levels in Europe, there are two approaches:
• Regulation on radioactivity levels in building materials. The Netherlands is focussing on radioactivity levels of
building materials normally used (approx. 150 Bq/kg). In Sweden and Germany there is a standard of 200 Bq/kg
for all product categories.
• Regulation on radioactivity in the air in houses/buildings. There are large differences between countries, ranging
from 150 up to 750 Bq/m3 for new houses.
Cement additive
Gypsum is used as an additive in cement to retard the rate at which the cement sets, keeping it in a workable state
for a longer period. Its use also increases the strength of the final material. Suitable purification of phosphogypsum
may be necessary, since phophate and fluoride impurities adversely affect the properties of the cement by delaying
the set and decreasing the initial hardness. The degree of purification required will naturally depend on the
phosphoric acid process and the phosphate rock used.
Industrial use
Gypsum can be used as a filler in the paper industry. The sulphate content in the gypsum can also be reprocessed
for the production of sulphuric acid and cement.
Paper industry
The paper industry uses mineral-based pigments, both as filler and for paper coating.
Filler pigment is mixed with the pulp. The most widely used fillers are kaolin, chalk and talc. The quality
characteristics of filler pigments are very important. The filler affects, amongst other things, the absorption capacity,
porosity and smoothness and the whiteness of the paper. The primary function of the coating pigment is to improve
the printability of the paper. Coating paste is applied on the paper surface. Koalin and calcium carbonate are used as
coating pigment.
The limiting factor in the use of phosphogypsum as filler or for paper coating is its whiteness. Gypsum pigment is
produced from phosphogypsum on industrial scale by Kemira Oy (Finland), based on a high quality phosphogypsum
produced from igneous phosphate rocks and recrystallization of phosphoric acid processes (HDH and DHH). Here
the gypsum is washed more thoroughly in order to reduce the amount of residual acid. The filter-dry gypsum is
dispersed with water by means of dispersion chemicals. The gypsum slurry is milled to a low particle size and
stabilising chemicals are added to the slurry.
If phosphogypsum contains impurities with a colouring effect, bleaching of the gypsum is necessary.
Recycling to sulphuric acid and cement
Gypsum is useful in producing sulphuric acid and cement by calcination with clay and coal around 1450°C. Gypsum
is decomposed to form lime (CaO) and sulphur dioxide (SO2). CaO reacts with clay to produce cement, while SO2 in
the gas is used to produce sulphuric acid by the conventional catalytic process. Major problems with phosphogypsum
are the high moisture content, which increases energy consumption. Also the impurities may have adverse effects,
such as poisoning the catalyst delaying the setting in the cement (caused by phosphorus). This process has been
used in England, Germany and Austria. The most recent plant, in Phalaborwa (South Africa), was shut down in 1989
as a result of low sulphur prices.
Annex 4: Detailed process description of the HDH-1 process of Kemira Agro Pernis (KAP)
and the HDH-2 process of Hydro Agri Rotterdam (HAR)
Kemira Agro Pernis (KAP)

The HDH-1 process of KAP comprises phosphate rock grinding, reaction and re-crystallization, gypsum repulping
and product acid desulfatation and evaporation. The diagram of the process is presented below.
p h o sphate rock
grind mill d u st filter d u st to air
water water fluorine to air

sulphuric acid
reactors scrubber fluorine and phosphate to water
flash cooler
return acid water fluorine to air
recrystallisator scrubber fluorine and phosphate to water
water
filter repulp filter g y p su m t o w a t e r
desulfatation
p h o sp. acid
storage fluorine and
water water p h o sp h a t e t o
water
st e a m evaporator separator scrubber condenser
seal vac.pump
Figuur 13: Diagram of the HRC-repulping process of Kemira Agro Pernis
Grinding
The phosphate rock is grinded in a ball mill followed by a particle size separator and cyclones, from which the
particles are pneumatically transported to storage. The finest fraction is adsorbed in a dust filter and the largest
particles are recycled to the mill.
Reaction- and recrystallization system

This section includes two premixers, three reactors and four crystallisators. Sulphuric acid is firstly diluted to 75%;
cooling water is used to control the temperature. In the premixers sulphuric acid and weak phosphoric acid from the
filtration (return acid) are added to the phosphate rock to form calcium phosphate at a temperature of 90°C. In the
reactors this transformation is completed. In the crystallisators the slurry is cooled down to 60°C by direct contact
with cooling air. During cooling down the hemihydrate transforms into dihydrate while the slurry is recirculated.
Scrubbing system
The reaction gases and the extraction air from the crystallisators are washed with water in separate two-stage
scrubber systems. Gas scrubber effluents are discharged into surface water (seawater).
Filtration
In a rotary table vacuum filter the hemihydrate crystals are separated from the phosphoric acid slurry and washed
countercurrently. The process involves a number of stages and filtrate offtakes. The first offtake is the product acid.
The acid collected from the second stage is a return acid, which is pumped back to the hemihydrate reaction system.
The third stage generates acidic washing water. Final cake washing is done using acid from the repulping filter,
before the cake is discharged to the repulping filter. Four vacuum water ring pumps in series, which effluent is
discharged into surface water, maintain the vacuum in the system.
Gypsum repulping section

The final P2O5 losses are removed from the gypsum cake in the repulping vacuum belt filter. The cake undergoes
countercurrent washings. The filtrate is used for washing the rotary table filter. The final wash is used for washing the
rotary table filter cloth. Finally, the gypsum is slurries with river water and discharged into surface water.
Phosphoric acid desulfatation

In the desulfatation unit the remaining sulphuric acid is removed from the product acid. A calculated amount of
phosphate rock is fed to a stirred reactor and reacts with the sulphuric acid to form gypsum. The gypsum slurry is
separated from the acid and pumped to the crystallisators.
Phosphoric acid concentration

The phosphoric acid produced contains approx. 28% P2O5. Concentration of the product acid to 54% P2O5 is
necessary. Concentration is done in four stages by forced vacuum evaporation. Each stage consists of a heat
exchanger, a flash chamber, condenser, vacuum pump and circulation pump. Steam is required for the evaporation
heat. Fluoride gases from the evaporator flash chamber are fed through an entrainment separator to remove P2O5
droplets, followed by absorption in a water scrubber, where fluosilicic acid is produced. The gases are further washed
with water in a direct contact condenser followed by absorption in a vacuum water ring pump. Liquid effluents are
discharged into surface water (seawater).
Prevention and reduction of emissions

The following overview gives a summary of measures which are taken to prevent or minimize emission to air and
water:
• Use of hemihydrate-dihydrate recrystallization process with single stage filtration (Nissan HRC-process),
extended with a repulp filter. The P2O5-recovery efficiency of the process is more than 98%.
• Use of a relatively large excess of sulphuric acid for complete dissolution and good recrystallization of the
hemihydrate gypsum to dihydrate gypsum with a low P2O5-content. (After separation of the product acid from the
dihydrate gypsum, phosphate rock is added to lower the sulphate content in the acid. The gypsum produced in
this operation is returned to the recrystallization section as a slurry. The remaining product acid (28%) is
concentrated in four stages to merchant grade acid (54%) by means of vacuum evaporators, and subsequently
transferred to storage tanks. The sludge from settling and storage tanks is also returned to the recrystallization
section as a slurry.)
• Use of cleanest igneous phosphate rock (Russian Kovdor rock, 65 - 80%) and sedimentary phosphate rock
(Jordan rock, 20 - 35%) presently available.
• Separation and recycle of coarse material to ball mill grinding system to ensure an optimal particle size
distribution for digestion of the phosphate rock particles in the reactors.
• Dust separation at grinding by means of cyclones and fabric filter.

• Fourfold countercurrent washing of gypsum (twofold washing in dihydrate and repulp filtration section each) with
warm wash water to remove as much as possible P2O5 values from the gypsum. The washing cycle produces a
weak acid which is returned to the reactor.
• Two-stage gas scrubbing (pre-washing in exhaust pipe followed by treatment in an unpacked spray tower) of
reaction gases and process air from the reactors and recrystallization tanks. The wash water form the spray
towers, containing mainly fluoride and some phosphate, is discharged to the sea without further treatment.
• Use of droplet separators to remove phosphoric acid droplets form the evaporator off gases, and single stage
washing of the off gases in the evaporator exhaust pipes, with recovery of the fluoride as H2SiF6 in the first three
stages. By subsequently using the wash water in the first, second and third stage, a 28% H2SiF6 by-product is
obtained. The condensable gases which are left after washing (mainly water vapour and some fluoride containing
compounds) are removed by direct contact condensors. Condensor water and the wash water of the fourth stage
are discharged to the sea without further treatment.
• Extraction and washing (in one of the unpacked spray towers) of air from the building where filtration takes place
to avoid diffuse fluoride emissions.
• Continuous monitoring of gas phase fluoride concentration and automatic alarm system to be able to react rapidly
and avoid prolonged air pollution in case limit values are exceeded.
• Reuse of heat arising from sulphuric acid dissolution (96% to 75%) by using heated cooling water as gypsum
wash water.
• Recovery of steam condensate from the evaporator section for use elsewhere (fertilizer plants)
• Frequent cleaning of evaporator section with hot 5% H2SiF6 to remove scale (affects heat transfer), and reuse of
the rinsing liquid as washing liquid for the gypsum filters.
• Leakages and rinsing losses during cleaning and rinsing operations are collected in a closed containment system
and recycled to the process
Hydro Agri Rotterdam (HAR)

The HDH-2 (hemi-dihydrate) process of HAR comprises two reaction systems and two filtration steps. A diagram of
the process is presented below.
Phosphate rock handling
Phosphate rock from storage is sieved and transported by a covered conveyor belt to a weighing unit, where an amount of
rock is dosed to the reaction system.
Grinding
(no grinding)
Hemihydrate reaction system

There are two parallel reaction systems on the HAR site. One reaction system comprises three reactors in series which are
all fitted with agitators. Phosphate rock and recirculated slurry from the flash cooler are fed to the first reactor where part of
the calcium precipitates. In the second reactor sulphuric acid and phosphoric acid from the hemihydrate filter (return acid)
are added with the slurry and the remaining calcium in the slurry precipitates. A flash cooling system, which pumps the slurry
from the second reactor to the first reactor, maintains the system temperature. The third reactor is the filter feed tank.
The second reaction system consists of four reactors and temperature is controlled by air-cooling.
Hemihydrate filtration
In a vacuum belt filter the hemihydrate crystals are separated from phosphoric acid slurry and washed countercurrently. The
process involves a number of stages and filtrate offtakes. The first offtake is the product acid, the second is pumped back to
the hemihydrate reaction system as return acid. Final cake washing is done using acid from the dihydrate filter. Finally, the
cake is discharged to the dihydrate reaction system. Off-gases are washed with water in a direct contact condenser, followed
by absorption in a vacuum water ring pump. Liquid effluents are discharged into surface water, remaining vapours are fed to
a gas scrubber.
p h o sphate rock
water
water flash cooler fluorine to air
sulphuric acid
reactors scrubber scrubber effluent
(fluorine and phosphate)
return acid
water
scrubber effluent
filter scrubber (fluorine and phosphate)
recrystallisator vapour water
filter g y p su m t o w a t e r
p h o sp. acid
storage
water water
steam evaporator scrubber condenser

scrubber effluent
Figuur 14: Diagram of the Hemi-dihydrate process (HDH-2) of Hydro Agri Rotterdam
Dihydrate reaction system

In this process the hemihydrate cake is redissolved and recrystallised as dihydrate gypsum. During this operation, any P2O5
bound in the crystal lattice is released and passes into solution. The P2O5 slurry is fed back into the process. The dihydrate
reaction system comprises two reactors in series, with agitators. In the first reactor sulphuric acid and silica (SiO2) is fed with
the slurry to support the hemihydrate transformation. The second reactor is the filter feed tank.
Dihydrate filtration
The dihydrate slurry from the reactor is pumped to the dihydrate vacuum belt filter. The filter separates the dilute phosphoric
acid solution from the dihydrate crystals. The gypsum cake undergoes countercurrent washings. The filtrate is used as a
final wash for the hemihydrate cake and the hemihydrate fabric filter. Finally, the gypsum and the dihydrate fabric filter
washing water is discharged into the surface water (seawater). The vacuum system of this filter is similar to the hemihydrate
filter.
Scrubbing system
The high temperature of the hemihydrate process results in fluoride formation, mainly as SiF4, to the gas outlet. There are
four gas scrubbing systems to absorb the fluoride compounds. Scrubber effluents are discharged into surface water
(seawater):
• A two-stage scrubber for the first hemihydrate reaction system. Reaction gases from the first two reactors are extracted
by the gas scrubber fan and washed with water in the first gas scrubber stage. Fluoride from the third reactor and the
flash cooler gas stream are scrubbed in the final stage scrubber.
• A single-stage scrubber for gases from the second hemihydrate reaction system.
• A two-stage scrubber for gases from the hemihydrate filter and the dihydrate reactors.
• A two-stage scrubber for gases from the dihydrate filter.
Phosphoric acid concentration

The phosphoric acid produced contains 42% P2O5. Concentration of the product acid to 54% P2O5 is necessary.
Concentration is accomplished by the forced vacuum evaporator system, comprising a heat exchanger, a flash chamber,
condenser, vacuum pump and circulation pump. Steam is required for the evaporation heat.
Apart from water vapour, a mixture of SiF4 and HF is generated during the concentration of phosphoric acid. Most of the
fluoride is absorbed as dilute fluosilicic acid in a scrubber containing a weak fluosilicic acid solution. The required
concentration is maintained by removing an amount of fluosilicic acid product. The gases are further washed with water in the
direct contact condenser. The washing water is recycled to the scrubber systems.
Prevention and reduction of emissions

The following overview gives a brief summary of measures which are taken to prevent or minimize emission to air and water:
• Use of hemihydrate-dihydrate recrystallization process with double stage filtration (HDH-2 process). The P2O5-recovery
efficiency of the process is about 99%.
• Use of cleanest sedimentary phosphate rock (Jordan rock, 100%) presently available.
• Addition of a sodium chloride solution in the hemihydrate reaction system to influence/reduce the uptake of cadmium in
the gypsum crystal lattice.
• Multiple washing of gypsum in countercurrent (dihydrate filtrate is used for washing of the hemihydrate gypsum). The
washing cycle produces a weak acid which is returned to the hemihydrate reactor.
• Hemihydrate reaction system: Washing of vacuum cooler off-gas by means of a direct contact condensor (condensable
gases) followed by washing of the gas in an unpacked spray tower (non-condensable gases). Furthermore two-stage and
single-stage washing of reactor off-gases and cooling air in unpacked spray towers. Condensor water and spray tower
wash water is discharged to sea without further treatment.
• Dihydrate reaction-/recrystallization system: Washing of reactor off-gas in an unpacked spray tower. The wash water is
discharged to sea without further treatment.
• Hemihydrate and dihydrate filtration system: Use of liquid separators to remove entrained phosphoric acid droplets
present in the vacuum filtration off-gases, and subsequent washing of the gases in a “packed bed direct contact
condensor” and an unpacked spray tower. Gases arising from the warm filter surfaces are extracted by an exhaust hood
and also washed in a spray tower. Condensor water and spray tower wash water are discharged to the sea without
further treatment.
• Evaporation system: Washing of evaporator off-gases with a recirculating 25% H2SiF6 solution in a fluoride gas
scrubber, with recovery of the fluoride as H2SiF6. The condensable gases that remain after washing (mainly water vapour
and some fluoride containing compounds) are removed by means of direct contact condensors. The condensor water is
re-used as wash water in the gas scrubber systems of the reaction, recrystallization and filtration sections before being
discharged to the sea.
• Frequent cleaning of the evaporator section to remove scale (affects heat transfer). The rinsing liquid is reused in the
phosphoric acid production process.
Annex 5: Emission monitoring standards used in The Netherlands
Component Monitoring standard Frequency
Emissions to water
COD (Chemical Oxygen Demand) NEN 6633 Frequency of emission

Nitrate (NO3) NEN-EN-ISO 13395 measurement is situation
N-Kjeldahl (Nkj) NEN 6472 specific.
Gypsum (as CaSO4.2H2O) calculation from Ca-content in gypsum slurry
*
Calcium (Ca) NEN 6446 after disclosure according to NEN 6465
Phosphate (P) NEN 6663
Fluorides (F) NEN 6483
Cadmium (Cd) NEN 6426 after disclosure according to NEN 6465
Mercury (Hg) NEN-EN 1483 after disclosure according to NEN 6465
Lead (Pb) NEN 6453 after disclosure according to NEN 6465
Zinc (Zn) NEN 6443 after disclosure according to NEN 6465
Copper (Cu) NEN 6426 after disclosure according to NEN 6465
Nickel (Ni) NEN 6426 after disclosure according to NEN 6465
Chrome (Cr) NEN 6458 after disclosure according to NEN 6465
Arsenic (As) NEN 6426 after disclosure according to NEN 6465
Vanadium (V) NEN 6426 after disclosure according to NEN 6465
Cobalt (Co) RIZA W4.135 after disclosure according to NEN 6465
Rare earth elements (Sc, Y, La, Ce, Pr, Nd,...) NEN 6426 after disclosure according to NEN 6465
Emissions to air The Netherlands Emission Regulations (NeR) are concerned

with process emisions to air and apply as guidelines for the
issuing of licences or for the adjustment of license conditions.
The NeR follows the same basic concept as the German TA-
Luft, except that the classification of some substances has
been adjusted in the light of recent toxicological findings. In
addition, the emission standards for some classes of
substances have been adjusted in line with current knowledge
with regard to best available techniques. In the NeR,
concentration standards for different substances are given,
which constitute upper limits for distinct point sources,
depending on mass flow. The “special regulations” comprise
measuers to limit emissions from incidental discharges or
diffuse sources. Furthermore, in the “special regulations”
rules departing form the “general emission standards” for
certain industries or specific installations are given.
*
Beforehand the sample should be diluted such that visually no solids are present after disclosure.
The Florida Institute of Phosphate Research was created in 1978 by the Florida Legislature
(Chapter 378.101, Florida Statutes) and empowered to conduct research supportive to the
responsible development of the state’s phosphate resources. The Institute has targeted areas of
research responsibility. These are: reclamation alternatives in mining and processing, including
wetlands reclamation, phosphogypsum storage areas and phosphatic clay containment areas;
methods for more efficient, economical and environmentally balanced phosphate recovery and
processing; disposal and utilization of phosphatic clay; and environmental effects involving the
health and welfare of the people, including those effects related to radiation and water
consumption.
FIPR is located in Polk County, in the heart of the central Florida phosphate district. The
Institute seeks to serve as an information center on phosphate-related topics and welcomes
information requests made in person, by mail, or by telephone.
Research Staff
Executive Director
Richard F. McFarlin
Research Directors
G. Michael Lloyd Jr. -Chemical Processing

Jinrong P. Zhang -Mining & Beneficiation
Steven G. Richardson -RecIamation
Gordon D. Nifong -Environmental Services
Florida Institute of Phosphate Research

1855 West Main Street
Bartow, Florida 33830
(863) 534-7160
Fax:(863) 534-7165
THE ECONOMIC BENEFIT OF PHOSPHOGYPSUM USE IN AGRICULTURE
IN THE SOUTHEASTERN U.S.
Greg Traxler, Associate Professor
Auburn University
Department of Agricultural Economics and Rural Sociology
304 Comer Hall
Auburn University, AL 36849-5412
Prepared for
FLORIDA INSTITUTE OF PHOSPHATE RESEARCH
1855 West Main Street
Bartow, Florida 33830
February 29, 1996

DISCLAIMER
The contents of this report are reproduced herein as received

from the contractor.
The opinions, findings and conclusions expressed herein are not
necessarily those of the Florida Institute of Phosphate Research,
nor does mention of company names or products constitute
endorsement by the Florida Institute of Phosphate Research.
PERSPECTIVE
Phosphogypsum, like gypsum from any source, is an almost ideal agricultural source of
both calcium and sulphur. In areas where phosphogypsum is available it has the advantage of
being the most economical of all types of gypsum for agricultural use.
Since it is slowly soluble, phosphogypsum remains available to the plant over long
periods. Unlike lime which makes the soil more alkaline, phosphogypsum is neutral in its soil
reactions. As a calcium source, gypsum is the material of choice for peanut farmers and while
it is a small market, gypsum used to supply calcium to ferns raised for the floral market allows
the soil to remain acidic for optimum growth. In other words gypsum is a hard to beat source
of calcium in agriculture.
Agricultural literature is reporting ever increasing instances of soil sulfur deficiencies that
adversely affect crop yields. With increased emphasis on removing sulphur gases from the air
and the use of high analysis fertilizers that contain little or no sulphur, the previous most
common methods of replenishing soil sulphur no longer exist.
In Florida one type of agriculture that could benefit dramatically from sulfur fertilization
is cattle ranching. In other parts of the world sulfur fertilization of pastures has resulted in as
much as a 20% increase in weight gain for livestock. Phosphogypsum is about the only
agricultural sulfur source that could be economical for pasture fertilization in Florida.
While the USEPA has banned the use of phosphogypsum in agriculture because it is
slightly radioactive, all of the research in this area that we are aware of contradicts the USEPA
assessment. We will continue to work towards having the USEPA revise their ruling by
presenting scientific facts that will allow Florida agriculture to achieve the significant economic
benefits that phosphogypsum can provide.
THE ECONOMIC BENEFIT OF PHOSPHOGYPSUM USE IN AGRICULTURE
IN THE SOUTHEASTERN U.S.
INTRODUCTION
Phosphogypsum is a solid waste byproduct of the wet phosphoric acid method of
processing phosphate rock. It is composed principally of calcium sulfate, but also
contains small amounts of quartz, phosphates, fluoride, radioactive minerals and
heavy minerals. Calcium and sulfur content usually exceed 23 and 18 percent,
respectively (Sumner, 1990).
The National Emission Standards for Hazardous Air Pollutants: National
Emissions Standards for Radon Emissions from Phosphogypsum Stacks of 1990
required that all phosphogypsum be disposed in stacks or mines because of its radium
content and the emission of radioactive radon gas. In 1992 the EPA issued a final
rule on National Emissions Standards for Radon Emissions from Phosphogypsum
Stacks which amended the standard to allow the distribution of phosphogypsum for
use in agriculture provided that the certified average concentration of radium-226 in
the phosphogypsum does not exceed 10 pCig-1. The ruling on the maximum
allowable radium content was based on an assumed 95th percentile application rate of
2,700 pounds per acre biennially for 100 years. The final rule also permits the
distribution of phosphogypsum for use in research and development in amounts not
exceeding 700 pounds per research activity.
1
Agriculture accounts for about 5 percent of the nearly 30 million tons of gypsum
used in the United States each year (Table 1). This report estimates the economic
benefit of removing restrictions on phosphogypsum use in agriculture in the
Southeast.
SIZE AND ORGANIZATION OF THE U.S. PHOSPHATE INDUSTRY
The United States is a major producer of phosphate rock, responsible for

approximately 30 percent of world production. Some 25 million short tons of
phosphate rock were traded on world markets in 1993. U.S. exports averaged nearly
5 million short tons from 1990-93 and are expected to increase as a result of NAFTA
and GATT trade agreements.
A total of 14 companies produced phosphate in the United States in 1993. About

85 % of the U.S. production, or 35 million tons, is accounted for by the six
companies located in central Florida and one in North Carolina. The U.S. also
imported approximately 850,000 tons annually during this period. The U.S. has no
duties or tariffs on fertilizer imports.
GYPSUM PRODUCTION
The U.S. is the world’s leading producer of gypsum. Oklahoma, Iowa, Texas,
Michigan, Nevada, California and Indiana are the largest producers of crude, or
2
mined, gypsum. Plaster, wallboard construction and cement production are the main
uses of gypsum in the United States. There are no operating gypsum mines in the
Southeast. Gypsum used in the Southeast is either byproduct gypsum or imported
mined gypsum. Byproduct gypsum accounts for about three percent of the gypsum
used in the U.S. Of the two major sources of byproduct gypsum, the desulfurization
of stack gas in thermal powerplants provides the largest share of byproduct gypsum.
The National Emissions Standards for hazardous air pollutants of the Clean Air
Act Amendments of 1990 restricts the use of phosphogypsum because of its radium
content and the emission of radioactive radon gas. The Act requires that
phosphogypsum be disposed of in stacks or in mined-out areas. In 1993 it was

estimated that the Florida phosphate industry had about 600 million tons of
phosphogypsum in existing stacks and that about 30 million tons of phosphogypsum
per year (an amount equal to total U.S. gypsum consumption) were being generated
(Llewellyn, 1993). Stacks must be lined with thick plastic sheet to prevent
groundwater contamination. In Florida the cost to build a 400 acre lined stack site in
1993 was estimated at more than $80 million (Llewellyn, p. 2). While
technologically possible to remove the harmful impurities from phosphogypsum, it is
not considered to be economically feasible (Llewellyn, p. 3).
Despite an overall rise in byproduct gypsum sales, phosphogypsum usage has
fallen by 50% since the 1990 EPA ruling limiting its use. An average of 207,000
tons of phosphogypsum were used in 1988-90, while the 1990-93 average is just
3
103,000 tons (Llewellyn). Over the same period, the share of phosphogypsum in
total byproduct sales fell from approximately 30 percent to 10 percent.
GYPSUM USE IN AGRICULTURE
A total of nearly 1.5 million tons of gypsum, including mined gypsum and
byproduct gypsum, were used in agriculture in 1994 (Table 1). Agricultural use
accounts for about 5 percent of the total of nearly 30 million tons of gypsum used in
the United States; construction uses account for 90 percent of total use. To be used
in agriculture, crude gypsum must be pulverized and screened to 100 mesh or finer
after mining. For wallboard production, the screened gypsum must then be further
treated by a calcining process. Agronomists have been unable to detect differences

between the agronomic effects of phosphogypsum and mined gypsum (Mullins and
Mitchell, Sumner).
The uses of gypsum in agriculture fall into three main categories (Sumner): 1) as
a source of calcium for peanut production 2) as a source of sulfur for vegetable crops
and forages 3) as an ameliorant for soil sodicity, crusting and subsoil acidity
problems. Sumner summarizes experimental evidence which examine the potential
for sulfur to increase the yield of several southeastern crops. At present little sulfur,
only 8,000 tons in 1994, is used in agriculture in the region (TVA). The use of
gypsum to reclaim sodic soils occurs primarily in irrigated agriculture, especially in
California, but occurs very rarely in the Southeast. By far the most commercially
important use of gypsum in the Southeast at present is as a source of calcium for
peanut production.
An average of 1.29 million acres of peanuts are planted in the six southern states
of Alabama, Florida, Georgia, North Carolina, South Carolina, and Virginia. The
Southeast’s “peanut belt” is centered about 150-200 miles from Florida’s main
phosphorus mining areas. About 80 percent of U.S. peanut production takes place
within a 100 mile arc around the juncture of the Georgia, Florida and Alabama
borders (Table 2). Georgia accounts for more than half of the U.S. peanut area.
The value of gypsum as a source of Ca for peanut production has been
recognized since the 1940’s (Sumner). Among Southeastern states, recommended
application rates range from 250 lb ac-1 to 860 lb ac-1 for banded application and from
688 lb ac-1 to 1720 lb ac-1 for broadcast application (Sumner).
An average of 198,626 short tons of gypsum are used in agriculture in Georgia,
Florida and Alabama each year (Table 3). Virtually all of this gypsum use is for
peanut production.
An important assumption of the EPA final rule on National Emissions Standards
for Radon Emissions from Phosphogypsum Stacks was the estimate of 1350 lb/ac as
the 95th percentile annual average application rate for phosphogypsum. Evidence that
the application rate used by Georgia peanut farmers is significantly less that this is
provided by survey information collected by the USDA national peanut research
laboratory in Dawson, Georgia. Data on input use levels were collected from a
random sample of 84 peanut farmers in 1991, 1992 and 1993 (Lamb). The sample
5
was selected to be statistically representative of all peanut farmers in Georgia. Forty-
six percent of surveyed farmers applied gypsum. The average application rate over
the entire sample was 402 lb/ac. Of farmers using gypsum, the average application
rate was 879 lb/ac. The 95th percentile application rate was 1,000 lb/ac (Figure 1).
The average gypsum expenditure was $17.44 per season, and the average farm price
was $40.00/ton.
The majority of farmers rotate peanuts with another crop to which they do not
apply gypsum in either a two or three year rotation. This suggests that most fields
receive gypsum on either one out of two or one out of three years, so that the long
run average application gypsum use rate on any given field is one half to one third of
those shown in Figure 1. This would place the survey long run average application
rate at 500 lbs/ac, which is less than 40% of the EPA assumed 95th percentile
application rate. Even the 99th percentile implied average application rate of 750
lb/ac is barely 50% of the EPA assumed 95th percentile.
A similar survey of input use among 30 peanut farmers in Alabama was

conducted by agricultural economists at Auburn University during the 1995 growing
season. Gypsum use among Alabama producers was much lower than among Georgia
producers (Figure 2). Only two producers, 7% of the sample, applied gypsum. The
highest application rate was 1,000 lb/ac, or an implied 500 lb/ac based on a two year
peanut rotation.
6
BENEFIT CALCULATIONS
Welfare analysis will be used in this section to estimate the total benefit from
removing restrictions on the use of phosphogypsum in agriculture. This section
provides a brief background on the economic surplus concepts that are used by
economists for applied welfare analysis. The parameters of the economic surplus
model and the benefit estimates are then presented.
The net economic benefit from allowing unrestricted use of phosphogypsum in

agriculture in Georgia, Florida and Alabama was calculated within the framework of
economic welfare analysis. Welfare analysis, which is a form of benefit/cost

analysis, is the most common method used by economists to quantify the costs and
benefits of changes in government policies. Just, Hueth and Schmitz and Alston,
Norton and Pardey summarize the economic welfare literature which has been
developed since welfare analysis was first used by Ricardo in the early nineteenth
century. Welfare analysis is a tool that is relatively easy to understand and apply as
well as being theoretically justified.
Welfare changes can be decomposed into changes in consumer and producer
surplus. Consumer surplus is the difference between the price a consumer pays for a
product and the price that he or she would be willing to pay. Consumer surplus can
be graphically represented as the area above the price line and below the demand
curve (triangle A in figure 3). The demand curve is called a derived demand curve
when the good being considered is an input such as gypsum which is an input into the
7
production of another commodity, This derived demand curve maps the marginal
value product of the input. The size of consumer surplus depends on the elasticity, or
slope, of the demand curve.
Producer surplus is the area below the price line and above the supply curve
(triangle B in figure 3). When product markets are competitive the supply curve for
the individual firm is the marginal cost curve. If inputs are available in perfectly
elastic supply, the industry supply curve is the sum of the marginal cost curves of
individual firms. Under the common economic conditions of competitive markets and
mobility of factors of production, the marginal cost curve reflects the opportunity cost
of resources. Producers’ surplus is affected by the elasticity of supply. In the special

case of perfectly elastic supply, which characterizes gypsum, no producers’ surplus is
generated.
Agricultural use has a negligible effect on the price of gypsum because the
amount of gypsum used in agriculture is very small both in relation to total gypsum
use (one percent or less), and in relation to the production of phosphogypsum. Each
year the Florida phosphate industry adds some 30 million tons of phosphogypsum to
the existing 600 million ton inventory (Llewellyn). The annual increment to
phosphogypsum stockpiles is 150 times the current total agricultural gypsum use in
the Southeast.
Removing the restriction on phosphogypsum sales would have the effect of

inducing a downward shift of the gypsum supply curve facing producers in the
Southeast (Figure 4). Geometrically, the welfare effect of the shift in supply is seen
8
as the sum of rectangle B and triangle C. These areas have straightforward intuitive
interpretations. Area B is simply the quantity of gypsum used multiplied by the
difference in price between mined gypsum and phosphogypsum. Area C represents
additional surplus due to the fact that more gypsum will be demanded as the price
falls. The size of the increase in the quantity demanded depends on the magnitude of
the demand elasticity. This “surplus triangle” is generally quite small. Note that, as
modeled, this surplus accrues entirely to gypsum consumers, i.e., agricultural
producers. Because supply is perfectly elastic, there is no producer surplus.
The formula for calculating the welfare change, or net benefit, is:
(1) Change in welfare = QJP + OSAPAQ
where Q, is current level of gypsum use, AP is the change in price of gypsum with
phosphogypsum restrictions removed, and TQ is the change in gypsum consumption
as the price falls. The ?Q is based on an assumed elasticity of demand for gypsum
of -0.2. The first term in (1) is simply the price change times the current quantity of
gypsum used and is equal to area B in figure 5. The second term accounts for the
small increase in gypsum use which will occur as the price falls (area C in figure 5).
Equation (1) is the annual benefit of the fall in the price of gypsum. Since this is
expected to be a permanent price reduction, the total financial benefit is the net
present value (NPV), which is the discounted sum of the annual benefit amounts for
all future years.
9
The Tennessee Valley Authority (TVA) reports average annual gypsum use
quantities for 1985-94 of 155,200 short tons in Georgia, 43,284 in Florida and 158
tons in Alabama. No published studies have estimated the elasticity of demand for
gypsum, but several reported elasticity estimates for phosphorus and nitrogen are
reported (Larson and Vroomen, Roberts). A value of q =-0.2 was used in this study.
Some uncertainty exists about the equilibrium gypsum price when

phosphogypsum restrictions are removed. Conservative estimates of the new gypsum
price were used in the benefit calculations. Phosphogypsum can currently be
purchased F.O.B. White Springs, Florida for $10.00/ton. White Springs is
approximately 100 miles from the center of Georgia peanut production, and about the
same distance from central Florida phosphate production. It is assumed that with the
entry of new phosphogypsum suppliers in central Florida, northern Florida suppliers

will be forced to reduce their price to meet this competition. Because of the cost of
adding to existing phosphogypsum stockpiles, it is assumed that central Florida
suppliers will be willing to supply phosphogypsum at a zero price F.O.B. central
Florida. The delivered farm price will then be determined by the transportation price
of $7.00/ton/l00 miles. Because White Springs is approximately 100 miles nearer
than other suppliers to the peanut growing areas, it, will not be forced to supply
phosphogypsum at a zero price, but rather will need to meet the effective north
Florida price of other phosphogypsum suppliers of $7.00 (i.e. the cost of
transportation from central Florida to White Springs). The result is that the delivered
10
gypsum price to Georgia, Alabama and north Florida peanut growing areas can be
expected to fall by a minimum of $3.00/ton.

There is a second economic benefit to society of the use of phosphogypsum in
agriculture. This is the cost saving that results from not adding any phosphogypsum
used in agriculture to existing stockpiles. This economic benefit accrues to
phosphorus producers. The estimated average cost per ton of constructing a

50,000,000 ton stack with a 10 year life is estimated at $49,000,000 (Rubin). This
cost includes neither capitalized interest expense, nor annual direct costs of handling
phosphogypsum. Kendron estimates per ton costs of stacking phosphogypsum at
$1.50 to $2.00. The $1.50 per ton cost will be used in this study.
The annual net benefit accruing to agricultural producers is estimated to be nearly
$$609,284 if prices fall by $3/ton. The reduced storage cost for the industry would
be $297,938, for a total economic benefit of nearly $900,000. The net present value
of this annual benefit flow is $17,606,768 using a 3% real discount rate. Because of
the uncertainty involved with predicting this future gypsum price, benefit calculations
were done using price assumptions ranging from a price reduction of $1.00/ton up to
a $10/ton reduction (Table 4).
SUMMARY
Economic welfare analysis was used in this study to estimate the benefit of
unrestricted use of phosphogypsum in agriculture in the states of Georgia, Florida and
11
Alabama. An average of nearly 200,000 tons of gypsum are used in agriculture in
these three states each year, primarily as a source of calcium for peanut production.
The most important information presented is the survey data on gypsum
application rates in Southeastern agriculture. Forty-six percent of peanut producers

in Georgia apply gypsum. Of farmers using gypsum, the average application rate is
879 lb/ac. Assuming a two year peanut rotation, the implied 99th percentile
application rate in Georgia is 750 lb/ac. Only seven percent of Alabama farmers
surveyed applied gypsum, with the highest observed application rate being 500 lb/ac,
assuming two-year peanut rotation.
Using an assumed $3.00 per ton fall in the price of gypsum if central Florida
phosphogypsum were to enter the market, the total annual net benefit from removing
the restriction on gypsum use in agriculture is estimated to be nearly $900,000. Of
the total annual net benefit approximately $600,000 would be passed on to agricultural
producers through lower prices, while reduced storage cost for the industry would be
nearly $300,000. The net present value of this annual benefit flow is $17,606,768.
12
REFERENCES
Alston, J.M., G.W. Norton, and P.G. Pardey. 1995. Science under Scarcity:
Principles and practices for agricultural research evaluation and priority setting.
Cornell University Press, Ithaca, NY.
Davis, L.L. 1993. Gypsum. in Minerals yearbook. U.S. Bureau of Mines, Dept. of
the Interior.
Just, R.E., D.L. Hueth, and A. Schmitz. 1982. Applied welfare economics and public
policy. Prentice Hall, Englewood Cliffs, NJ.
Kendron, T.J. Sulfur Recovery from Phosphogypsum. Paper presented at the Florida
Institute of Phosphate Research Forum, Tallahassee, Florida, December 7,1995.
Lamb, M. 1995. Economic Analysis of Planning, Management and Marketing Peanuts
in the Southeast U.S. Unpublished Ph.D. dissertation, Auburn University.
Larson, B.A. and H. Vroomen. 1991. Nitrogen, phosphorus, and land demands at the
U.S. regional level: A primal approach. Journal of Agricultural Economics.
42:354-64.
Llewellyn, T.O. 1993. Phosphate rock. Minerals Yearbook. U.S. Bureau of Mines,
Dept. of the Interior.
Mullins, G.L. and C.C. Mitchell. 1990. Use of phosphogypsum to increase yield and
quality of annual forages. Publication No. 01-048-084 of Florida Institute of

Phosphate Research, Bartow Florida.
Roberts, R.K. 1986. Plant nutrient demand functions for Tennessee with prices of
jointly applied nutrients. Southern J. Agric. Econ. 18: 107-112.
13
Rubin,G.J. Phosphogypsum Handling. Paper presented at the Florida Institute of
Phosphate Research phosphogypsum Fact-Finding Forum, Tallahassee, Florida,
December 7, 1995.
Sumner, M.E. 1995. Use of calcium and sulfur as nutrients for crops in florida:
Reconciliation of literature review with EPA’s final rule on phosphogypsum.
Draft report prepared for Florida Institute of Phosphate Research.
Sumner, M.E. 1990. Gypsum as an ameliorant for the subsoil acidity syndrome.
Publication No. 01-024-090 of Florida Institute of Phosphate Research, Bartow
Florida.
Tennessee Valley Authority. Various years. Commercial fertilizers. TVA, Muscle

Shoals, AL.
14
Table 1. Gypsum use: Total, byproduct, and phosphogypsum, U.S. and Southeast
(Georgia, Florida and Alabama), 1989-93
1989 1990 1991 1992 1993
Tot. use, U.S.* 27,068 25,691 21,859 27,113 29,460
Tot. use ag., U.S.’ 1,172 1,381 1,560 1,193 1,350
Ag. share tot. U.S. 4.3% 5.4% 7.1% 4.4% 4.6%
S.E. ag. use* 204 248 220 159 215
S.E. ag. share tot.,U.S. 0.8% 1.0% 1.0% 0.6% 0.7%
Byproduct sales, U.S.* 725 667 618 694 933
Phosphogypsum sales, U.S.* 174 207 136 69 103
Byproduct share tot. gypsum 2.7% 2.6% 2.8% 2.6% 3.2%
Phosphogypsum share tot.
gYPsum 0.6% 0.8% 0.6% 0.3% 0.3%
* Thousands of short tons
Sources: Llewellyn; TennesseeValley Authority
15
Table 2. Peanut area planted in Georgia, Florida, and Alabama, 1985-94
YiZU Georgia Florida Alabama Total
1,000 acres
1985 595 80 201 876
1986 670 93 220 983
1987 630 91 221 942
1988 690 98 237 1,025
1989 690 95 240 1,025
1990 782 102 258 1,142
1991 900 126 278 1,304
1992 675 88 237 Loo(--)
1993 700 92 240 1,032
1994 640 75 220 935
Avg 1985-94 697 94 235 1,026
Source: USDA
16
Table 3. Gypsum use in agriculture in Georgia, Florida, and Alabama, 1985-94
YCXU Georgia Florida Alabama Total S.E.
Short tons
1985 185,604 31,378 0 216,982
1986 125,924 53,932 0 179,856
1987 154,079 31,793 19 185,891
1988 187,837 31,342 15 219,194
1989 176,007 27,101 477 203,585
1990 206,135 42,111 nr 248,246
1991 184,610 35,627 146 220,383
1992 105,879 53,311 299 159,489
1993 141,140 74,175 134 215,449
1994 84,784 52,068 329 137,181
Avg 1985-94 155,200 43,284 142 198,626
nr = not reported
Source: Tennessee Valley Authority
17
Table 4. Annual economic benefit and present value of benefit under wrious
assumed changes in price agricultural gypsum
Annual Annual Total

Change in agricultural stacking present
price benefit cost saved value
$1.00 $199,122 $297,938 $9,742,606
$2.00 399,237 297,938 13,664,954
$3.00 600,346 297,938 17,606,768
$4.00 802,447 297,938 21,568,048
$5.00 1,005,542 297,938 25,548,793
$6.00 1,209,630 297,938 29,549,004
$7.00 1,414,711 297,938 33,568,681
$8.00 1,620,785 297,938 37,607,823
$9.00 1,827,852 297,938 41,666,432
$10.00 2,035,912 297,938 45,744,506
18
Figure 1. Distribution of gypsum application rates among Georgia peanut farmers
60%
50%
2 40%
s
3
; 30%
2
s
ii! 20%
10%
500 550 600 650 700 800 827

Gypsum Application Rate (lb/ad
Figure 3. Consumer and producer surplus
Price
SUPPlY
Demand
Q Quantity
21
Figure 4. Change in economic surplus from a shift in supply
Price
Supply before policy change
P’
\ Demand
I 1
I I
I I
I I
Q Q’ Quantity
22
Figure 5. Shift in supply of gypsum
Price
Present Supply of Gypsum

P’
Supply of Phosphogypsum
P
I
I
I I
.
I
.
I
I I
.
: I
I
: I
I
I
I
I Agricultural Demand for Gypsum
:
:
.
I
.
I :
\
I
I
I
I
.
. :
I
I :
I .
I m
I .
I I
I I
I
I
I
:
I
Q’ Q Quantity
23
Fluorine Recovery http://www.waterwatchofutah.com/reservoirs.htm
Phosphorous & Potassium, September/October 1979 No. 103, pp. 33-39 Fluorine recovery in the
fertilizer industry - a review.
by H.F.J. Denzinger, H.J. Konig and G.E.W. Kruger
The fluorine compounds liberated during the acidulation of phosphate rock in the manufacture of
phosphoric acid and fertilizers are now rightly regarded as a menace, and the industry is now
obliged to suppress emissions of fluorine-containing vapours to within very low limits in most parts
of the world.
As with any pollution control operation, it is highly desirable for the operator of the fluorine
scrubbing operation to find a use or market for the recovered fluorine to help defray at least partially
the cost of the operation.
This article reviews the chemical and technical principles of gaseous fluorine compound removal,
the principal types of practical fluorine recovery processes that have been developed and their
limitations, and possible methods of utilizing the fluosilicic acid solution which these processes
generate.
Most phosphate rocks mined today contain an average of 3-4% fluorine. When they are processed to
phosphoric acid (the basic material from which a variety of fertilizers are manufactured) fluorine
compounds appear at various process stages. For the purposes of this review the volatile fluorine
compounds HF and SiF4 are of prime interest, as they can be separated relatively easily from the
reaction vapours during the acidulation or concentration by scrubbing with water or dilute fluosilicic
acid. Many authors have dealt with the processes for and problems of fluorine recovery from wet-
phosphoric acid in the last decade. Besides a few review articles, (67-75) the publications refer to
separation techniques for fluorine compounds, e.g. precipitation, (1-16) solvent extraction, (27-35)
ion exchange (35-40) and volatilization. (41-66).
In the past, little attention was paid to the emission of gaseous fluorine compounds in the fertilizer
industry. But today fluorine recovery is increasingly necessary because of stringent environmental
restrictions which demand drastic reductions in the quantities of volatile and toxic fluorine
compounds emitted into the waste gases. These compounds now have to be recovered and
converted into harmless by-products for disposal or, more desirably, into marketable products. At
the same time, the expected depletion of natural fluorspar reserves, the main source of fluorine
compounds, within the next 2-3 decades increases the importance of fluorine recovery from
phosphate rock. As phosphate rock reserves are guaranteed until the end of the next century (78)
silicon tetrafluoride or fluosilicic acid might well become the most important source of fluorine for
the chemical industry.
Only part of the fluorine contained in phosphate rock is economically recoverable with today's
technology. In the course of wet-process phosphoric acid production by sulphuric acid attack
(dihydrate and hemihydrate processes) 45-60% of the fluorine is released in gaseous, recoverable
compounds, 30-45% of the fluorine precipitates in the gypsum in solid compounds while 5-10%
remains as an impurity in the acid. During single or triple superphosphate production, the portion of
volatile compounds diminishes to about 10-25%.
Fluosilicic acid recovered by scrubbing these volatile compounds could in future become the
primary raw material for chemicals such as aluminum fluoride and cryolite - auxiliaries
indispensable in Hall-process aluminum smelting - or hydrofluoric acid and others which, until now,
are normally produced from natural fluorspar. Even synthetic fluorspar can be obtained for use as
flux in steel making.
Fluorine recovery
During the production of phosphoric acid from fluorapatite (3Ca3(PO4)2CaF2) and a strong mineral
acid, the calcium fluoride present in the rock is converted, by reaction with the silica also present,
into fluosilicic acid according to the following equations:
CaF2 + 2H+ (H2SO4, HNO3, H2PO4, HCl) >

(1) 2HF + Ca++
(2) 4HF + SiO2 > SiF4 + 2H20
(3) 3SiF4 + 2H2O > 2H2SiF6 + SiO2
The hydrogen fluoride and silicon tetrafluoride are partly evolved directly as vapours and partly form
fluosilicic acid which, under the influence of heat, decomposes again into volatile SiF4 and HF,
leaving the reaction vessel together with the water vapour.
As the heat of the reaction evolved in the attack stage is much less than that required for
evaporation, the major portion of the volatile fluorine compounds is obtained during subsequent
concentration of the phosphoric acid.
In the production of single and triple superphosphate or weak (28-32%) phosphoric acid, silicon
tetrafluoride is preferentially volatilized because under the conditions prevailing its vapour pressure
is higher than that of hydrogen fluoride. As the phosphoric acid is concentrated up to 54% P2O5,
more and more hydrogen fluoride escapes. The molar ratio HF:SiF4 in the vapours increases sharply
with the concentration of the phosphoric acid and surpasses 2 when the acid concentration is 50%
P2O5 or more. At molar ratios below 2, reaction (3) will take place when the vapours are scrubbed,
and surplus silica will be precipitated in the scrubber liquor, an effect that has to be considered
when designing equipment for fluorine recovery.
There are two distinct basic types of process in use:
- fluorine recovery under atmospheric pressure (as used in single and triple superphosphate and
weak phosphoric acid production)
- fluorine recovery under vacuum (used in the concentration of phosphoric acid from 30%-50% P2O5
and in evaporative cooling of reaction slurry during phosphoric acid production)
Typical descriptions of the two process types are given below. The second is of greater importance,
as it represents the larger recoverable fluorine source.
Fluorine recovery at atmospheric pressure
The gases (mainly silicon tetrafluoride) extracted from the reaction vessel are fed to a venturi
scrubber in which the silicon tetrafluoride is absorbed, forming fluosilicic acid and silica (Fig. 1). The
scrubbing liquid is dilute, circulating fluosilicic acid. To increase scrubbing efficiency (up to 99%)
two or more units are placed in line. Dust can be eliminated first, if necessary, in a special scrubber.
Precipitated silica must be removed from the product, for example by filtration. The concentration of
the formed fluosilicic acid depends on the use to which it is to be put; normally it is maintained at
between 18 and 25%. The higher the concentration of the acid, the lower the washing efficiency.
Fluorine recovery under vacuum
The superheated vapours from the flash vessel of the phosphoric acid concentration plant first pass
through a high-efficiency entrainment separator. This is essential to reduce the P2O5 contamination
of the vapours, and thus the product, to a minimum; this is particularly important if the product
fluosilicic acid is to meet the purity specifications demanded for certain of its uses. The collected
mixture of dilute phosphoric and fluosilicic acid is sent back to the concentration unit and thus does
not represent a loss of either fluorine or P2O5. The cleaned vapours are then fed to a fluorine
scrubber, where the silicon tetrafluoride and hydrogen fluoride they contain are absorbed using
circulating fluosilicic acid as the scrubbing liquor. Fluosilicic acid (18%-25%) is withdrawn
continuously under density control and the corresponding amount of water is introduced into the
system. (Fig 2) For economic reasons, it is desirable to achieve the required fluorine recovery with
one scrubber stage only. However, this depends on various factors which need to be carefully
investigated before the final decision is made.
Whereas the attainable fluorine recovery largely depends on the fluorine content of the incoming
vapour as well as the concentration and the temperature of the fluosilicic acid produced, the P2O5
content of the fluosilicic acid is mainly dependent on the P2O5:F ratio in the vapours from the flash
vessel and on the efficiency of the P2O5 separator. Figure 3 shows the fluorine recovery efficiency
versus the fluorine content of the vapours for a single-stage scrubbing unit for different
concentrations of circulated fluosilicic acid. From this it is quite clear that a high fluorine recovery
cannot be achieved with a single-stage unit when a high fluosilicic acid concentration is required
and at the same time the fluorine content of the vapours is low. In that case, a second scrubbed
stage would be necessary.
Figure 4 shows the P2O5 contamination of the fluosilicic acid in relation to the P2O5 content of the
vapour, expressed as the P2O5:F ratio for different fluosilicic acid concentrations, based on a
constant fluorine level in the vapours and a given efficiency of the P2O5 separator of 98%. The P2O5
impurities of a 25% fluosilicic acid in this case are almost twice as high as for an 18% fluosilicic
acid.
Figure 5 is similar to Fig 4 but it indicates the influence of the fluorine content of the vapours for a
given H2SiF6 concentration.
From this it follows that, for an existing installation, neither the efficiency of the fluorine absorption
unit nor the P2O5 content of the fluosilicic acid is constant. They depend rather on the type of
phosphate rock processed as well as on the actual operating conditions of the phosphoric acid and
concentration plant.
Direct uses of fluosilicic acid
Fluosilicic acid has only limited applications for direct use but it can be used advantageously as a
raw material for the production of, for example, aluminum fluoride and cryolite; this will be described
later. Its direct use is restricted because of its low concentration and the relatively high amount of
impurities, as shown below for a typical acid composition:
H2SiF6 18-25%
P2O5 100 ppm
Fe2O3 70 ppm
SO4 1,000 ppm
Cl 1,000 ppm
The main characteristics of fluosilicic acid are its bactericidal and fungicidal effects, because of
which there is some direct use as a sterilizing and impregnating agent in breweries and for wood
protection. Today, some attempts have been made, mainly in the United States, to fluoridate drinking
water with up to 1 ppm F using fluosilicic acid or its salts. (80)
Pure silicon tetrafluoride is not isolated on an industrial scale because of the great expense of doing
so. Only one process is described in the literature (the Ochrate process) for direct uses of SiF4 in
which dry concrete is treated with SiF4 gas to improve stability and abrasion strength. (81)
Disposal as a waste
The strong and poisonous fluosilicic acid has to be converted into inert and harmless waste
products if no suitable application exists. Small plants, especially, are often confronted with the
problem on economic grounds. They prefer to neutralize the acid, for example with limestone or milk
of lime, to precipitate the acid as a mixture of calcium fluoride and silica.
The precipitated solids are filtered off and removed as a waste product, sometimes together with
gypsum from the phosphoric acid plant. The neutralization has to be closely controlled to avoid
problems in settling and filtration. However, it is difficult to achieve complete neutralization, and
therefore small amounts of poisonous fluorine compounds are still found in the effluent.
Use in the production of fluorine compounds
There are various ways of using fluosilicic acid as a raw material to produce essential fluorine-
containing materials on an industrial scale.
Aluminum fluoride
Aluminum fluoride and cryolite are used to reduce the melting point of alumina (forming an eutectic
mixture) in electrolysis plants producing aluminum metal. Normally about 20-30 kg aluminum
fluoride and about the same amount of cryolite are consumed per tonne of aluminum, depending on
the specific process conditions. The P2O5 content of these flux materials should be as low as
possible in order to minimize losses of electrical energy.(125)
The classical route for producing this indispensable auxiliary of the aluminum industry is from
hydrogen fluoride and aluminum hydroxide; the modern processes using fluosilicic acid (82-117) are
divided into the acid and the ammonia process. The acid process, especially the one developed by
Chemie Linz, (118-121) is of greater significance, having been in industrial use since 1962.
According to this process the required quantities of aqueous fluosilicic acid and aluminum
hydroxide are mixed in a reaction vessel. At the boiling point and by careful control of distinct
process conditions, the following reaction takes place:
H2SiF6 + 2Al(OH)3 + 2H2O > 2(AlF3 3H2O) + SiO2
The trihydrate crystallizes very slowly and therefore the precipitated silica is separated first from the
quasi "metastable" solution. The filtrate is then discharged to a batch crystallizer, where the
precipitation of the trihydrate is completed within several hours with the aid of some seed crystals.
The separated trihydrate is converted into pure AlF3 (97%) by calcination at 550 C.
A variant of this process has been developed by Derivados del Fluor, (122) while Bayer (123)
proposed that the reaction should be carried out at elevated temperature and pressure to form a
water-depleted product, AlF3 H2O directly.
The ammonia treatment of fluosilicic acid results in a solution of ammonium fluoride in the first step,
which after separation of the silica, is converted first to ammonium cryolite by addition of partly
calcined aluminum hydroxide and subsequently into pure AlF3 (Mekog-Albatros process). (124)
The ammonia is recycled.
Cryolite
There are no significant differences between the various processes for manufacturing cryolite. (126-
147) IG-Farben was the first to develop a process in its factory at Oppau in 1940. It was based on
neutralization with ammonia and treatment with sodium aluminates.
This fundamental process was modified in many ways, for example to improve filtration of silica
(148) or to minimize the impurities in the cryolite. (149)
According to a suggestion of VEB Stickstoffwer Piesteritz, (150) ammonium fluoride, formed by the
neutralization of fluosilicic acid with ammonia, can be converted into to cryolite by reaction with
sodium hydroxide and then aluminum fluoride.
Chemie Linz has developed a process to neutralize fluosilicic acid in different reaction vessels with
aluminum hydroxide and soda ash, forming aluminum fluoride and sodium fluoride solutions, which
after separation of the precipitated silica, react to give cryolite.
Instead of soda ash, caustic soda can be used.
Other routes use fluosilicates as an intermediate product, for example, the process of Kaiser
Aluminum, (151) Montedison, (152) and Onoda. (153) The Kaiser Aluminum process has been used
in the United States for more than ten years. However, a major disadvantage of this process is the
dilute hydrochloric acid by-product.
Hydrofluoric acid
To produce hydrofluoric acid from fluosilicic acid, a number of processes have been developed,
(154-174) but none has so far been used industrially. According to their principles, five groups of
processes can be distinguished.
a) Fluosilicic acid is decomposed, by the action of concentrated sulphuric acid, into the gaseous
components of hydrofluoric acid and silicon tetrafluoride. Hydrofluoric acid is separated from the
sulphuric acid solution by means of distillation. Processes of this kind have been developed both in
the U.S.S.R. (175) and by the Tennessee Corp. (178)
b) Another suggestion (179) refers to the thermal decomposition of fluosilicic acid. Because of its
higher vapour pressure, silicon tetrafluoride is evaporated preferentially and the water solution is
enriched with hydrofluoric acid, which is purified afterwards by distillation.
c) Ammonium fluoride solution, prepared from fluosilicic acid and ammonia, is converted into
ammonium hydrogen fluoride by means of evaporation. This component reacts with sulphuric acid
forming hydrofluoric acid.
d) A quite different separation principle comprises using the better solubility of hydrofluoric acid in
organic solvents (for example polyether) during the evaporation of fluosilicic acid. (181)
e) Synthetic fluorspar made from fluosilicic acid may be used in place of the natural mineral in
sulphuric acid attack.
Fluorspar
As for hydrofluoric acid, much research work has been done to develop processes for the
production of synthetic fluorspar from fluosilicic acid, although no industrial-scale application has
been described to date. The number of publications increased in the last years as a result of the
expected shortage of natural fluorspar reserves, and the promising perspectives for the use of a
mixture of calcium fluoride and silica as a fluorspar substitute in steelmaking. (182) Finally, pure
synthetic fluorspar can be used as a raw material for producing hydrofluoric acid, the basic
compound of the fluorine industry. Unfortunately, this process route is not yet economic.
The neutralization of fluosilicic acid with limestone or milk of lime is the main principle of fluorspar
production. (182-187) Normally, the calcium fluoride and silica are precipitated together but, under
certain process conditions, silica remains metastable in the solution. Alternatively, silica can be
precipitated first by using the reaction between fluosilicic acid and ammonia to form ammonium
fluoride, which is afterwards converted into calcium fluoride.
Fluosilicates
These components can easily be produced by treating fluosilicic acid with salts like calcium chloride
and potassium chloride because of their low solubility in water.
Though their direct use is limited to some applications in disinfectants, fluosilicates can serve as
raw material for the production of other fluorine compounds, as has been described.
Prospects for fluorine recovery
More than 100 million tonnes of phosphate ore are consumed annually, from which approximately
1.2 million tonnes of fluorine could be recovered and converted into essential fluorine compounds.
(198) The future development of fluorine recovery can be considered optimistically because of the
increasing environmental responsibility and positive perspectives in aluminum production. (199-201)
Nevertheless, fluorine recovery and recycling in the aluminum industry itself have to be taken into
account, which reduce the specific fluorine consumption. (202) However, as this applies mainly to
the recovery of fluorine in the form of cryolite it is very likely that the specific consumption ratio of
cryolite to aluminum fluoride will change in favor of aluminum fluoride.
Note: This online version of this article does not contain the lengthy list of references, nor the
diagrams and all of the chemical equations that are contained in the original.
Vol. 28 BOOKS AND REPORTS 1007
chology and the 60 other extensive quo- is the refrain, " Treat the child as an
tations from case histories of behavior integrated whole."
problems and their treatment, it would The book should serve its purpose
be described as a well organized and well, whether its reader be the embryo
carefully documented reference book. psychoclinician, to whom it is ad-
The author's clear interpretation of his dressed, the medical student, or the
material and the practical applications physician or school administrator seek-
of it give it added value as a " textbook ing to keep abreast of the most recent
for students of clinical psychology." work in the field of clinical psychology.
Its contents may be briefly indicated: FREDERICK W. BROWN
Part I-Methods, includes an introductory
chapter and two chapters on Diagnostic More of My Life-By Andrea
Methods, devoted to Anamnesis and Ex- Majocchi. New York: Knight Pub-
amination and to Psychometrics, respectively. lishers, 1938. 313 pp. Price, $2.50.
Part II-Problems Correlated with Abili-
ties, deals with the following topics, to each All who read Life and Death will
of which a chapter is given: Mental De- welcome this addition to the auto-
ficiency or Feeble-Mindedness; School Re- biography of Italy's famous surgeon.
tardation; Specific Disabilities in School Sub- The author speaks of these new stories
jects; and Superiority. as "Pages from my life . . ." "notes
Part III-Primary Behavior Problems, con-
tains 6 chapters covering the following sub- torn from -a surgeon's diary," yet they
jects: Behavior Problems: Introduction; have, as he says, a definite relationship
Conduct Problems; Juvenile Delinquency; to one another although apparently
Speech Defects; Personality Problems; Psy- little connected. To a certain extent
choneuroses and Psychoses.
Part IV-Problems Correlated with Organic it is a biographical sketch of a great
Disabilities is divided into two chapters, the friend and senior surgeon, Dr. Franco
first dealing with Sensory Defects and the Forti.
second with Neurological and Physical Disa- Biographies, even of the humblest
bilities. people, if they are sincere, carry much
A list of references and a good index of interest. When we have the story
complete the volume. of a man who has come into contact
In a foreword L. T. Meiks, M.D., with life in so many varied forms as
emphasizes the unique opportunities of the author of this book, it cannot but
the family physician and the pedia- be of intense interest. Some of the
trician for observation and intimate chapters have been dedicated. to three
knowledge of the family background of persons, an unknown patient, a nun,
children under their care and the recog- and a priest, who had been deeply
nition "of many of these behavior dis- moved by reading Life and Death. We
orders in their incipience, before the have no hesitation in picking out these
untrained associates of the child realize chapters as easily the best in the book,
that the reactions are in any way un- The Sacrifice, The Hymn to the Sun,
desirable. An enlightened medical Mass at the Front, and Sunset. To
profession," he says, " can do much to these we would add, Human Depths.
prevent the development of these dis- It seems to have become the fashion
orders and to handle them in the proper for doctors to write autobiographies.
fashion once they have appeared." Among those which have appeared, this
Both Dr. Meiks and the author recog- stands easily among those at the top.
nize the need for the specialized technics It is the story of a man who has worked
of the trained psychiatrist and clinical hard, studied both books and men, has
psychologist in solving many behavior loved his kind and devoted his life to
problems. Running throughout the book their betterment. Above all, -it is simple
1008 AMERICAN JOURNAL OF PUBLIC HEALTH Aug., 1938
and sincere. It can be recommended manner in which the author deals with
without reservation. the subject expresses itself in a mono-
The book is beautifully printed and graph which includes 57 tables, 96
gotten up. It is a pity that the trans- figures, and a bibliography of 893
lator did not consult a doctor, which references.
would have avoided several errors which Although primarily begun as an in-
jar on the professional man. dustrial hygiene study, the author has
MAZYCK P. RAVENEL encompassed the whole field of fluorosis
in a manner that makes the book one of
Step by Step in Sex Education- equal interest to those in other branches
By Edith Hale Swift, M.D. New of medicine, especially pediatricians,
York: Macmillan, 1938. 207 pp. Price, orthopedists, and radiologists, as well as
$2.00. epidemiologists, dentists, biochemists,
This is a unique presentation of veterinarians, and agriculturists.
sex education material arranged in The discussion of the prevention of
dialogue form between parents and fluorine intoxication embraces the whole
a boy and girl in the normal relations group of fluorine compounds found in
of family life. It proceeds step by industry. The author states (p. 310)
step as the children advance in age to that " it would be desirable to forbid
give them a scientific nomenclature of the employment of males under 18 years
sex anatomy and physiology, at the and females as a whole, on work with
same time revealing to each child the fluorine compounds which give off dust
personal and social implications of sex. or vapour." The necessity for control
It is written primarily for parents who of all sources where fluoric dust or vapor
are at a loss to know how to approach is generated, is emphasized in detail,
the subject when confronted by the not only with respect to the workers
curiosity and perplexing questions but to that area surrounding the factory
which modern children present. It is that might become contaminated by
clothed in everyday conversational volatile fluorine compounds.
style and is clear and concise without Although numerous experiments in
a trace of morbidity, although the induced experimental fluorosis have
author does not stop at introducing the shown considerable storage of fluorine in
most intimate situations in sex relations. the bones with a resultant development
The only part of the book which might of defective osseous structure, Roholm
arouse controversy is that dealing with demonstrates that comparable condi-
contraception, which is confined to a tions are not uncommon among cryolite
few pages at the end. workers.
RICHARD A. BOLT In a chapter entitled " Post Mortem
Examinations of Two Cryolite Work-
Fluorine Intoxication-A Clinical- ers," the author records (p. 184):
Hygienic Study, with a review of the "After Skeletonizing, the bones present
literature and some experimental in- marked changes. All are of a chalky-
vestigation-By Kaj Roholm. Copen- white color, the surface is irregular and
hagen: Nyt Nordisk Forlag-London: the weight considerably increased."
H. K. Lewis and Co. Ltd., 1937. Calcification of the ligamentous attach-
364 pp. ments was commonly observed. The
In a succinct review, it is impossible fluorine content of the costal bones was
to do adequate justice to what is prob- 9.9 and 11.2 mg. per gm. of bone ash
ably the outstanding contribution to the respectively whereas about 0.5-2.1 mg.
literature of fluorine. The thorough of fluorine per gm. of bone ash is re-
Nutrition Noteworthy
Volume 2, Issue 1 1999 Article 4
A Pediatrician’s Guide to Infant Dental

Hygiene: Focus on Fluoride and Nutrition
Sukey Egger∗
∗
David Geffen School of Medicine at UCLA,
Copyright 1999
c by the authors, unless otherwise noted. This article is part of the collected
publications of Nutrition Noteworthy. Nutrition Noteworthy is produced by the eScholarship
Repository and bepress.
Abstract
As future pediatricians some of us will be asked seemingly benign questions, the answers
to which are not simple and are mired in current public health controversy. One of these
questions will be about dental hygiene for infants. This paper poses some common questions
parents may ask, and attempts to provide the information necessary to provide the best answers
possible. Plaque is a buildup of microorganisms that produce acid as a byproduct of sugar
metabolism. This acid demineralizes the tooth’s enamel; fluoride slows acid production and
provides the substrate for remineralization. Development of caries depends on the relative
rates of de- and remineralization. Los Angeles’ water supply is unusual for a major city in
the US because it contains amounts of fluoride well below the optimal levels recommended by
public health officials (1.0 ppm). Despite the low fluoride content, fluoride supplementation for
infants is not recommended by the American Academy of Pediatrics due to evidence of dental
fluorosis (mottling of teeth) after exposure to excess fluoride. The clearest recommendations
for parents of infants are to only provide sweets at mealtimes, including sweetened beverages,
and to brush their children’s teeth with a low fluoride toothpaste as soon as the teeth erupt.
Keywords: infant, fluoride, nutrition, dental hygiene
Suggested Citation:
Sukey Egger (1999) “A Pediatrician’s Guide to Infant Dental Hygiene: Focus on Fluoride and
Nutrition ”, Nutrition Noteworthy : Vol. 2: Article 4.
http://repositories.cdlib.org/uclabiolchem/nutritionnoteworthy/vol2/iss1/art4
Egger: Infant Dental Hygiene: Focus on Fluoride and Nutrition 1
A Pediatrician's Guide to Infant Dental Hygiene: Focus on Fluoride and Nutrition

As future pediatricians some of us will be asked seemingly benign questions, the answers to
which are not simple and are mired in current public health controversy. One of these questions
will be about dental hygiene for infants. Our first priority is to our patients and their families, so
we need the best answers to the most common questions. Second, we need to be aware of the
classic and current research findings in order to feel confident in these answers and to help
influence public policy regarding issues such as water fluoridation. This paper poses some
common questions parents may ask, and attempts to provide the information necessary to
provide the best answers possible. Many parents will respond best to the handy American
Academy of Pediatrics table below, while others will want more detailed answers.
Parent's Question: I remember the commercials with Crest toothpaste vanquishing the
"cavity creeps". They hated Fluoride. What is fluoride and why did they hate it so?
Information to Help You Answer This Question: Fluoride is a trace element that has been
demonstrated to be effective in preventing and fighting dental caries. The "creeps" were actually
bacteria in plaque that build up on teeth. These bacteria produce acid as a byproduct of sugar
metabolism and this acid demineralizes the tooth's enamel (12). When fluoride is present in the
oral cavity, along with calcium and phosphate, the tooth can use it to engage in remineralization
of enamel. Development of caries into cavities is dependent on the relative rates of
demineralization and remineralization (12; 1; 10; 4). Parents of an infant must consider both
preeruptive and posteruptive effects; during the first year of life, infants' primary and permanent
teeth will be developing (preeruptive), and some teeth will be erupting (posteruptive). Fluoride is
administered by two methods accordingly: systemically and topically. Systemic administration
of fluoride assists in development of teeth; in addition, systemic fluoride is released from
salivary glands following stimulation by sugars, bathing the oral cavity in saliva containing
fluoride (15).
In order to demonstrate the efficacy of fluoride in preventing dental caries, many types of studies
have been conducted. Many studies (over 113 studies in 23 countries; 11) have established a
clear causal link between fluoride and caries prevention. Some studies established test
communities with optimally fluoridated water and control communities without water
fluoridation. Other studies used an ABA design in which a community's dental health is
evaluated before fluoridation, after fluoridation, and after cessation of fluoridation. While there
are some methodological problems, such as communities being able to decide whether they are
test or control communities, in general the findings are quite conclusive. Optimal caries
protection by fluoride occurs between 1 and 2 ppm (1-2 mg/L water) (12, 1, 10; for excellent
reviews).
Q: Sounds like fluoride is pretty important, but why do I have to worry about it for my
child. Don't they put fluoride in the water these days?
A: In light of the discovery of Fluoride's protective effect, public health officials recommended
adding fluoride to water supplies (3). However, these officials found that when water levels
exceeded 1.5 ppm (1.5mg/L) there were significant increases in a mottling of the teeth, called
fluorosis. Thus, optimal levels of fluoridation were set at 1 ppm.
Produced by eScholarship Repository, 2008

2 Nutrition Noteworthy Vol. 2 [1999], No. 1, Article 4
Los Angeles' water is not optimally fluoridated, with levels often far lower than recommended.
In fact, there are only seven of the 50 largest US cities without optimally fluoridated water (12).
Many cities have reduced their fluoride content for several reasons, some political (people
believe fluoridation violates their rights to 'pure water'; e.g., the landmark "Strathclyde
Fluoridation Case"), and others scientific (evidence of fluorosis now that most people are
receiving fluoride from other sources, such as fluoride toothpastes).
Water in Los Angeles comes from a variety of sources. The majority of West Los Angeles, the
San Fernando Valley, and South Bay receive water from the Los Angeles Filtration Plant and the
MWD Jensen Treatment Plant. Downtown and South Central Los Angeles receive water from all
four sources below. The DWP monthly monitors the sources, reservoirs, tanks, and distribution
mains to determine water contents. Fluoride content in 1997 from these sources were:
Fluoride Content
Source Range Average
Los Angeles Filtration Plant 0.4-0.6 0.5
MWD Jensen Treatment Plant 0.2 0.2
MWD Weymouth Treatment Plant 0.2-0.3 0.3
River Supply Conduit 0.3-0.5 0.4
Thus it can be concluded that children in Los Angeles are not receiving optimal levels of fluoride
from their drinking water, and some may be getting significantly less that this amount.
Q: I've heard of Fluoride supplements. If my child isn't getting Fluoride from the water,
should I be giving her these supplements? And if so, how much?
A. There are many types of supplements that children can take (see 10; 1; 12; for reviews). These
include tablets, drops, rinses, and gels topically, and fluoridated milk and salt systemically.
These supplements arose at the same time as water fluoridation, in response to significant
community-wide dental problems. Some measures were taken in schools, such as having all
children take tablets or rinses each day in school. Some infant formulas were also supplemented
with fluoride in the hope of reducing "baby bottle mouth" (rampant caries from constant suckling
on bottles filled with sweet solutions).
While these measures were effective at the time, today supplementation is problematic. Children
now receive fluoride from many sources. Parents and physicians need to estimate the amount of
fluoride children receive from all sources before deciding to implement supplementation in order
to prevent fluorosis (mottling of the teeth) and fluoride overdose(14). Decisions about
supplementation need to consider (a) all sources of fluoride, (b) child's age and size, and (c)
child's caries risk status. Recently, the American Academy of Pediatrics developed the following
guidelines on supplementation (7):
American Academy of Pediatrics Fluoride Supplementation Recommendations

Water Fluoride Content (in ppm)
Age <0.3 0.3-0.6 >0.6
Birth-6 mo 0 0 0
6 mo - 3 yr 0.25 0 0
3 - 6 yr 0.50 0.25 0
6 - 16 yr 1.00 0.50 0
This table provides a helpful rule of thumb for a practioner in many cases. However, it is clear
that it is problematic. First, the water fluoride content used in this table may not be helpful for
the community in question. For example, in Los Angeles' Westside, water comes from two
sources, which have average fluoride contents of 0.5 and 0.2. The proportion of the water that
comes from each of these sources varies day to day, depending on the availability of water that
day (2). In addition, the range of water from a site may vary week to week and month to month.
For example, the aqueduct's water sometimes has levels as high as 0.6. This makes determination
of "water fluoride content" very complex. Depending on the day of the week, a child may fall
into any of the three categories above. Second, the table does not consider other sources of
fluoride, such as swallowed toothpaste, and fluoridated products. Some infant foods, especially
those high in chicken, have been found to have high fluoride content and should be considered
(Heilman et al., 1997). Finally, the table does not consider caries risk status, which some
researchers consider a function of previous caries, diet, and socioeconomic status. Despite the
difficulty of using this table, it is clear that for parents of infants who are not believed to be at
particular risk of caries, no supplemention is recommended, regardless of the level of water
fluoridation.
Q: Can I brush his teeth with my own toothpaste?
A: Early research suggested that systemic ingestion of fluoride was most helpful in preventing
caries. The most current research is suggesting that post-eruptive effects of fluoride in balancing
the levels of demineralization and remineralization are most crucial. Thus, teeth should be
brushed carefully as soon as they erupt. To prevent fluorosis and accidental overdose (14),
children should use either a low fluoride paste (500mg) if possible and should be taught not to
swallow as soon as they are old enough. Currently only between 2% and 39% of parents reported
brushing their infant's teeth with fluoride dentifrice (9). In addition, some research has shown
that teeth should not be rinsed after brushing in order to maximize the effectiveness of fluoride
application. Tooth brushing and establishing a routine of brushing daily is likely to be one of the
most effective dental preventive habits a parent can teach a child. This may be difficult and
parents may need lots of reinforcement for helping their child establish good dental hygiene
practices.

Q: What about my child's diet? Are there foods that are better or worse?
A: Nutrition is an important factor in controlling dental caries in children and adults. The most
cariogenic foods are those high in sugars (particularly glucose, sucrose, and fructose), especially
foods that are sticky and will remain in the mouth, such as raisins and toffee. Plaque pH falls
below demineralization levels within 10 minutes of eating sugars, and pH levels do not return to
baseline for 40 minutes after consumption (12). Thus, frequent eating of sugars places teeth at
higher risk. Eating sweets with meals can be considered safe because this limits the amount of
time the sugars are available to the microorganisms, and it also encourages the flow of saliva.
Fast flow saliva is alkaline and can help balance the pH flux. This is thought to be the basis for
some of the protective effects of foods that stimulate salivation (e.g., sugarless gum).
The presence of fluoride during and after meals can have several beneficial effects. In addition to
aiding in remineralization, the presence of fluoride also has been shown to reduce the metabolic
acid production rate of the plaque, resulting in smaller pH shifts (8).
The following table reviews foods that are cariogenic, non-cariogenic, and protective:
Cariogenicity Food
High Sugars (sucrose, glucose, fructose, maltose)
Fine processed grains with sugars (e.g., cookies, sweet breads)
Sugared, fruit-flavored drinks (e.g., Hi-C, Kool-Aid)
Sweetened fruit juices
Extremely high consumption of fruit (especially bananas and apples)
Very Low/Non Cooked, staple starchy foods (i.e., whole grain breads, rice, pasta, potatoes)
Artificial Sweeteners
Fresh fruit (especially citrus)
Protective FLUORIDE!!!!
Milk (Calcium, Phosphorus, Casein, Fat)
Cheese (possibly, not a lot of studies)
Plants (phospate/phytate, still under clinical investigation)
Fibrous Foods (possibly, due to intense chewing stimulating salivary flow)
Sugar-free chewing gum
Summary
In summary, when parents of infants under one year ask for advice about dental hygiene, a
simple clear response often works best in terms of adherence to recommendations:
1. Diet: Limit sweets to mealtimes; includes sweetened beverages and sweeteners on

pacifiers
2. Toothbrushing: Brush your children's teeth as soon as they erupt with a small (pea-
sized) amount of fluoridated children's toothpaste (500mg). Do not allow them to
swallow this toothpaste if possible.
3. No supplementation: Do not supplement infants with fluoride
4. Public health efforts: Consider purchasing fluoridated water or writing policymakers in
support of public health efforts to optimally fluoridate your community's water source.
5. Ask again next year. Guidelines are different for older children and there is some
evidence in support of fluoride-containing implants, fissure and pit sealants, and unique
combinations of fluoride with other chemicals (10; 5) that may enhance its effectiveness.
Currently these are problematic and expensive, but future developments may make them
more practical.
REFERENCES
1. Burt BA, Eklund SA. Community-based Strategies for Preventing Dental Caries.
In: Pine CM, ed. Community Oral Health. Oxford: Reed Educational &
Professional Publishing Ltd.; 1997: 112-121.
2. California Department of Health Services (DHS). City of Los Angeles 1997
Annual Water Quality Report.
3. Dean HT, Arnold FA, Elvove E. Domestic water and dental caries, V. additional
studies of the relation of fluroide domestic waters to dental caries experience in
4425 white children aged 12-14 years, of 13 cities in 4 states. Public Health
Report. 1942; 57: 1155-1179.
4. Ehrlich A. Nutrition and Dental Health, 2nd ed. Albany, NY: Delmar Publishers;
1994.
5. Gaffar A, Blake-Haskins JC, Sullivan R, Simone A, Schmidt R, Saunders F.
Cariostatic effects of a xylitol/NaF dentifrice in vivo. International Dental
Journal. 1998; 48: 32-9.
6. Heilman JR, Kiritsy MC, Levy SM, Wefel JS. Fluoride concentrations of infant
foods. Journal of the American Dental Association. 1997; 128: 857-63.
7. Klish WJ, Baker SS, Flores CA, Georgieff MK, Lake AM, Leibel RL, Udall JN.
American Academy of Pediatrics Fluoride Supplementation for Childre: Interim
Policy Recommendations. Pediatrics. 1995; 95.
8. Lenander-Lumikari M, Loimaranta V, Hannuksela S, Tenovuo J, Ekstrand J.
Combined inhibitory effect of fluoride and hypothiocyanite on the viability and
glucose metabolism of Streptococcus mutans, serotype c. Oral Microbiology and
Immunology. 1997; 12: 231-5.

9. Levy SM, Kiritsy MC, Slager SL, Warren JJ, Kohout FJ. Patterns of fluoride
dentifrice use among infants. Pediatric Dentistry. 1997; 19:50-55.
10. Murray JJ, Naylor MN. Fluorides and Dental Caries. In: Murray, JJ, ed. The
Prevention of Oral Disease. 3rd ed. Oxford: Oxford University Press; 1996: 32-
67.
11. Murray JJ Rugg-Gunn AJ, Jenkins GN. Fluorides in Caries Prevention, 3rd ed.
Wright, Butterworth Heinemann: 1991.
12. Rugg-Gunn AJ. Dental Caries. In: Welbury, RR, ed. Paediatric Dentistry.
Oxford: Oxford University Press; 1997: 93-114.
13. Rugg-Gunn AJ. Diet and Dental Caries. In: Murray, JJ, ed. The Prevention of
Oral Disease. 3rd ed. Oxford: Oxford University Press; 1996: 3-31.
14. Shulman JD, Wells LM. Acute fluoride toxicity from ingesting home-use dental
products in children, birth to 6 years of age. Journal of Public Health Dentistry.
1997; 57: 150-158.
15. Twetman S, Nederfors T, Petersson LG. Fluoride concentration in whole saliva
and separate gland secretions in schoolchildren after intake of fluoridated milk.
Caries Research.1998; 32: 412-6.
16. Brunette DM. Critical Thinking: Understanding and Evaluating Dental Research.
Chicago: Quintessence Publishing Co, Inc.; 1996
17. Cecil Textbook of Medicine, 20th ed.
http://home.mdconsult.com/das/book/view/201?sid=2307598.
18. Chen M, Andersen RM, Barmes DE, Leclercq MH, Lyttle CS. Comparing Oral
Health Care Systems: A Second International Collaborative Study. Chicago: The
World Health Organization; 1997.
Health risks from drinking of demineralised water
http://www.lenntech.com/health-risks-demineralized-water.htm
Introduction
A community’s drinking water supply comes from ground and surface water sources.
Every country's regulations require communities to treat and disinfect drinking water
before distributing it to the public, because of the possible presence of pollutants
(micro organisms, toxic minerals and metals, organic chemicals, radioactive
substances, additives). Usually surface water has to undergo many more purification
steps than groundwater to become suited to drink. Every country has its own legal
drinking water standards. These prescribe which substances can be in drinking water
and what the maximum concentrations of these substances are. The standards are
called maximum contaminant levels. They are formulated for any contaminant that
may have adverse effects on human health and each company that prepares
drinking water has to follow them up. The main guidelines about drinking water
standards are published by the World Health Organization (WHO) and by the
European Union (EU).
There are several problems that can endanger the quality of the drinking water and
some diseases can occur by drinking improperly treated water.
Even if the water is purified and cleaned, it can miss some minerals or desirable
substances, not being fully appropriate for consumption. In fact, not all substances
present in water are necessarily harmful to our health: some substances are health
improving.
Water almost or completely free of dissolved minerals as a result of distillation,
deionisation, membrane filtration, electrodialysis or other technology is called
demineralised water.
There are many pros and cons on drinking demineralised water. The argument in
favour of drinking it is that the minerals present in water intervene with our body
functions. Many books are written by doctors and nutritionists claiming that the
presence of minerals in drinking water causes disease. The arguments against
drinking demineralised water are that we lost a primary source of necessary minerals
in our diet and that water that has lost its own minerals will attract and absorb
minerals in our body, causing a mineral deficit.
Drinking water hardness

When water is referred to as 'hard' this means that it contains more minerals than
ordinary water. These are especially the minerals calcium (Ca) and magnesium (Mg).
Hardness is expressed in terms of calcium carbonate (CaC03). Water with less than
75 milligrams per litre (mg/l) is considered soft, 76-150 mg/l moderately hard, and
above 150 mg/l hard water.
The degree of hardness of the water increases when more calcium and magnesium
dissolve. ‘Soft’ water is water that contains small amounts of calcium and
magnesium. Some soft water is naturally occurring, but most of it is created by
water softeners. A water softener is a unit that is used to soften water, by removing
the minerals that cause the water to be hard. A water softener collects hardness
minerals within its conditioning tank and from time to time flushes them away to
drain. Ion exchangers are often used for water softening. When an ion exchanger is
applied for water softening, it will replace the calcium and magnesium ions in the
water with other ions, for instance sodium (Na) and potassium (K). The exchanger
ions are added to the ion exchanger reservoir as sodium and potassium salts (NaCl
and KCl).
Health risks
There has been much publicity over the years about the negative health effects of
drinking softened water, but recent research showed that the amount of salt
consumed by drinking softened water is insignificant when compared to overall daily
salt intake. Anyway over the past 25 years research has continued to amass in
support of the beneficial role of minerals in water: studies of populations in areas of
naturally occurring hard water and soft water have found few occurrences of
cardiovascular diseases, cancer, diabetes, respiratory diseases or other health
problems in hard water areas.
A domestic, innovative system, which can be used to get perfectly balanced
proportions of minerals good for our health in drinking water, is provided by
Lenntech. For more information go to our home water filter web page.
In the draft of the rolling revision of the WHO guidelines for drinking-water quality,
titled ‘Health risks from drinking demineralised water’ by F. Kožíšek, the possible
health consequences of low mineral content water consumption are divided in the
categories: direct effects on the intestinal mucous membrane, practically zero
calcium and magnesium intake, low intake of other elements, loss of calcium,
magnesium and other essential elements in prepared food, possible increased dietary
intake of toxic metals, possible bacterial re-growth.
Direct effects on the intestinal mucous membrane

It has been demonstrated that consuming water of low mineral content has a
negative effect on homeostasis mechanisms. Homeostasis literally means ‘same
state’ and it refers to the process of keeping the internal body environment in a
steady state. In his publication Kožíšek states that "experiments in animals have
repeatedly shown that the intake of demineralized water leads to diuresis (increased
urination caused by substances present in the kidney tubules), extra cellular fluid
volume and serum concentration of sodium and chlorine ions and their increased
elimination from the body, lower volumes of red blood cells and other hematocritic
changes (alteration of the number of red blood cells)". A German study carried out
by th German Society for nutrition proved instead that if distilled water is ingested,
the intestine has to add electrolytes to this water, taking them from the body
reserves. After the ingestion of distilled water the electrolytes dissolved in the body
water are further dilute. Inadequate body water redistribution may compromise the
function of vital organs.
In the past, acute health problems were reported in mountain climbers who had
prepared their beverages with melted snow. which was not supplemented with
necessary ions. A more severe course of such a condition coupled with brain
oedema, convulsions and metabolic acidosis was reported in infants whose drinks
had been prepared with distilled or low mineral bottled water (CDC 1994).
Practically zero calcium and magnesium intake

Calcium and magnesium are essential elements for our body. They can be provided
to our organisms by food, but even the diets rich in calcium and magnesium intake
may not be able to fully compensate their absence in drinking water.
Calcium is part of bones and teeth. In addition, it decreases neuromuscular
excitability, is beneficial to the conducting myocardial system, heart and muscle
contractility, intracellular information transmission and blood clotting. Osteoporosis is
the most common manifestation of calcium deficiency; a less common but proved
disorder attributable to Ca deficiency is hypertension.
Magnesium plays an important role as a cofactor and activator of more than 300
enzymatic reactions including glycolysis, ATP metabolism, transport of elements such
as sodium (Na), potassium (K) and calcium through membranes, synthesis of
proteins and nucleic acids, neuromuscular excitability and muscle contraction etc. It
acts as a natural antagonist of calcium. Magnesium deficiency increases risk to
humans of developing various pathological conditions such as vasoconstrictions,
hypertension, cardiac arrhythmia, atherosclerotic vascular disease, acute myocardial
infarction, preeclampsia in pregnant women, possibly diabetes mellitus of type II and
osteoporosis (Rude, 1998; Innerarity, 2000; Saris et al, 2000).
Researches and studies proved that water low in magnesium can cause increased
morbidity and mortality form cardiovascular disease, higher risk of motor neuronal
disease, pregnancy disorders, preeclampsia. Water low in calcium may be associated
with higher risk of fracture in children, certain neurodegenerative diseases, pre-term
birth and low weight at birth. Lack both in calcium and in magnesium can also cause
some types of cancer.
Water hardness and cardiovascular disease

Over 80 observational epidemiological studies relating hardness and cardiovascular
disease risks have been realized and their results had been discussed by experts at
the meeting organized by the WHO European Centre in Rome on November 11-13,
2003. The conclusions are quoted in the WHO report titled: 'Nutrient minerals in
drinking-water and the potential health consequences of long-term consumption of
demineralized and remineralized and altered mineral content drinking-waters',
published in August 2004.
It was observed a positive (protective) association between cardiovascular disease
mortality and increased water hardness in countries around the world, both for
population and on individual-basis. It was then supposed that these beneficial health
effects can possibly be extended to large population groups on a long- term basis by
adjusting the water quality.
It was pointed out that magnesium and possibly calcium may be effective in reducing
blood pressure in hypertensive individuals. Nutritional studies suggest that some
other micronutrients may have a beneficial role associated with their presence in
drinking water, even is they have not extensively considered in these epidemiological
studies yet. More studies are needed to better understand the possible risks and
benefits of essential and trace elements found in water.
The discussion group concluded there is sufficient epidemiological evidence of and
inverse relationship between magnesium concentration in drinking water and
ischemic heart disease mortality, and therefore the reintroduction into demineralised
water in the remineralisation process would likely provide health benefits. There are,
in fact, no known harmful human health effects associated with the addition
magnesium within a large range and the nutritional benefits are well known. It is
thought that adding calcium provides the same benefits, however, a correlation
between calcium in drinking water and decreases in the occurrence of heart disease
is not yet proven substantially.
Low intake of some essential elements

The contribution of water to uptake of some essential elements for humans is
important because the modern diets are often not an adequate source of some
minerals. Moreover these minerals are often present in water as free ions, so they
are more readily adsorbed from water compared to food. Recent epidemiological
studies suggest that low mineral drinking water may be a risk factor for hypertension
and coronary heart disease, gastric and duodenal ulcers, chronic gastritis, goitre,
pregnancy complications and several complications in infants. A study of this kind
conducted in 1992 by Lutai on two populations living in areas with different levels of
dissolved minerals showed that the population of the area supplied with water low in
minerals showed higher incident rates of these disease. Children living in this area
exhibited slower physical development and more growth abnormalities, pregnant
women suffered more frequently from oedema and anaemia.
High loss of calcium, magnesium and other essential elements in food prepared with
low mineral water
If soft water is used for cooking it can cause substantial losses of all essential
elements from food. In contrast, if hard water is used, the loss of these elements is
much lower. Since the current diet of many people does not provide all the necessary
elements in sufficient quantities, it is important to not loose essential elements and
nutrients during cooking. Therefore, in the areas supplied with soft water, we have to
take into account not only a lower intake of magnesium and calcium from drinking
water but also a lower intake of magnesium and calcium from food due to cooking in
such water.
Risk from toxic metals

Low mineralised water is highly aggressive to materials with which it comes into
contact. It easily adsorbs metals and some organic substances from pipes, coatings,
storage tanks and containers. Moreover, calcium and magnesium in water and food
are known to have an antitoxic activity: they can prevent the absorption of some
toxic elements from the intestine into the blood. Population supplied with low-
mineral water may be at a higher risk in terms of adverse effect from exposure to
toxic substances compared to populations supplied with water of average
mineralization. Calcium and to a lower extent also magnesium in both drinking water
and food were previously found to have a beneficial antitoxic effect since they
prevent – via either a direct reaction resulting in an no absorbable compound or
competition for binding sites – absorption or reduce harmful effects of some toxic
elements such heavy metals.
Possible bacteria contamination of low-mineral water

The bacterial re-growth is encouraged by the lack of a residual disinfectant and by
the possibly great availability of nutrients in aggressive water, such the low-mineral
water, particularly if it has a high temperature.
Harmful effects of hard water

No evidence is available to document harm to human health from harder drinking
water. Perhaps only a high magnesium content (hundreds of mg/l) coupled with a
high sulphate content may cause diarrhea. Other harmful health effects were
observed in water rich in dissolved solids (above 1000 mg/l of TDS) showing mineral
levels that are not common in drinking water. In areas supplied with drinking water
harder than 500 mg/l CaCO3, higher incidence rates of gallbladder disease, urinary
stones, arthritis and arthropathies as compared with those supplied with softer water
were reported (Muzalevskaya et al, 1993). An epidemiological study carried out in a
particular region (Tambov) found hard water (more than 400-500 mg/l of CaCO3) to
be possible cause of higher incidence rates of some diseases including cancer
(Golubev et al, 1994).
Sensorial disadvantages of hard and soft water

Higher water hardness may worsen sensorial characteristics of drinking water or
drinks and meals prepared with such water: formation of a layer on the surface of
coffee or tea, loss of aromatic substances from meals and drinks (due to bonding to
calcium carbonate), unpleasant taste of water itself for some consumers.
Very soft water, such as distilled and rain water as two extreme examples, is of
unacceptable taste for most people who usually report it to be of unpleasant to soapy
taste. A certain minimum content of minerals, the most crucial of which are calcium
and magnesium salts, is essential for the pleasant and refreshing taste of drinking
water.
Fluoride in drinking water

Most drinking waters contain some fluoride. Processes such anion exchange,
demineralisation and some other treatments which will remove it, affecting its
concentration.
High levels of excess fluoride intake cause crippling skeletal fluorosis. This is almost
always associated with high fluoride intake from drinking water. Ingestion of excess
fluoride during tooth development, particularly at the maturation stage, may also
result in dental fluorosis.
The optimal drinking water concentration of fluoride for dental health is generally
between 0.5 to 1.0 mg/litre and depend upon volume of consumption and uptake
and exposure from other sources. These values are based on epidemiological studies.
The WHO drinking water quality guideline value for fluoride is 1.5 mg/l. The US
Environmental Protection Agency has set a Maximum Contaminant Level of 4.0 mg/l
in the US based upon prevention of crippling skeletal fluorosis and a guidance of 2.0
mg/l to avoid moderate dental fluorosis.
A decision to use demineralised water as drinking water sources without addition of
fluoride during remineralization will depend upon many factors: the concentration of
fluorine in the existing local supply, the volume of water consumed, the prevalence
of risk factors for dental caries, oral hygiene practices, level of public dental
awareness, presence of alternative vehicles for dental care and fluoride available to
the whole population.
Desirable mineral content of demineralised drinking water
In the late 1970’s, the issue of an optimum composition of drinking water,
particularly if obtained by desalination, was in the centre of attention of the WHO.
The WHO also emphasized the importance of mineral composition of drinking water
and warned e.g. against the use of cation exchange sodium cycle softening in water
treatment (WHO, 1978; WHO, 1979).
In the 1980’s the wave of interest in the effect of water hardness on cardio vascular
diseases morbidity rather subsided; it seemed that any new insight into the issue
could not be expected. The focus was on confirming the role of magnesium as a
crucial factor of hardness and on first attempts of more general quantification of its
protective effect.
In the 1990 criticisms of the existing studies started to make a new challenge to
publications of further studies. These critics asserted that morbidity was evaluated at
a population group based level, rather than at an individual-based level and
individual exposure to calcium and magnesium from water was not established. In
other studies, the confounders possibly involved in cardio vascular diseases
morbidity such as age, socio-economic factors, alcohol consumption, eating habits,
climatic conditions etc. were not adequately taken into account.
Most new epidemiological studies of the 1990’s were able to specify the effect of
either calcium or magnesium and also focused on morbidity other than cardio
vascular diseases. During the 90’s research confirmed a protective effect of both
drinking water magnesium and calcium against cardio vascular diseases, and more
data on beneficial effect of these elements in drinking water on human health were
presented.
More recent studies have provided additional information about minimum and
optimum levels of minerals that should be in demineralised drinking water. These
studies suggest for magnesium a minimum of 10 mg/l and an optimum of 20-30
mg/l, for calcium a minimum of 20 mg/l and an optimum of about 50 mg/l, for
fluoride an optimum of 0.5 – 1 mg/l and a maximum of 5 mg/l. For total water
hardness the sum of calcium and magnesium should be 200 to 400 mg/l.
At these concentrations, minimum or no adverse health effects were observed and
the maximum protective or beneficial health effects of drinking water appear to
occur.
Conclusion and recommendations

Minerals are important parts of drinking water and are of both direct and indirect
health significance. Sufficient evidence is now available to confirm that a certain
minimum amount of minerals in water is desirable, since their deficiency have many
negative health effects: diseases and possible aggression from toxic elements and
bacteria.
The optimum Ca and Mg levels in drinking water should lie within the following
ranges: from 20 to 30 mg/l for Ca and from 40 to 80 mg/l for Mg and from about
200 to 400 mg/l for water hardness.
Unfortunately, over the past two decades little research attention has been given to
the beneficial or protective effects of drinking water substances.
As recommended in the rolling revision of the WHO guidelines for drinking water
quality, titled: ‘Nutrient minerals in drinking-water and the potential health
consequences of long-term consumption of demineralised and remineralized and
altered mineral content drinking-waters’, there is a need for more precise data on
the impact of water composition and intake under a broader range of physiologic and
climatic conditions, in order to more precisely evaluate the importance of minerals in
drinking water on mineral nutrition. Additional studies should be conducted on
potential health consequences associated with consumption of both high and low
mineral content waters in addition to consideration of water hardness. When studies
are conducted, investigators should consider exposures to both calcium and
magnesium levels in combination with other minerals and trace elements that may
be present in hard and soft waters. National governments and water suppliers should
be encouraged to practice stabilization of demineralised water with additives that will
increase calcium and magnesium levels and to conduct studies that monitor public
health impacts. Community and bottled water suppliers should provide information to
the general public and health professionals on the composition of water for
constituents including possibly beneficial substances. Water bottlers should also
consider providing waters with mineral compositions that are beneficial for
population segments.
For all you questions on demineralised water move to the demineralised water FAQ
or look at our demiwater web page.
References
• C. Ingram, The drinking water book, Ten Speed Press, 1991

• F. Kožíšek, Health risks from drinking demineralised water, WHO, 2004
• F. Kožíšek, Health significance of drinking water calcium and magnesium,
National Institute of Public Health, February 2003
• Consensus of the meeting August 2004, Nutrient minerals in drinking-water
and the potential health consequences of long-term consumption of
demineralized and remineralized and altered mineral content drinking-waters,
WHO
IMC Fertilizer Group, Inc.
http://www.fundinguniverse.com/company-histories/IMC-Fertilizer-Group-Inc-Company-History.html
Address:
2100 Sanders Road
Northbrook, Illinois 60062
U.S.A.
Telephone: (708) 272-9200

Fax: (708) 205-4804
Statistics:
Public Company
Incorporated: 1988
Employees: 5,000
Sales: $1.06 billion
Stock Exchanges: New York Midwest
SICs: 2819 Industrial Inorganic Chemicals, Nec
Company History:
IMC Fertilizer Group, Inc. (IMCF) was created in 1988 when the onetime International Minerals
& Chemicals Corporation divested its fertilizer assets in the form of a new, publicly traded
company. As the fertilizer market was then in the midst of a long and disastrous slump, the
spin-off proved to be most beneficial for the parent company, which promptly changed its
name to Imcera Group, Inc., and entered the market of high-tech health and animal care
products. IMCF, meanwhile, the largest private-sector producer of phosphate and potash
fertilizers in the world, was left to contend with the continuing collapse of its domestic and
international markets, which never recovered from the price shocks caused by the 1973-74 oil
crisis. IMCF's strategy was a proposed joint venture with its nearest domestic competitor,
Freeport-McMoRan Resource Partners, itself the result of a divestment move similar to that
which created IMCF. If the joint venture was approved by antitrust regulators, it would control
nearly half of all United States phosphate production--an enviable position to occupy, if and
when the fertilizer market regained its former health.
The ancestor of IMCF was formed at the end of the nineteenth century, a time when farmers in
the United States and western Europe were switching from traditional fertilizers to the use of
commercial chemical fertilizers. Scientific experiments in the first half of the nineteenth
century had identified precisely the nutrients needed for plant growth and continued soil
fertility. Chief among these were nitrogen, phosphorus, and potassium, known by their
chemical symbols as the basic N-P-K triad of nutrients. During the preceding centuries of
farming, trial and error experiments had discovered sources for each of these nutrients in such
traditional fertilizers as animal manure, bones, guano, and fish scrap; but with the progress of
chemical knowledge came the search for methods by which N-P-K could be produced in their
most concentrated and inexpensive forms. In the United States commercial fertilizer was
especially desired in the eastern and southern states, where older, over-farmed land responded
well to their application. By the last quarter of the nineteenth century a strong business had
grown up around the phosphate mines of Florida and Tennessee.
The earliest predecessor of IMCF was founded in 1897 in Tennessee by Thomas C. Meadows and
his brother-in-law Oscar L. Dortch. Meadows was an engineering graduate of Vanderbilt
University who understood the potential market for Tennessee's phosphate rock, which when
treated with sulphuric acid yielded a product rich in the form of phosphorus most readily
absorbed by growing plants. With Oscar Dortch, Meadows formed T.C. Meadows & Co. to mine,
process, and sell this "superphosphate" both by itself and in ready-mixed fertilizer containing
suitable proportions of the other two basic nutrients, nitrogen and potash. These would have to
be purchased on the market from sources originating as far away as Germany and Chile, making
the business of fertilizers capital intensive and encouraging the development of large combines
capable of supplying all three ingredients.
With that in mind, Meadows & Co. changed its name in 1899 to United States Agricultural
Corporation and began acquiring the assets it would need to survive in the rapidly consolidating
fertilizer industry. In 1900 it gained control of two companies engaged in the Florida phosphate
mines, Florida Mining Company and Peoria Pebble Phosphate Company. Because Florida's
phosphate fields, located in the central and northern parts of the state, were richer and easier
to mine than those of Tennessee, they soon became the backbone of the U.S. phosphate
industry. In most cases the mines were laid in remote, inhospitable, and sparsely settled areas
where employers such as United States Agricultural could find few workers to perform the
manual labor then required to extract phosphate. The mining companies turned this to their
advantage, however, by building primitive "company towns" and importing convicts from the
state of Florida and others from neighboring Georgia and Alabama. The combination of high-
grade phosphate and cheap labor enabled United States Agricultural to make an excellent
return on its Florida operation and attracted the attention of outside investors eager to get
into the growing fertilizer industry.
Among the financial backers rounded up by Meadows and Dortch, the most important was
Waldemar Schmidtmann, member of an Austrian family that controlled one of the largest
potash mines in Germany--Kaliwerke Sollstedt. Potash is the most abundant mineral source of
potassium and for many years virtually all of the world's known potash was found in Germany,
giving that nation a powerful bargaining chip in its trade with the United States. An industrial
cartel set prices and controlled production of German potash; only intermittently effective,
the cartel was nevertheless sufficiently troublesome for United States importers to make the
possibility of ownership in a German potash mine extremely appealing. Thus Meadows and
Dortch were happy to listen when Schmidtmann proposed a union of their respective holdings,
and in 1901 the Austrian became a partner in the newly renamed International Agricultural
Corporation (IAC). Along with an investment of cash, Schmidtmann also brought to IAC a part
interest in Kaliwerke Sollstedt, guaranteeing the U.S. company access to two of the three basic
fertilizer nutrients.
IAC moved swiftly into the finished product end of the fertilizer business as well, buying up
mixed fertilizer plants from Maine to Alabama in an effort to complete the vertical integration
of the company. IAC was also heavily involved in the growing export market for high-grade
Florida phosphate, whose value as a plant nutrient was gradually being recognized around the
world. It would not be long before the peasants of China and villagers of remote Bulgaria were
introduced to the wonders of commercial fertilizer, and, especially as population pressure
increased in Asia and Africa toward the middle of the twentieth century, the export of
phosphate and mixed fertilizer became increasingly important to the U.S. fertilizer industry.
By 1910 IAC was firmly established as one of the handful of consolidated companies dominating
the U.S. fertilizer business. Controlling between 30 and 40 subsidiary companies engaged in
every aspect of fertilizer production, IAC generated revenues of approximately $8.5 million, on
which it earned a net income of about $1 million. The industry as a whole had enjoyed a
tremendous upsurge over the preceding 20 years; U.S. commercial fertilizer consumption more
than quadrupled, while the traditional methods of organic fertilization all but disappeared
from the landscape.
Problems arose with the approach of the World War I, however. Not only was IAC and the
entire U.S. fertilizer industry dependent on German potash mines, German scientists had also
developed the first reliable method of fixing atmospheric nitrogen in the form of ammonia,
which could then be used in the production of two radically different but equally crucial
materials--fertilizer and explosives. The war forced the U.S. government into a frenzied
development of its own nitrogen-fixing process and the fertilizer industry into a long search for
domestic sources of potash. IAC temporarily lost access to its Sollstedt mine in Germany, but
upon the war's conclusion in 1918 resumed its imports of potash, leaving to other companies
the 20-year search for North American deposits.
It was not until the late 1930s, when war again threatened to cut off German supplies, that IAC
joined other fertilizer concerns in exploring the American Southwest for potash. Oil drilling had
established the presence of potash near Carlsbad, New Mexico, as early as the mid-1920s, and
in 1937 IAC invested $100,000 in the Union Potash Company in exchange for a portion of its
findings. When these proved sizable, IAC effectively bought out Union Potash and built itself a
state-of-the-art potash facility in time to meet its own needs before the onset of World War II
in 1939. IAC has remained one of the largest American producers of potash, pioneering several
new techniques at the Carlsbad mine and in 1962 opening a second major deposit at Esterhazy,
Saskatchewan. The latter required five years of engineering effort to complete its 3,000-foot
shaft but yielded an enormous find of unusually high quality potash.
Phosphate, however, remained the strength of IAC. The company continued to buy or lease
acreage in the central Florida area, where in 1929 it pioneered the flotation method for
separating phosphate pebbles from surrounding sludge, thereby greatly increasing the yield
potential of any given mine. Shortly before that, IAC had opened its first major phosphate
processing plant in Wales, Tennessee, where raw phosphorus was converted into a variety of
products, including such fertilizers as superphosphate and diammonium phosphate and also
cleaning agents like tri-sodium phosphate. By 1939 IAC was the largest producer of phosphate
rock in the world. Population pressure in Asia and Latin America, combined with the needs of
larger, state-owned farms in Eastern Europe and Russia, gave to the business of fertilizers an
importance that ensured that the decades of the 1950s and 1960s would be highly profitable
for manufacturers such as IAC.
As if anticipating the postwar explosion in its foreign trade, IAC in 1941 changed its name to
International Mineral & Chemical, Inc. (IMC) and also shifted its headquarters from Atlanta to
downtown Chicago. With the war's end in 1945, American agricultural methods were studied
and adopted by nations first awakening to the problems of overpopulation and land exhaustion,
and America's agriculture depended above all else on large quantities of fertilizer. Soon Japan
was importing potash for its burdened rice fields, followed by India and a host of lesser Asian
countries, while in the impoverished lands of Africa chemical fertilizers were adopted with the
hope of averting wholesale famine. As long as the world's leading suppliers of commercial
fertilizer were located in the United States and western Europe, fertilizer prices only
strengthened as developing and communist countries upped their usage. Producers such as IMC
responded by increasing capacity and enjoyed a 20-year period of solid profits and continued
expansion.
In 1963 IMC made its belated entry into the nitrogen business, forming a joint venture with
Northern Natural Gas of Omaha, Nebraska, to build an ammonia plant on the Mississippi River in
Cordova, Illinois. A year later IMC underscored its faith in the export business by building its
own ocean shipping terminal near Tampa, Florida, with storage facilities for phosphate rock
and chemicals and a mechanized loading system capable of handling 2,500 tons per hour. At
the same time, to solidify its land transportation IMC began assembling its own fleet of rail
cars, ensuring itself of adequate rolling stock for the highly seasonal business of mixed
fertilizers. The company also took a few tentative steps toward diversifying its holdings with
the 1967 purchase of two industrial mineral firms and the acquisition a few years later of
several container companies.
By that time, however, the world fertilizer market was in the midst of a radical change. Third
World and Communist-bloc nations had placed great emphasis on developing indigenous
supplies of the basic fertilizer nutrients, seeking to free themselves of dependence on the
Western multinationals, and as a result total world production was up sharply by the early
1970s. Many of the new producers were under government control or enjoyed state subsidies,
making it impossible for Western suppliers to offer competitive pricing. This shift was
dramatized by the oil crisis of 1973-74, when skyrocketing energy prices pushed fertilizers up
by as much as 300 percent, providing further impetus for the development of Third World and
Communist-bloc supplies. (The production of nitrogen in the form of ammonia is extremely
energy-intensive, and as nitrogen is the most widely used fertilizer in the world, fertilizer
prices tend to follow the cost of energy.)
Fertilizer prices quickly returned to pre-1973 prices, but the turmoil only confirmed the resolve
of IMC president Richard A. Lenon to pursue a program of diversification. In 1975 IMC paid $207
million for Commercial Solvents Corporation, a major producer of industrial chemicals,
hydrocarbons--including explosives--and pharmaceuticals, including various growth hormones
for livestock. Commercial Solvents also brought with it a sizable ammonia plant in Sterlington,
Louisiana, to which IMC soon added a second facility in an effort to protect itself against any
further price panics in the nitrogen market. 1975 was also the year in which IMC's new state-of-
the-art processing plant began operations near Mulberry, Florida, increasing the company's
production of phosphate and other chemicals in anticipation of energy-driven cost and price
surges.
Unfortunately for IMC, however, the fertilizer market has drifted continually downward ever
since the mid-1970s. What the business periodicals referred to as "the notoriously cyclical
fertilizer industry" was in fact entering a depression that has proven to be all but permanent.
Worldwide use of fertilizers continued to climb, but an ever greater percentage of fertilizer
was produced in developing and centrally planned economies. According to the World Bank, in
1950 the capitalist West produced about 70 percent of the world's fertilizer; by the 1980s that
figure was down to around 30 percent, with the bulk of the new producers located in
Communist-bloc countries that could sell their excess fertilizer below Western market prices.
Exacerbating this general decline was the recession suffered by U.S. agriculture throughout the
1980s, when grain surpluses drove down the commodity markets and idled many farms in the
United States and Canada. Further, the use of phosphates in detergent was banned by the
Environmental Protection Agency in the 1970s, while a growing proportion of the U.S. public
expressed concern about the presence of nonorganic fertilizers in their food.
In the meantime, IMC management made a number of poor business decisions in the early
1980s. The company embarked on a vast expansion of its Florida phosphate rock holdings,
doubled the capacity of its processing plant at Mulberry, and pursued a technique for uranium
oxide recovery at a time when the nuclear energy industry had been brought to a standstill by
opposition from environmentalists. When the fertilizer market hit a ten-year low in 1986, new
IMC Chairman George Kennedy succeeded at last in diversifying the company's holdings with the
purchase of Mallinckrodt Corporation from Avon, Inc., for $675 million. Mallinckrodt, a 115-
year-old St. Louis firm, was powerful in medical imaging technology and pharmaceuticals. IMC
soon added Pitman-Moore, an Illinois-based manufacturer of animal health products.
IMC's Kennedy then made the kind of brilliant strategic decision that will doubtless be the
subject of a business school case study. Recognizing the fundamental weakness of the fertilizer
business, which then supplied about half of corporate revenue, he made IMC into a holding
company with three separate subsidiaries--IMC Fertilizer, Mallinckrodt, and Pitman-Moore.
When fertilizer prices rose briefly in early 1988, he sold off 62 percent of IMC's stock in a public
offering, then gradually sold the remainder of IMC's holdings back to IMC itself. By means of
this adroit maneuver, IMC freed itself of the troubled fertilizer business while picking up the
cash to make another major purchase in 1989, when it added Cooper Animal Health Group.
Kennedy changed IMC's name to Imcera Group, Inc., and has fared splendidly ever since.
IMCF has not prospered to nearly such a degree. U.S. agriculture remained weak, while the
demise of communism brought an enormous amount of fertilizer into the open market at
bargain prices; the formerly state-controlled economies were desperate to obtain cash from
the West. The severe recession that began in 1989 was a further blow to IMCF's fortunes, as
were a 1992 special charge of $166 million for accounting charges and a 1993 settlement of a
lawsuit for $169 million. The suit was brought by various parties following an explosion at a
nitroparaffin plant in Sterlington, Louisiana, in May of 1991; eight employees were killed and
many injured by the explosion, which occurred in a plant operated by IMCF although owned by
Angus Chemical Company.
With fertilizer prices dropping to their lowest levels since the mid-1970s, IMCF formed a joint
venture in 1993 with Freeport-McMoRan Resource Partners to pool their phosphate holdings.
While it is hard not to see this move as the rather desperate attempt of a staggering giant to
salvage what it can from a hopeless situation, it may yet prove to be a winning combination
once the world fertilizer market returns to some semblance of order. With one half of all U.S.
phosphate production, the new joint venture would obviously dominate a healthy phosphate
market, but as of 1993, it remained only the largest player in a losing game.
Further Reading:
Chemical Week, January 27, 1993, p. 9.

"Growing With Agriculture to Feed a Hungry World," Northbrook, Illinois: IMC Fertilizer
corporate publication, c. 1991.
"IMC Group Charts Chemical Course," Chemical Week, September 17, 1975, p. 18.
"IMC: Slimmer Profits for a Fertilizer Giant," Chemical Week, March 17, 1982, pp. 44-50.
Improving the Supply of Fertilizers to Developing Countries, Washington, DC: The World Bank,
1989.
Kemezis, Paul, "Imcera's Quick-Change Act," Chemical Week, July 18, 1990, pp. 22-24.
Nelson, Lewis B., History of the United States Fertilizer Industry, Muscle Shoals, AL: Tennessee
Valley Authority, 1990.
"Prairie Province Goes Wild Over Potash," Business Week, July 21, 1982, pp. 110-114.
Source: International Directory of Company Histories, Vol. 8. St. James Press, 1994.
MODELING THE IMPACT OF A
PHOSPHOGYPSUM STACK ON THE GROUNDWATER AQUIFER
by
Manfred Koch
and
Takashi Thomas Shinkawa
Temple University
Philadelphia, PA 19122
March, 1997
1
TABLE OF CONTENTS
1. INTRODUCTION………………………………………………
2. BACKGROUND……………………………………………….
Location…………………………………………………….
Geology……………………………………………………..
Hydrogeology………………………………………………
3. METHODS OF DATA ANALYSIS ..…………………………
Phosphogypsum Stack……………………………………
Surficial Aquifer………………………………………….
4. HYDROLOGIC DATA ..………………………………………
Stack Analysis……….……………………………………..
Analysis of Hydraulic Heads………….……………
Cooper-Jacob Straightline Method..…………………
Pressure Transducer Tests …………………………..
Borehole Flowmeter Tests …………………………….
Surficial Aquifer………………………………………….
Regional Flow Trend………………………………….
Water Table Contours……………………………….
Conductivity Analysis………………………………
Kirkham Auger HoleTest……………………
Bouwer Rice Test……………………………..
Precipitation………………………………………………
5. GROUNDWATER FLOW MODEL………………………….

Description of the MODFLOW model…………….
Mathematical Theory
Design of the flow model………………………
The conceptual model
Grid geometry……………………………………..
Hydrologic Parameters…………………………….
Boundary Conditions ……………………………..
2
Sources and Sinks ………………………………..
Calibration……………………………………………….
Sensitivity Analysis………………………………………
Leakance……………………………………………
Conductivities………………………………………
Ditch Specifications………………………………..
Water Budget Analysis…………………………………..
6. CONCLUSIONS……………………………………………
REFERENCES CITED………………………………………….
APPENDICES……………………………………………………….
I: Cooper-Jacob Straightline Plots
II: Pressure Transducer Tests
III: Hydraulic Head Contour Plots
IV: Bouwer Rice Plots
3
CHAPTER 1
INTRODUCTION
Phosphate mining in Florida is currently one of the state’s largest industries, and
produces approximately 40 million tons of material per year (Miller and Sutcliffe, 1984).
Estimates from previous studies indicate that 335 million tons of phosphatic waste have
been stockpiled in above-ground formations called “Phosphogypsum Stacks” (defined as
such by the source and product of their existence). Gypsum and silicon hexafluoride make
up the slimy waste that is pumped out to large evaporite ponds, where the former is
allowed to precipitate. Over time, accumulation at the bottom of the pond is dug out and
piled on the embankments of the pond. This practice is intended to strengthen the walls of
the pond, as it grows in size and elevation. Approximately eighteen such industrial
facilities are located in the Tampa area, with an average area of 227 acres and a range of
heights between 30 and 140 feet.
As the stockpile of gypsum stacks grow to a projected billion-plus tons by the year
2000 (May and Sweeney, 1983), the high concentrations of radionuclides, acid, fluoride,
phosphate, and sulfate become an increasingly problematic characteristic of this
resource, with the potential for groundwater pollution.
The primary focus of this study was to investigate the hydrologic controls of the
phosphogypsum stack, and to provide a model of groundwater flux upon which a future
transport and geochemical model can determine the migration and fate of possible
contaminant leachate plumes and to delineate the physical and chemical processes
involved. As to the more particular objectives of the hydrological part of the research
4
they amount to a quantification of the vertical and horizontal flow rates in the
phosphogypsum stack and the surficial aquifer, respectively, as well as to a
determination of the hydraulic impact of the phosphogypsum stack on the surficial
aquifer.
5
CHAPTER 2
ENVIRONMENTAL SETTING
Geography
The Piney Point Phosphates facility, located along the coast of western Florida,
lies approximately 30 kilometers south of downtown Tampa in Manatee County, along
Florida route 41 (figure 1). The study area is a rural setting with cattle ranches, citrus
groves, and vegetable farms making up a majority of the businesses close by.
Topographically, the area is relatively flat with drainage flowing either to the Manatee
River in the North, McMullen Creek in the South, or to the Gulf of Mexico in the West
(figure 2). The Piney Point Phosphates complex is at an elevation of 3 - 8 m. above mean
sea level, and is about two kilometers from the shoreline of the Gulf of Mexico.
The climate of the research area is subtropical. Convective thunderstorms
dominate the rainy weather of the summer months, while winter and spring are fairly dry.
Consequently, irrigation demands on the groundwater reach a peak from March through
May.
This particular site, although presently inactive, is an ideal location for studying
fluid migration from phosphogypsum stacks, owing to the fact that local groundwater
movement is toward the Gulf of Mexico and away from any large population in the area.
Major lithologies of stratigraphic units in the area define three distinct groups of
formations (figure 3). Each groups bears significance as a water producing unit with
respective hydrologic importance to its defining lithology. Although heterogeneous
6
Figure 1. Location of Research Area on Florida State map
7
GULF
of
MEXICO
ne
eli
or
Sh
20
5
10 30
25
15 20
35
25
10
30
35
5
10 30
35
25
5
10 20
15
LEGEND SCALE
Piney Point Complex
Waterways 0 1 2 km.
Roads
Figure 2. Topographical map of Research Area. Data has been taken

from USGS 7.5 -minute maps using 5 foot contour intervals.
8
characterization of lithologies within each group exist (table 1), generalization of the
groups’ defining units will be the limit to which the investigation is concerned.
The base of the stratigraphic column (figure 3) is made up of the Suwanee, Ocala,
and Avon Park Limestones. Together, these formations comprise a 150 - 250 m thick
limestone unit which is commonly referred to as the Floridian Aquifer. Boundaries of this
limestone group are defined beneath by a carbonate unit containing intergranular
evaporites, and above by another carbonate unit with higher percentages of clays (Miller
and Sutcliffe, 1984).
Overlying the Floridian Aquifer are alternating sandy limestone and clay layers.
This alternation of layers is classified as a second lithological group, and is composed of
the Tampa and Hawthorn Formations. Although this intermediate group can be used as a
source of water, it is primarily made of various clays. The upper confine of the unit is
delineated by a phosphatic clay, known as the Bone Valley Formation. It is used as the
ore for the phosphate industry in the area and has been called “one of the world’s most
important sources of phosphate” (Miller and Sutcliffe, 1984). Thickness of the
intermediate unit is from 75 - 125 m , with the phosphatic clay composing the upper 10 -
20 m.
At the surface, a 10-20 m thick unit of undifferentiated sands and clays is
classified as the third lithological group of this section of the stratigraphy. It consists
primarily of surficial sands with occasional clay lenses, and is lithologically distinct from
the other two units.
9
Figure 3. Stratigraphic Cross Section of Regional Geology
A Generalized Lithological Representation of Stratigraphic Units
below Piney Point Phosphates, INC.
10
Table 1. Stratigraphic Framework (Miller and Sutcliffe, 1984)
Stratigraphic General Major Hydrogeologic

System Series Unit Lithology Lithological Unit
Unit
Quaternary Holocene, Surficial Predominantly fine Sand Surficial Aquifer
Pleistocene Sand, terrace sand; interbedded
sand, clay, marl, shell,
phosphorite limestone,
phosphorite
Pliocene Bone Valley Clayey and Pebbly Phosphatic Confining unit
Formation Sand; clay, marl, Clay
shell, phosphatic
Hawthorn Dolomite, sand, Intermediate
Formation clay, and Carbonate Aquifer system
limestone; silty, and Clastic (Includes First
phosphatic and Second
Aquifers)
Miocene Tampa Limestone, sandy,
Limestone phosphatic,
fossiliferous; sand
and clay in lower
part in some areas
Tertiary Oligocene Suwanee Limestone, sandy
Limestone limestone,
fossiliferous
Ocala Limestone, chalky,
Limestone foraminiferal, Carbonate Floridan Aquifer
dolomitic near
bottom
Eocene, Avon Park Limestone and hard
Paleocene limestone brown dolomite
Lake City, Dolomite and Carbonate lower confining
Oldsmar, and chalky limestone, w/ bed of floridan
Cedar Key with intergranular intergranular aquifer
Limestones gypsum and evaporites
anhydrite
11
Hydrogeology
Groundwater in the area is commonly drawn from one of the three available water
producing units described above. Flow within these aquifers is, for the most part, in the
horizontal direction with little leakage between layers. The water table in the unconfined
unit varies with precipitation and evaporation, while underlying units modulate their
potentiometric yields according to changing lateral flow from inland areas of recharge
and local points of discharge. Seasonal highs and lows of the potentiometric surfaces
have been recognized by the U.S. Geological survey (Johnson et. al., 1981) as September
and May, respectively, and are mainly associated with groundwater pumpage for
agricultural irrigation.
Comparison of the potentiometric surfaces in the southeastern United States by
Johnston et.al. (1980,1981) before and after development has shown a regional trend in
the vertical flow between aquifer units. Following extensive development of the area in
the late 1970’s, Polk County to the East had become an area of recharge whereas the
coastal area along Tampa Bay had become a zone of discharge to the Gulf of Mexico.
This trend dictates a downward flow to the Floridan Aquifer in the area of recharge, and
an upward flow in the area of discharge. Because the Piney Point facility is in the area of
discharge, there exists an upward flow gradient in the water-bearing units through their
confining beds.
Locally, groundwater is drawn primarily from the Floridan Aquifer, although the
surficial and intermediate aquifers are equally important to some. The surficial unit is
used for domestic lawn irrigation, while the intermediate aquifer system is tapped for use
as a rural domestic source of water and for agricultural irrigation. Additionally, the
12
Floridan aquifer south of the Piney Point facility contains mineralized water, and
promotes the intermediate aquifer as the primary source for municipal water.
In the studies of Miller and Sutcliffe (1982) and Miller and Sutcliffe (1984) the
aquifer system around the Piney Point complex was probed for the first time in more
detail. About forty test holes (wells) whose depths extended from the surficial,
unconfined aquifer to the intermediate, confined (artesian) aquifer were drilled around the
ponds and the gypsum stack during this study. A few older, mostly abandoned irrigation
wells that extend further down into the confined Floridan aquifer were also monitored.
Various geophysical well-logging techniques were applied in some of the boreholes to
determine the lithology of the aquifer substratum. Groundwater table elevations were
taken data during the time and three wells were monitored continuously by means of
recorders. The hydrographs for the three continuously monitored wells show sporadic
evidence of an upward hydraulic head gradient between the intermediate and the surficial
aquifer. This has been taken as evidence that potential surface contamination cannot leak
into the lower intermediate aquifer. However, during the dry season (April to June), when
the intermediate aquifer is heavily pumped for agricultural irrigation, the situation may be
reversed and a downward gradient is observed. The water elevation data shows also a
topographic mounding effect of the gypsum stack on the groundwater-level in the
surficial aquifer.
The Piney Point Phosphate Inc.'s quarterly reports of the groundwater monitoring
survey around the phosphogypsum stack to the Florida Department of Environmental
Protection (FDEP) provide some evidence of the direction of the regional groundwater
flow in the vicinity of the stack. As part of the proposed extension of the phosphogypsum
13
stack to its present-day size, Gerathy & Miller Inc. was consulted by the Piney Point Inc.
to install 7 monitor wells extending into the surficial aquifer on the premises of the
company. Most of these monitor wells are still in use today and are being sampled on a
regular basis. Figures 4 and 5 show the piezometric isolines for two particular dates and
Figure 6 illustrates the hydraulic head surface for one of these dates in 3D form. One can
observe from these figures that the groundwater flow is mainly in northwestern direction.
Moreover, the flow system in the surficial aquifer appears to be very much in steady-
state, as witnessed by the similarity of the isoline contours taken two years.
As for the hydrogeology in the phosphogypsum stack itself, only the geotechnical
study of the slope stability carried out by Oaks Geotechnical Inc. (1980) as part of the
proposed extension of the gypsum stack to its present-day size provides some
rudimentary clues about the water flow in the stack. During this study several boreholes
were drilled into the flanks of the stack and water-table levels were monitored over a
period of several months. Because the exact well construction data has not been reported
precise inferences on the stack-flow cannot be made.
14
Surface Contours: Piney Point
11-4-91
ad
ailro
6.00 R
e
Lin
ast
Co
ard
o
ab
Se
5.00
4.00
Chemical
Plant
MW-3
3.00
MW-4
Gypsum Stack
MW-6
Cooling
2.00
WC-1
WC-3
Ponds WC-2
MW-7
1.00 Buckeye Road

MW-1
MW-2
MW-5
0.00 1.00 2.00 3.00 4.00 5.00 6.00
Figure 4. Contour Plot of the Piezometric Heads in the Surficial Aquifer

on November 4, 1991. (contour levels are in ft)
15
Surface Contours: Piney Point
9-23-93
ad
a ilro
6.00 eR
L in
st
C oa
d
ar
a bo
Se
5.00
4.00
Chemical
Plant
MW-3
3.00
MW-4
Gypsum Stack
MW-6
Cooling
2.00
WC-1
WC-3
Ponds WC-2
MW-7
1.00 Buckeye Road

MW-1
MW-2
MW-5
0.00 1.00 2.00 3.00 4.00 5.00 6.00
Figure 5. Contour Plot of the Piezometric heads in the Surficial Aquifer

on September 23, 1993. (contour levels are in ft)
16
3-D Views of Hydrological Head
9-23-93
Figure 6. 3D Plot of the Piezometric heads in the Surficial Aquifer on

September 23, 1993.
17
CHAPTER 3
METHODS OF DATA ANALYSIS
Compilation of the data as well as computation for the analyses was conducted in
spreadsheet format using Microsoft Excel. Representation of this data as graphs, in
addition to a regression for the topographical analysis were done in Axum 5.0.
Modification of some figures was accomplished through use of Microsoft Paint, and
Hijaak Pro.
Phosphogypsum Stack
Identification of hydrologic flow within the phosphogypsum pile itself was carried
out through a series of investigations centered around quantifying the hydrologic
parameters of the stack material, and identifying vertical gradients between stratigraphic
layers. Ten partially screened wells and one fully screened well were drilled into the
oldest portion of the stack. The wells were set at various depths (Table 2) in two clusters
of four wells and one cluster of three. Cluster one (PP1) in the west wall and cluster three
(PP3) in the center of the stack along an old working road wall had four wells, while
cluster two (PP2) in the south wall only had three wells (figure 7). The gypsum-aquifer
interface (base of the stack) is at a depth of 20.8 m from the surface, so there is only one
well which taps the surficial aquifer through the gypsum stack
18
Figure 7 - Locations of Monitoring Wells at
Piney Point Phosphates, Inc. Palmetto, Florida
0
82 32’
ad N
il ro
e Ra
t Lin
as
Co Legend
d
ar
a bo PG Stack Wells USGS Wells
Se Research Wells Monitor Wells
(AMAX)
R2 Old Piezometers
39
Surface Sample Site
Lake Rainfall Sample Site
24
27
O
23 22 38 9 37
38’ 36
R1
CHEMICAL S2
17 PLANT 21 DIAMMONIUM
PHOSPHATE
New Phosphogypsum
19 14 Ponds 34
18 3 POND
3 20
8 4A 16 15 10
Old
6a Phosphogypsum
15 23
13 Ponds
Cooling
13
11
K J
T S1
110
7
Ponds
U 12 9 8 1
Buckeye Road 11 10 Scale (meters)
9, 10, 11
41 2 0 300 600
5
19
Table 2 - Depths of Sampling Wells Drilled into the Stack
Total Well Depth Cased Screened

Cluster # - Well # (in m. from top of Section Section
riser) (m. depth) (m. depth)
1 - 1 18.0 0 - 14.8 14.8 - 18
1 - 2 14.8 0 - 12.5 12.5 - 14.8
1 - 3 12.5 0 - 9.5 9.5 - 12.5
1 - 4 9.5 0 - 6.6 6.6 - 9.5
2 - 0 23.6 0 - 22.0 22.0 - 23.6
2 - 1 18.0 0 - 14.8 14.8 - 18.0
2 - 2 14.8 0 - 12.5 12.5 - 14.8
2 - 3 11.5 0 - 8.2 8.2 - 11.5
3 - 1 18.0 none 0 - 18.0
3 - 2 14.8 0 - 12.5 12.5 - 14.8
3 - 3 11.5 0 - 8.2 8.2 - 11.5
All wells were constructed with a 10 cm. diameter PVC pipe. Screens were
packed in 20-30 mesh sand with approximately 50 cm of bentonite hole plug overlying
the sand pack except for the PP 2-0 well which has a 2m thick bentonite plug over the
sand pack. The risers were grouted to the surface with a bentonite-cement mixed grout
compound. For the fully screened well PP 3-0 grout-plugs were set at intervals of 1.5m,
in order to reduce the possibility of vertical outer-borehole flow which could corrupt the
borehole flowmeter tests.
Quantification of hydrologic parameters within the stack was determined by one
of the most commonly used non-equilibrium pump tests, the Cooper-Jacob (straight-line)
method. This method was used over the more popular Theis-curve match for its
asymptotic approximation of the well function for a small radius and long times, because
20
it is important to rule out the bias of values representative of the region directly around
the well. A Grundfos 1.2-amp pump was used to pump water out of the well at an
approximate rate of 6 L/min., and head measurements were taken with an electrical head
level indicator.
Hydraulic gradients within the stack were determined by using a pressure
transducer, a new electromagnetic borehole flowmeter (Molz et al., 1994) , and through a
comparison of hydraulic head values. Due to the significance of a hydrologic gradient for
the understanding of the flow system in the stack, the use of these different methods
should increase the reliability of the results obtained.
In situ vertical head measurements were made using a set of inflatable packers
bought from the Tennessee Valley Authority, and a 20 psi pressure transducer from Telog
Instruments, INC. Inflation of the packers above and below the pressure transducer
allowed a section of the well to be isolated, and a reading to be taken. Measurements of
the in situ pressure were taken at all screened intervals possible, along with 3 - 5 cased
intervals (to provide a standard hydrostatic gradient upon which to compare the screened
readings). Variations of anomalous readings in the screened sections were correlated with
the presence of a pressure perturbation (i.e., a flow gradient).
Borehole flowmeter tests were conducted by Quantum Engineering Corporation
using the deepest well of each stack cluster. Ambient flow, induced flow, and pump test
measurements were conducted at all wells; however, a complete analysis was only done
for well 1-1. Results for wells 2-1 and 3-1 were incomplete, owing to the onset of a
thunderstorm the day that the measurements were taken. Results from this testing have
provided data for ambient flow direction and magnitude, as well as response of various
21
vertical sections of the stack to induced flow conditions. Utilization of these induced flow
rates with the measurements for net flow can also be used
Hydraulic head measurements for the monitoring wells on the stack were taken
approximately every three months. Because wells in the same cluster were fairly close
together, comparison of the head measurements were used to indicate possible variations
of head gradients in the vertical direction within the stack. Organization of the data as a
cross-sectional view provided information on internal stack-stratification.
Surficial Aquifer
Analysis of the hydrology in the surficial aquifer includes calculations of
hydraulic conductivities and transmissivities, a contour analysis of monitoring well head
levels, and regional flow gradients in the surficial aquifer. Primary interest of this
research was to quantify horizontal flow rates in the surficial aquifer, as well as to
establish the direction of flow in an attempt to determine the hydraulic impact of the
phosphogypsum stack on the surficial aquifer.
Hydraulic conductivity analyses were conducted by two different analytical
methods, allowing for respective well geometries that were available. USGS well #9
(figure 7) was treated as an auger hole, while all other research wells were drilled to be
partially screened for their lowest 10 feet.
The hydraulic conductivity for the auger hole was calculated according to a
method prescribed by Boast and Kirkham (1971). The well was pumped out by a Grunfos
machine, and the water table (i.e. head) allowed to rebound over the next hour.
22
Measurements of the rebounding head elevation were taken with a conductive measuring
tape, and entered into in a spreadsheet calculation program.
The analysis for the partially penetrating monitor wells was conducted on
proprietary wells 1 and 8, and research wells 11, 18, 21, 22, and 24, using a method
described by Bouwer and Rice (1976). A volume of approximately 200 liters was pumped
out of each well using a Grunfos machine, and then the well was allowed to recharge. As
the hydraulic head rebounded, elevation measurements were taken and imported into a
spreadsheet program.
The contours of the water table on site were compiled every three months using
hydraulic head elevations taken from the following wells : proprietary wells 1 - 5, 8-11,
research wells 8 - 24, U.S.G.S. wells 8, 9, 34, 36, 37, 39, and stack well 2 - 0. Data files
were entered into the Surfer program, and contours generated using the Kriging method.
Because of the importance of the head measurement at well 2-0 (which wasn’t drilled
until March 1996), only contours for months that include measurements at this well are
presented.
The regional flow of the surficial aquifer is partly controlled by the confining unit
beneath it, and its direction and gradient was estimated through an assumption of a
consistent surficial aquifer thickness. Because of a lack of monitor wells further away
from the phosphogypsum stack that would have allowed to properly define the
groundwater gradient the standard assumption was made that the regional flow in the
surficial aquifer is primarily determined by the topographic slope of the land surface. To
determine the latter a three-dimensional regression of the drainage basin using an
equidistant node grid of elevations was made, leading to a first-order representation of the
23
regional flow without the mounding effect of the phosphogypsum stack.. Calculations of
the topographic plane were made in the AXUM graphing program using a collection of
data points taken from topographical maps of the area (figure 3). The transects for the
data point collection were made at a one unit interval (representing 200 m.) of plotted
data in an AutoCAD drawing.
The precipitation for the area was measured daily at stations on site, and at the
U.S.G.S. stations in Ruskin (10 miles to the north), and Bradenton (5 miles to the south).
These data were compared to monitoring well heads and stack pond levels in hydrograph
format. In addition, these hydrographs were analyzed for temporal and spatial relevance
to the possible recharge of the aquifer and the phosphogypsum stack..
24
CHAPTER 4
CHARACTERIZATION OF THE HYDROLOGICAL ENVIRONMENT
This chapter presents the results of the hydrologic characterization of the gypsum
stack and the underlying surficial aquifer, including an analysis of the regional
precipitation data. These characterizations are necessary for the parameter adjustments of
the groundwater model presented in the following chapter. Data are presented in
Appendices I, II, and III.
Stack Analysis
Analysis of Hydraulic Heads
Hydraulic head measurements for all three well clusters demonstrate a downward
flow in all instances. Specific gradients between stratigraphic layers of the gypsum stack
can be made for each of the well regions, as well as a determination of the flow gradient
to the surficial aquifer. Patterns of relative head do not change over time, but can be
correlated to the precipitation record (presented at the end of this chapter).
Well cluster 1 (figure 8) shows a typical illustration of gradualized downward
flow. The occurrence of a slight plateau between wells 1-2 and 1-3 points to a region of
slower flow when compared to the neighboring head gradients to wells 1-1 and 1-4.
Well cluster 3 (figure 9) illustrates flow toward the screening depth of well 3-2,
which is conceptually consistent with well cluster 1, because even though well 3-1 is the
deepest of the three wells, it is fully screened. Thus, head measurements are responding
25
1-1 1-2 1-3 1-4
25.0
Hydraulic Head Elevation (m ASL)
22.5
20.0
17.5
15.0
12.5
7 / 18 / 95
11 / 15 / 95
10.0
2 / 9 / 96
3 / 25 / 96
7.5 5 / 6 / 96
9 / 19 / 96
5.0
2.5
Gypsum / Aquifer Interface
0.0
0 2 4 6 8 10 12 14
Distance (m)
Figure 8. Hydraulic Head Comparison for Well Cluster 1. A general

downward gradient is found in consecutively deeper wells.
26
3-1 3-2 3-3
25.0
22.5
Hydraulic Head Elevation (m MSL)
20.0
17.5
15.0
12.5
10.0
7.5 7 / 18 / 95
11 / 15 / 95
2 / 9 / 96
5.0 3 / 25 / 96
5 / 6 / 96
Gypsum / Aquifer Interface 5 / 26 / 96
2.5 9 / 19 / 96
0.0
0 1 2 3 4 5 6 7 8 9 10 11
Distance (m)
Figure 9. Hydraulic Head Comparison for Well Cluster 3. A

downward gradient is found toward well 3-2, which represents a head
level for the deepest section of screening in the gypsum stack.
according to their highest screened elevations and force downward flow gradients
between all wells.
27
Well cluster 2 (figure 10) is of particular significance due to well 2-0, which is
drilled into the surficial aquifer. Gradients between all wells are still downward, which
also includes down into the surficial aquifer. The presence of a gradient toward well 2-0
provides one of the most critical factors needed for a distinction of flow into the surficial
aquifer; however, the relative magnitude of the actual gradient and of the hydraulic
conductivity will determine the flow velocity and the fluxes of stack water that can seep
into the surficial aquifer. A comparison to surficial aquifer head levels, as well as
quantitative modeling of flow rates, will provide a clearer picture of the factors
controlling the hydrological environment here.
Cooper-Jacob Straight-line Method
Transmissivity and storativity values were determined through a modification of
the Cooper-Jacob equation. The latter represents an asymptotic solution for large times t
of the Theis equation which describes the radially symmetric, non-equilibrium head-
drawdown s(r,t) in a confined aquifer as a function of the radius (distance) r and time t
under the influence of pumping. The Cooper-Jacob equation is then (Driscoll, 1986):
Q
s( r , t ) = ⋅ ( −0.57772 − ln u ) (4.1a)
4π T
28
2-0 2-1 2-2 2-3
25.0
22.5
Hydraulic Head Elevation (m MSL)
20.0
17.5
15.0
12.5
10.0
7.5 7 / 18 / 95
11 / 15 / 95
2 / 9 / 96
5.0 3 / 25 / 96
5 / 6 / 96
Gypsum / Aquifer Interface 5 / 26 / 96
2.5 9 / 19 / 96
0.0
0 1 2 3 4 5 6 7 8 9 10
Distance (m)
Figure 10. Hydraulic Head Comparison for Well Cluster 2. A

downward gradient is found into the surficial aquifer represented by
well 2-0.
r2S
By substituting for the expression u = , and converting to log base-10 format one
4Tt
gets the following equation:
2.3Q Tt
s( r , t ) = ⋅ Log ( 2.25 2 ) (4.1b)
4πT r S
29
By obtaining the drawdown s(r,t) observed in one log unit (figures 11 and 12), and a
known value for the pumping rate Q, a value for the transmissivity can be calculated for
the wells that were pumped (i.e. PP1-2, PP2-2, and PP3-1).
The storativity S is determined from the intercept time t_0 which corresponds to a
zero drawdown s=0 (i.e is obtained by setting the log-term equal to one). The intercept
time t_0 is depicted graphically from the intercept of the straight line tangent to the
Table 3. Transmissivity and Storativity Values for Stack Wells
Well Designation Transmissivity Storativity

(m2/day)
1-1 16.163 0.00009143
1-2 6.883 -
1-3 47.638 0.00001568
1-4 90.512 0.00008784
2-1 2.526 0.00006698
2-2 0.846 -
3-1 0.445 -
3-2 10.842 0.00001706
3-3 32.526 0.000008922
30
4
6
Hydraulic Head (m)
10
11
12
10-1 2 3 4 5 6 100 2 3 4 5 6 101 2 3 4 5 6 102 2 3 4
Time (min)
Figure 11. Pump Drawdown vs Time in Stack Well 2-1. Of particular

note is the recharge that occurs in the data between 50 and 80 minutes
of pumping
31
5.0
5.2
5.4
5.6
Hydraulic Head (m)
5.8
6.0
6.2
6.4
6.6
6.8
2 3 4 5 6 100 2 3 4 5 6 101 2 3 4 5 6 102 2 3 4
Time (min)
Figure 12. Pump Drawdown vs Time in Stack Well 2-2. Of particular

note is the recharge that occurs in the data between 65 and 90 minutes
of pumping.
32
drawdown curve with the horizontal axis. Values for the storativity S cannot be
determined for the wells that were pumped, since there is a singularity in the solution for r
=0.
Even though transmissivity values for only three of the stack wells were obtained
(Table 3), the wide range found indicates a variation of the transmissivity throughout the
stack. This variation may be caused by modification of the stack structure during
structural maintenance of the stack, whereby gypsum material from the pond is dug out to
strengthen the confining walls. The transmissivity value for well 3-1 is the best
representation of conductivity for the stack as an entire unit (owing to the well’s
representative screened length), while the values for wells 1-2 and 2-2 are more indicative
of particular horizons within the stack.
Storativity values are well constrained, with all values falling within one log unit.
An average of 4.8 x 10-5 denotes a value comparable to that of natural gypsum,
indicating that the waste material maintains storage properties similar to that of its
chemically related compound.
Although drawdown curves for most of the analyses are typical of a normal
aquifer response, wells 2-1 (figure 11) and 2-2 (figure 12) demonstrate a plateau in their
data close to the equilibrium stage of pumping. This occurrence has been classified as an
influence of recharge, resulting from a proximity to the stack pond. Additionally, the
delay observed between the wells is attributed to the recharge occurring closer to the
pump source. On the other hand, the plateau at well 2-2 is less dramatic because it is on
the perimeter of the drawdown influence.
33
Pressure Transducer Tests
Investigation with the pressure transducer was intended to provide an
identification of horizontal flow within the stack interior. Complete analysis of the
pressure at every depth in all three cluster areas was not possible because of the limited
range provided in the screened sections. Regardless of this restriction, anomalous
horizontal flow was identified in three of the wells. Wells 1-3 (figure 13) and 3-
1 (figure 14) illustrate sections of decreased ambient pressure, while well 3-2 (figure
15) demonstrates a single section of increased pressure. All other wells showed no
deviation from the hydrostatic reference pressure, as computed from the density of the
gypsum stack-water solution, indicating no significant vertical variations of the pressure
and the hydraulic heads in those depths. This means that either there is no significant
amount of vertical flow in that depth-section of the stack that would lead to a detectable
amount of vertical pressure head gradient, or the pressure transducer is just not sensitive
enough to pick it up.
The low pressure zone found at well 1-3 is on the west wall indicating the
presence of a vertical flow gradient at depths approximately 10 m below the surface.
Analysis of well 2-1 examines the same interval on the south wall, but does not indicate
flow different from the expected hydrostatic reference. Thus, no support for a conclusive
statement on the stack edges can be made, but the possibility for flow still exists.
Measurements made at well 3-1 were conducted in a different manner, owing to
the fully screened section of the well. Comparison to unpacked pressure readings instead
34
2
4 Well 1-3
Hydrostatic Norm
Depth below Water Table (m)
6
Cased Section
10
Screened Section
12
14
0 2 4 6 8 10 12 14
Pressure (PSI)
Figure 13. Pressure Transducer Measurements for Well 1-3. Deviation

of readings in the screened section (9.5 - 12.5 m.) below the
hydrostatic norm show a regional decrease in ambient pressure.
35
0 Your Text
Your Text
2
Depth below Well Riser (m)
4
Packers are used
Packers are not used
6
10
12
14
16
18
20
0 2 4 6 8 10 12 14 16 18 20 22
Pressure (PSI)

of readings in two sections below the hydrostatic norm (no packers
used) show a regional decrease in ambient pressure.
36
2
4 Well 3-2
Hydrostatic Norm
6
8
Cased Section
10
12
Screened Section
14
16
0 2 4 6 8 10 12 14 16
Pressure (PSI)

of readings in the screened section (12.5 - 15.0 m.) above the
hydrostatic norm show a regional increase in ambient pressure.
of a hydrostatic line allows a broader interpretation of the readings; however, two areas of
pressure anomalies are still apparent. Lower pressures found in the “packed”
measurements from 2 - 8 m. are most likely an influx of fluid flow from the nearby pond,
37
whereas spikes found at depths of 16.5 and 18.0 m. are more of a mystery. This
development is either evidence of poor field methods, or an indication of a flow conduit
The latter would suggest cracks or faulting at the intervals of the spikes, although the
large contrast in pressure would suggest that this explanation is unlikely. Therefore, the
spikes are interpreted as evidence of poor grouting of the well, whereby flow can seep
vertically between the outer side of the borehole casing and the back-fill formation..
The high pressure zone of well 3-2, at an approximate depth of 13 - 15 m is quite
important since it is located in the center of the stack between the north and south ponds.
This reading is an indication of an increase in overburden pressure and is evidence for the
conceptualized flow of a typical groundwater mounding model. Because of the fact that
this anomaly is located close to the low pressure anomaly found in well 3-1, the
measurements do not support a regional characterization of downward flow. Thus,
conflicting evidence from both wells indicates heterogeneity of the gypsum stack at
depth. However, because well cluster PP 3 is located essentially at an old pond
construction road, there is also the possibility that some of the observed anomalies do not
reflect the phosphogypsum formation alone, but also the compacted back-fill material
of the road.
Borehole Flowmeter Tests
The Borehole Flowmeter Tests (cf. Burnett et. al., 1985 for details) yield the
following three major pieces of information:
38
1) Ambient flow in the well under natural conditions. The nature of the ambient flow,
especially its direction, provides clues on anomalous fracture and fault zones and
vertical variations of the hydraulic heads.
2) Flow rates for each vertical section under steady-state pumping conditions.
3) Using the results from 1) and 2) vertical variations of the net flow rate in each of the
probed intervals that are directly proportional to the hydraulic conductivity K in that
vertical aquifer section.
Ambient flow measurements for both well 1-1 (figure 16) and well 3-1 (figure 17)
provide strong support for a natural, downward flow of fluid in the stack. This evidence
enhances the theory for topographical mounding of stack waters on the surficial aquifer,
and clarifies specific internal heterogeneities at particular depths. The ambient
differential readings of well 3-1 illustrate this point; readings fluctuate throughout the
stack. These flow inconsistencies indicate that localized fracturing and/or bedding
planes control flow.
A gradual decrease in the ambient flow is noted for both wells near the stack base,
and is important to qualifying the significance of any topographical mounding. Although
this trend is typical of unconfined units, its utilization in clarifying the permeability of the
surficial aquifer interface is critical. Understanding of flow beneath the interface will
determine whether this decrease is a product of an impermeable boundary, or the result of
an unconfined situation.
39
Figure 16. Borehole Flowmeter Results for Stack Well 1-1. Positive
values denote downward flow and negative values upward flow.
40
Figure 17. Borehole Flowmeter Results for Stack Well 3-1. Positive
values denote downward flow and negative values upward flow.
Induced pumping of the wells was undertaken in an attempt to investigate the
response of the aquifer to such conditions and to quantify possible vertical stratifications
of the hydraulic conductivity within the stack, as might be indicated by the presence of
bedding planes that are clearly visible at the stack. As depicted in well 3-1, changes in
41
increase of the net flow (or 2x net flow) denote a region of varied hydraulic conductivity.
This finding gives strength to a theory of the stack as a layered hydraulic structure, with
varying conductivities in different layers. Absolute values for these conductivities could
be calculated from a more complete set of values determined by the Cooper-Jacob Test,
along with the specific thicknesses of various identifying layers. However, this task has
not been carried out here since layered stack conductivities will not be required as an
input parameter in numerical mounding model to be presented in the next chapter .
Surficial Aquifer
Regional Flow Trend
The regression plot of topographical data (figure 18) taken from figure 3 denote a
flow gradient of 1.977 x 10-3 at an azimuthal direction of 303.19 0 . This gradient is at
such a low angle that localized influence of the water table will be a large factor on the
direction and speed of flow. Thus, these results may not represent small-scale flow
patterns and gradients for the area, but they do give the best approximation for a
generalized regional flow pattern. In addition, topography around the gypsum stack
complex is relatively flat, so that the resulting gradient from this calculation is still a good
representation of ambient conditions.
42
z = 21.619485 + 0.001655*x -0.001083*y
Figure 18. A 3-Dimensional Regression Plot of Topographic Data. The

above equation represents the trending plane in units of meters,
although the slope and direction of the plane is determined by the x
and y coefficients, which do not change. Resulting slope and
direction of the regression plane are approximated as regional flow
characteristics of the surficial aquifer, due to a consistent thickness of
the unconfined layer.
43
Water Table Contours
Contours of hydraulic heads for surficial aquifer monitoring wells are greatly
impacted with the addition of well 2-0. Thus, accurate representation of the water table in
the unconfined zone cannot be made without inclusion of a measurement taken at this
well. Contours for measurements taken on May 6, 1996 (figure 19) and November 8,
1996 (figure 20) are typical of other data sets analyzed, and represent the extent of values
found in the calculation of the water table for the surficial aquifer. Additional contours
drawn from measurements at other sampling dates are depicted in appendix III.
Most significant of the contouring plots is the influence of the head-reading taken
at well 2-0. The gradient between its location and other monitoring wells, namely,
wells MW 1, RW 8, 11, 18, 21, 22, & 24 is indicative of a flow in the vertical
direction, as well as a flow away from the gypsum stack in almost all horizontal
directions; though flow to the southeast is hindered due to the opposing force of regional
flow. A water table low in the southwest quadrant may be the result of the cooling pond
and the ditch system in that area. Presence of the ditches draws water flowing toward
them to be evaporated and essentially taken out of aquifer system. Thus, the
existence of the evaporating system leads to a lowering of the local water table.
Conductivity Analysis
Kirkham Auger Hole Test
Hydraulic conductivity of the well designated as USGS 9 was determined
following the so-called auger hole method described by Boast and Kirkham (1971) and
44
2250
2000
1750
North - South (m)
1500
1250
1000
750
500
250
0
0 250 500 750 1000 1250 1500 1750 2000 2250 2500 2750
East - West (m)
Figure 19. Contour Plot of the Surficial Aquifer on May 6, 1996.

Asterisks represent well measurements upon which the contour is
based. Noteworthy characteristics of the map include a large head
value at well 2-0 and regional low in the southwest quadrant.
45
2250
2000
1750
North - South (m)
1500
1250
1000
750
500
250
0
0 250 500 750 1000 1250 1500 1750 2000 2250 2500 2750
East - West (m)
Figure 20. Contour Plot of the Surficial Aquifer for

September 19, 1996. Asterisks represent well measurements upon
which the contour is based. Noteworthy characteristics of the map
include a large head value at well 2-0 and a regional low in the
southwest quadrant.
Amoozegar and Warrick (1986). This calculation dictates a relationship between the
drawdown (y), time (t), and hydraulic conductivity (K) in the following equation :
46
K = {π r 2 / [C ( ti +1 − ti )]} ln( yi / yi +1 ) (4.2)
The hydraulic conductivity is in units of cm/sec, and is compared to known ranges of
unconsolidated material (Bear, 1979). C is a shape factor that is commonly referred to as
a constant of the equation. Three variables are used to calculate the value of C/r in
equation 4.2 :
(1)- the ratio of the cavity height to the well radius,
(2)- the ratio of the cased well section to the well radius, and
(3)- the ratio of the impermeable layer depth beneath the cavity to the well radius.
Although the geometry of USGS 9 does not allow the determination of a constant
from known values (Youngs, 1968), a log base E curve-fit of these values (figure 21) was
able to obtain a viable solution for many ratios of the cavity height to the well radius
hc/r. Based on the most likely geometry of the well, the “hc/r=0” curve was selected as
the most reliable one. Using this type-curve a hydraulic conductivity in the range of
0.00075 - 0.00190 cm./sec. was determined, which is in the range of two geomorphic
classifications : clean sand ( 1 - 10-4) and silty sand (10-1 -10-5).
47
35
hc / r Ratio
0
.5
30 1
2
4
34.16 - 2.417*ln x 8
25
Constant C/r
20
22.94 - 1.443*ln x
15
15.96 - 0.749*ln x
12.22 - 0.5549*ln x
10
10.1 - 0.4792*ln x
5.976 - 0.1349*ln x
5
0
0 10 20 30 40 50 60 70 80 90
H/r Ratio
Figure 21. Determination of Shape Factor C/r by a Natural log

Curve-fit. Approximation of the shape factor for large H/r values was
needed in calculating the conductivity for USGS well #9.
Bouwer Rice Test
Procedure for the pump analysis of wells 2-0, MW 1, RW 8, 11, 18, 21,
22, & 24 followed a “slug” recovery method, developed by H. Bouwer and R.C. Rice
48
(1976) This procedure takes into account the partially screened nature of many
monitoring wells (figure 22) in the calculation of hydraulic conductivity, and allows a
spatial analysis of conductivities around the site.
The Bouwer / Rice theory is based upon a modification of the Thiem equation to :
y
Q = 2π K L ( 4.3)
ln( Re / R w )
where Q is the volume of water flowing into a well at a specific depth y, K is the
hydraulic conductivity, L is the length of the screened section, and Re/Rw is a ratio of the
effective radius of the pumping influence over the effective radius of the well (including
the grouted radius). The rate of water level rise (dy/dt) can be represented as :
2
dy dt = − Q π rc ( 4.4 )
where rc is the radius of the cased well section. Insertion of equation 4.4 into 4.3,
followed by integration will produce :
2 KLt
ln y = − + constant ( 4.5 )
rc 2 ln( Re Rw )
Applying this solution for limits yo and yt where t = 0 to t while solving for K yield the
finalized equation that was used :
2
r ln( Re Rw ) ln ( y 0 y t )
K= c (4.6 )
2 Lt
49
Figure 22. Generalized Well Geometry of a Partially Screened Well.
Note values for H,L, and D.
Although most parameters are easily determined in the calculation, ln (Re/Rw) is
somewhat variable within various geologic environments. More specifically, the effective
50
radius of influence will vary in relation to the depth of the underlying confining unit
below the bottom of the well. Bouwer and Rice (1976) determined that ln (Re/Rw) varies
inversely with ln [H / Rw] and linearly with ln [(D-H)/ Rw]. Results enabled derivation of
the following two equations: eq. 4.6 for partially penetrating wells and eq (4.7) for
completely penetrating wells (where D-H = 0).
L 11. + A + B ln b D − H g / R OP
ln R R = M
w
−1
e
MN ln H R
w
w L R PQ
w
(4.6 )
ln R R = M
L 1.1 + C OP −1
e
N ln H R L R Q
w
w w
(4.7 )
Coefficients A, B, and C from equations 4.6 & 4.7 are resolved by a relationship that has
been determined through an electrical node analysis (figure 23) presented in Bouwer and
Rice (1976).
In addition to the determination of the value for ln (Re/Rw), hydraulic head values
were graphed against time in a log plot (figure 24) (additional graphs are depicted in the
appendix IV). The resulting slope of the line determined an average value for ln(yo/yt)/t to
be used in the calculation of the hydraulic conductivity.
Results for the hydraulic conductivities determined by this method (Table 4)
characterize three zones of regional conductivity. Well 2-0 represents an area of a low
conductivity (1.3 x 10-5 cm/sec) for the region beneath the stacks, while higher
conductivities (mean ~ 3.9 x10 -4 cm / sec) are found in wells to the Northwest (RW 18,
51
Figure 23. Relationships of A, B, & C for the Calculation of Re/Rw.
Using the formulas from the Bouwer/ Rice method, a range of
possible conductivities were determined for the pump analyses.
52
4
3
1.0008
6
5
5
Drawdown (m)
4
3
0.1009
7
6
5
4
3
0.010
8
0 240 480 720 960 1200 1440 1680 1920 2160 2400
Time (sec)
Figure 24. Drawdown vs. Time Plot for Well 18. The slope of the dashed
line above is used in the calculation of conductivity as the value for
log (yo/yt)/t.
21, 22, 24). Southward of the stack (MW 1, USGS 9, RW 8 & 11) moderate values for
-4
conductivities are found (mean ~ 1.3 x 10 cm/sec). A comparison of the
conductivities for the wells in the south to those in the northwest shows that the highest
53
conductivities are determined for RW 18 & 24, where values are 3 - 4 times higher than
the mean for the more southern wells. This is peculiar in relation to the wells’ proximity
to the influence of the stack, but the difference can be attributed to variations in the local
geologic composition of the surficial aquifer.
Table 4. Conductivity Ranges for Surficial Aquifer Wells. Units for all values are in
cm./sec, with maximum and minimum values approximated from individual
slopes between head values in the drawdown plots.
Well Mean Minimum Maximum

PP 2- 0 0.0000131 0.0000093 0.0000136
MW 1 0.0001290 0.0000900 0.0001620
MW 8 0.0000710 0.0000360 0.0001690
USGS 9 0.0001480 0.0001330 0.0002290
MW 11 0.0001700 0.0001100 0.0003480
MW 18 0.0006130 0.0002100 0.0007690
MW 21 0.0002440 0.0001700 0.0003090
MW 22 0.0002590 0.0001130 0.0003180
MW 24 0.0004370 0.0002770 0.0006960
Precipitation
Precipitation records from all three available sources indicated that each was
unique in its measurements, and that not all of the sources could be relied upon in
correlation with the hydrologic system in the stack area. Thus, records from on-site
measurements for 1995-1996 were relied upon in the correlation to precipitation, while
readings from Bradenton and Ruskin were not considered.
54
Precipitation measurements showed a high degree of correlation to stack pond
levels (figure 25) and monitor well levels (figure 26). Therefore, hydrologic controls of
these water bodies were considered to be at relative equilibrium with their environment.
Water-table levels of the stack pond were shown to be very small on a monthly scale and
found to impact ambient levels only during large precipitation events, as depicted in the
records for October of 1994. Water-table elevations in monitoring wells are seen to
recover within weeks, owing to the high conductivity of the sandy composition in the
surficial aquifer.
Annual precipitation for 1995 was 159.2 cm. with the highest monthly records in
July and August, and the lowest in the months of December and January. Precipitation
highs and lows are attributable to seasonal variations, with large annual numbers due to
the area’s latitude and proximity to the Gulf of Mexico. Annual totals are minimally
variable from year to year, and consistent in their pattern of distribution each month.
In summary, precipitation has been highly variable spatially over the area but
similar in annual totals. This will, of course, lead to localized variations of the recharge
flux into the hydrologic environment (i.e. the gypsum stack and the surficial aquifer) from
day to day, but should even out when considered on a regional scale over longer periods
of time. Large precipitation events will impact hydraulic head levels in the stack ponds
for months, while influences on the surficial aquifer are found to only last weeks.
55
Old North
Old South 62
New North
18 New South 79
61
16
60
78
14
59
New Pond Elevation (feet)

Old Pond Elevation (feet)
12
58
Precipitation (in)
77
10
57
8 76
56
6
55
75
4
54
2
74 53
0
1-9
2-9
3-9
4-9
5-9
6-9
7-9
8-9
9-9
10
11
12
1-9
2-9
3-9
4-9
5-9
6-9
7-9
8-9
-94
-94
-94
4
4
4
4
4
5
5
5
5
5
5
Date (monthly total)
Figure 25. Comparison of Precipitation Records to Stack Pond

Elevations. Correlation between the records is important for
October of 1994.
56
10 4
8 3
Head Level (ft)
Precipitation (in.)
7
6 2
1 MW11
4 MW10
MW9
RW 13
3 MW3
RW 15
RW 16
0 MW4
RW 17
2-
3-
3-
4-
4-
5-
5-
6-
6-
7-
7-
7-
8-
8-
9-
9-
22
22
23
21
18
16
30
13
27
10
24
MW8
Precip.
Date
Figure 26. Comparison of Precipitation Records to Monitor Well

Levels. Correlation between the records is important during mid-
June.
57
CHAPTER 5
GROUNDWATER FLOW MODEL
Description of the MODFLOW model
Groundwater flow at the Piney Point facility was simulated using Processing
Modflow for Windows (1994), a computer-simulation software package (hereinafter
referred to as MODFLOW) that utilizes a three-dimensional, modular finite difference
method, first developed by McDonald and Harbaugh (1988) for the U.S. Geological
Society. This modeling practice makes use of a nodal network, whereby each node
represents a hydraulic head and is modified through adherence to aquifer parameters (i.e.,
hydraulic conductivity and transmissivity ) and environmental constraints (i.e., ditches
and ponds, recharge from precipitation and evaporation ). These simulations may be run
under transient or steady-state conditions; however, only steady-state solutions are
considered here.
Mathematical Theory
Modflow simulates groundwater flow under the assumption of constant fluid
density, and generates head values for each node within its environment by solving the
following partial differential equation (groundwater flow equation) for the hydraulic head
h as a function of space (x,y,z) and time t (cf. Anderson and Woessner, 1992):
∂ ∂x ∂ ∂y ∂ ∂z ∂h
( Kx ) + ( K y ) + ( Kz ) = S s − R (5.1)
∂x ∂ h ∂y ∂ h ∂z ∂ h ∂t
58
where Kx, Ky, and Kz are hydraulic conductivity values in the x, y, and z coordinate
directions, Ss is the specific storage of the geologic unit, h is the hydraulic head, and R is
a generalized sink / source term of external nature to the system (Anderson and
Woessner, 1992).
Eq. (5.1) is used in its steady-state form by setting the dh/dt-term on the right side
to 0. The resulting steady-state groundwater flow equation changes then to the Poisson
equation which is then integrated by a finite-difference method whereby discrete head
values at each node, by using information from neighboring nodes, are iterated through
the equation until the head change between two consecutive iterations is less than a
chosen value. The numerical procedure used for the iteration process was the
Preconditioned Conjugate Gradient method.
Design of the Flow Model
The Conceptual Model
Primary consideration for the design of the conceptual model was to isolate the
stack-surficial aquifer boundary in the environment, so that a determination of the
hydrologic flux between these two units could be made from the simulated hydraulic
conditions.
The model is comprised of two layers that represent the two aquifer units being
studied: The stack and the surficial aquifer (figure 27). The overlying stack layer consists
of two regions of 8 and 15m thicknesses, representing new and old stack accumulations,
59
respectively (figure 28), while the surficial aquifer layer is constructed as a flat-lying bed
of a constant 10 m thickness. Regions of the top layer not representing a gypsum unit are
designed to be insignificant through construction as a very thin unit (1 mm) with high
hydraulic conductivity; thus, any water contained within each unit is drained immediately
into the underlying layer and is of no consequence to any other head values.
Topography of the land surface will vary at the site, but it will have no influence
upon the hydrologic head because this value in an unconfined unit will be impacted more
by elevation of the water table. Thus, the effect of stack control on head levels in the
surficial aquifer are just as easily modeled impacting a topographically flat geologic unit
as a varied one.
Grid geometry
The simulation of the stack environment encompasses an area of 1183.36 hectares
and is organized into 6400 cells on an 80 x 80 unit grid (figure 28) . Each of the unit cells
is in a square configuration with dimensions of 43 m x 43 m, and models an actual land
surface of 1849 m2. Although the gypsum stack represents only 6.1% of the total grid, a
large modeling area was intended so that boundary conditions of the modeled
environment would not have any major effect on head values in the stack region.
60
Figure 27. Vertical Cross-section of the Modeled Environment. Actual
representation of the environment is made with each rectangle
representing a unit cell.
61
Figure 28. Specification of Layer 1 Regions. Pink cells are representative
of values in the old stack, blue cells for values in the new stack, and
green cells for the designation of insignificance in the top layer.
62
Hydrologic Parameters
Values for the hydraulic conductivities in both layers are adjusted so that the
horizontal component is calculated from the horizontal conductivity and thickness values
specified, while the vertical component is modeled in the model over the leakance values
between the stack and the surficial aquifer. The leakance value for the stack is varied in
the range of 1.0 x 10-2 - 1.0 x 10-3 day -1, while the value at the bottom of the surficial
aquifer is specified five orders of magnitude lower, owing to the presence of the
confining Bone Valley formation. Horizontal conductivity in both units were defined
from the results of the aquifer pump tests; essentially, these estimations include the
transmissivity found for well 3-1 (0.443 m2/day) and the average of the conductivities
measured at the north and south monitoring wells (1.3 x10-6 m/s & 3.9 x10 -6 m/s).
Regions of horizontal conductivity are specified in the surficial aquifer (figure 29)
as three different sections: a sub-stack area (7.0 x 10-7 m/s), a northwest high conductivity
-6
zone (3.9 x10 m/s), and a generalized hydraulic conductivity for the remainder of the
modeled cells (1.3 x10-6 m/s). This modification was made to allow for a good match of
the modeled to the observed contoured head data.
Boundary Conditions
Constant head cells are specified in the top layer with initial head measurements of 18 m
and 25 m for the new and old stack regions, respectively (figure 27). The implication of
the constant head acting as a consistent source of water from stack ponds is intended, as
the ponds are kept at relatively constant levels from precipitation recharge.
63
Figure 29. Zones of Hydraulic Conductivity in the Surficial Aquifer.
Consecutively darker colors signify a relatively faster conductivity;
dark blue denotes a conductivity of 4.0x10-5 m/s, light blue a
conductivity of 1.3x10 -5, and light green a conductivity of 7.0x10-6.
64
Constant head cells are also specified at the east and west grid boundaries in
order to simulate regional groundwater flow driven by a constant gradient between these
boundaries. The angle and the slope of the regional head trend (determined from
topographical regression in chapter 4) is generated through an offset of northward
decreasing initial head values of the constant head cells. Initial head values for variable
cells of the surficial aquifer are set to 5 m.
Sources and sinks
Sources of water in the system were generated from the constant head designation
discussed above, while sinks for the system were modeled through use of the drain
package in the MODFLOW program.
Drainage cells have been included in the top layer to simulate evaporation from
stack flanks, and in the bottom layer to model the influence of engineered ditches around
the perimeter of the stack as, well as an influential pond south of the stack (figure 30).
The insertion of drainage cells involves a specification of the drain conductance and the
elevation of the drain bottom. Drains in the top layer are specified with an elevation of 10
m and a conductance of 43 m2/day. The latter has been determined as the product of the
area, the hydraulic conductivity of the ditch fill, and the assumed thickness of the ditch
bottom.
Drains in the surficial aquifer are generally located at elevations of 3.0 & 6.0 m
with respective conductances of 43 & 21 m2/day. Drainage for the pond south of the stack
was specified at an elevation of 3.0 m, with a conductance of 43 m2/day.
65
Figure 30. Designation of Drainage Cells in the Surficial Aquifer.
Darkened cells of the grid are specified as sinks conducting water out
of the system. Representation as ditches and a pond is intended.
66
Calibration
The water table in the surficial aquifer did not vary enough to demand a complete
calibration of the model to each of the set of monitoring well head levels. Thus, a
calibration to within 10% of the average deviation for any particular head data set was
accepted as satisfactory for the steady state solution. Heterogeneities that could not be
determined or modeled within the aquifer environment were believed to be responsible
for most of the large deviations between modeled and actual head values.
Calibration of the head values in the model to their present form (figure 31) was
initiated as a large scale match to a set of contrived constant head cells which represented
values for a data set of actually measured head observations. Model parameters were then
adjusted until aberrations caused by the constant head cells disappeared and the contours
seemed adequately fit. After this was accomplished, the constant head values for
monitoring wells were taken out, and fine tuning of the parameter values was attempted.
All parameter values were kept as uniform as possible, so as to bring out inconsistencies
that would clarify local heterogeneities. Actual calibration of the model was done
conceptually in four steps:
1) balancing of stack leakance values with sub-stack conductivity to produce a head
match to well 2-0 located in the surficial aquifer,
2) adjustment of stack leakance values to generate vertical fluxes that are consistent with
the effective recharge of the gypsum stack from precipitation (minus evaporation),
67
5 .0
4.0
6.0
3.0 0
3.
2
2.0.0
7.0
20.0
7.0
2.0
6.0
5.0
0
4.0
3.
Figure 31. Contours of the Modeled Heads in the Surficial Aquifer.

Contours are in m intervals. Note the large influence of the cooling
pond ditches on the water table in the northeast section of the
model
3) adjustment of horizontal conductivity values in the surficial aquifer to produce head
values close to those of nearby monitoring wells,
68
4) modification of drain conductance and elevation to constrain large anomalies in head
contours.
The first two steps in the calibration involved a determination of the leakance value
trying to both match the observed hydraulic head in the surficial aquifer well 2-0 and the
estimated effective recharge of the gypsum stack as calculated from the difference
between precipitation and evaporation as measured in the region over the last few years
(see section on precipitation in the previous chapter) . Results of this calibration effort
show the strong dependency of the vertical stack-aquifer flux upon the leakance value
chosen (figure 32). With an estimated effective recharge of about 1600 m 3 /day over the
total area of both the new and the old stack, an optimal leakance value of 3 x10 -3 /day is
obtained.
In the second step, values for horizontal conductivity zones outside of the stack
region were found to be accurately quantified from the aquifer pump tests, and did not
need to be adjusted.
The final part of the calibration was made through changes in ditch elevations and
ditch conductances. Within this step was the addition of drainage cells to represent a pond
to the southeast of the stack. It was thought that impact of this pond contributed to some
69
2900 Sensitivity of Effective Stack
Recharge to Leakance
Effective Recharge (cu. m / day)
2600
2300
2000
1700 Estimated Recharge
1400
Optimal Value
1100
800
500
0 1 2 3 4 5 6 7 8 9 10
−4 −1
Leakance ( x 10 day )
Figure 32. Relationship of Stack Recharge to Leakance Value. Estimated

recharge values are compared to leakance values so that an optimal
leakance value can be inferred.
of the head drop from the stack in that region. The incorporation of the drainage cells
modeled partly also the effective evaporation of groundwater from the pond and from the
stack flanks, the exact value of which was not explicitly known in this study.
70
Comparison of modeled head values to observed values for September 19, 1996
(figure 20) was made to ensure a model fit (Table 5 & figure 33). The average deviation
of modeled values from well measurements was found to be 24 centimeters, which
approximated an 8.7% variance from actual values. The largest deviation of modeled
head was found to be at MW 5, which is isolated in an agricultural field south of the
research area, and could possibly be under influence of additional hydrologic factors not
considered, (i.e. irrigation pumping). Another significant deviation is exhibited at well
RW 17, which by itself is an anomaly. Contour plots of observed data (figures 19 & 20)
show that RW 17 forces a loop in the 3 m equipotential contour around the complex area.
This pattern is not quite understood, but may be the influence of a high conductivity
region or additional recharge to the groundwater in that area.
Sensitivity Analysis
Values of significance to the calibration of the model were also prime candidates
for a sensitivity analysis of the hydrologic control parameters in both the gypsum
stack and the surficial aquifer. Modeled parameters for leakance, hydraulic conductivity
and ditch specifications were modified over a range of one order of magnitude in either
direction to investigate their relative effect on the contoured modeled heads.
Table 5. Model Output Comparison to Actual Head Values. Comparison is expressed

as both an absolute depth value (in meters above MSL) and as a percentage.
71
W e ll n u m b e r 9 /19 /96 V alu e M o d e le d V a lu e D iffe re n ce P e rc e n ta g e
MW 1 7.5 9 7 .3 -0.2 9 -3 .82
MW 2 4.1 7 4 .3 0.1 3 3 .12
MW 3 3.0 8 3.1 8 0.1 0 3 .25
MW 4a 1.6 4 1.8 4 0.2 0 1 2 .20
MW 5 1.7 4 2.6 1 0.8 7 5 0 .00
MW 8 1.5 3 1.7 3 0.2 0 1 3 .07
MW 9 6.3 9 5.2 4 -1.1 5 -1 8 .00
MW 10 6.8 2 6.9 9 0.1 7 2 .49
MW 11 7.2 6 7.2 4 -0.0 2 -0 .28
RW 8 7.2 7 7.2 2 -0.0 5 -0 .69
RW 9 5.5 5 5 -0.5 5 -9 .91
RW 10 4.0 4 4.3 7 0.3 3 8 .17
RW 11 2.7 3 2.7 2 -0.0 1 -0 .37
RW 12 2.9 7 3.4 1 0.4 4 1 4 .81
RW 13 2.9 1 3.5 4 0.6 3 2 1 .65
RW 14 3.3 9 3.6 5 0.2 6 7 .67
RW 15 2.4 4 2.1 4 -0.3 0 -1 2 .30
RW 16 1.8 6 1.8 9 0.0 3 1 .61
RW 17 3.4 3 2 .7 -0.7 3 -2 1 .28
RW 18 1.5 7 2.2 7 0.7 0 4 4 .59
RW 19 2.1 8 2.3 6 0.1 8 8 .26
RW 20 3.1 2 3.6 4 0.5 2 1 6 .67
RW 21 3.2 0 3.2 3 0.0 3 0 .94
RW 22 3.0 6 3.3 8 0.3 2 1 0 .46
RW 23 2.9 0 3.1 5 0.2 5 8 .62
RW 24 2.6 1 3.3 6 0.7 5 2 8 .74
USGS 8 6.9 9 6.7 6 -0.2 3 -3 .29
USGS 9 4.1 5 4.5 1 0.3 6 8 .67
PZ 34 6.5 8 7.0 4 0.4 6 6 .99
PZ 36 6.3 3 6.2 8 -0.0 5 -0 .79
PZ 37 6.0 4 6.0 8 0.0 4 0 .66
S ta c k 2 - 0 1 1.7 3 1 1.7 3 0.0 0 0 .00
A v era g e 0.2 4 8 .70
72
13
12
11
10
9
Modeled Head (m)
0
0 1 2 3 4 5 6 7 8 9 10 11 12 13
Observed Head (m)
Figure 33. Modeled versus observed head values. Shown are the
listed values of table 5 with the +/- 1m error band between modeled
and observed heads
Leakance
Uniform leakance volumes from beneath the stack were the most critical value in
reference to overall head values for the entire grid. Conceptually, the leakance was
important in supplying the general volume of water available for flow into the stack and
73
the surficial aquifer. The sensitivity of the effective recharge from the stack ponds and,
owing to a lack of information, neglecting the flank water losses, ergo the flux into the
surficial aquifer to the leakance value chosen can be clearly observed from figure 32.
Thus a variation of a unit change in the leakance was found to increase head levels
beneath the stack on the meter-scale, with a modification by one order of magnitude
leaving too much of an impact on volume fluxes of water into the surficial aquifer. Thus,
the physical flux through the confining layer between the gypsum stack and the surficial
aquifer surface has the most significant impact on the modeled environment.
Conductivities
Modeled conductivity values in the surficial aquifer zones were found to
definitely be within at least one order of magnitude of their actual, measured “group”
quantity. Modification of these values by single units allowed for better model fits to
some data sets, but not to others. Since a generalized, rather homogenous hydraulic
conductivity was intended, the best fit for a generic head representation of observed
values yielded the best solution (as indicated by the differences between modeled and
observed heads of table 5) in the steady state mode. Thus, the modeled values for the
hydraulic conductivities are probably within a range of 5 units from the actual values
determined from the aquifer pump tests (cf. figure 29). It is thought that internal
heterogeneities of the hydraulic conductivity are responsible for localized head anomalies.
Ditch Specifications
Ditch elevation and conductance was determined to be of the most importance to
sinks within the hydrologic environment. Although conductance signified the degree of
74
impact each ditch had, the elevation of the ditches was a limiting factor on whether or not
any impact would be made to the flow system. The presence of ditches within the system
therefore, were a crucial part of the flow barrier surrounding the stack. Actual values of
the ditch elevations were critical to head values nearer to the stack, and although these
numbers were not directly specified from engineered specifications, slight modifications
of the elevation could be made up with additional conductance (which was also not
quantified to specifications but rather to the model fit). Regardless, ditch presence was
absolutely necessary and its parameters could not be altered very much.
As an example of the sensitivity of the model to the conductance of the ditches,
figure 34 illustrates a case whereby a conductance of 0.43 m2/day, instead of the 43
m2/day in figure 31, was used for the cooling pond ditches. With such a low conductance
the inclination of the head contours toward the cooling pond in the western part of the
model , as indicated by the actual heads (figure 20), has nearly disappeared.
Predictions for alteration of the hydrologic system are somewhat restricted to a
change in ditch presence, owing to the fact that hydraulic conductivities and water
recharge from the stack will most likely not change. Filling in of ditches will allow a
75
4.0
5.0
6.0
3 .0
2.0
7 .0
20.0
2.0
7.0
6.0
0
4.0
3.
5.0
Figure 34. Sensitivity of the Modeled Heads in the Surficial Aquifer to

the conductance of the cooling pond ditches. In comparison with
figure 30 where a conductance of 43 m2/day was used, this one here
is only 0.43 m2/day.
larger transfer of groundwater from the stack into the surficial aquifer, and will create a
larger impact (mounding effect) of the stack on the surficial aquifer. Quantification of this
76
influence will be dependent upon how much of the ditch is actually filled in. Greatest
influence of such a change would be made to the west and southwest perimeters, as the
head gradients in those ditches support the largest volume of water conducted out of the
system. As a recommendation for future studies of the problem, ditch elevations should
be monitored more precisely than has been undertaken during the course of this
investigation.
Water Budget Analysis
A volumetric flux analysis of the surficial aquifer (figure 35) shows the actual
impact of the stack on the surficial aquifer. Values for fluxes of the hydraulic system as
obtained from the MODFLOW program and from measured hydrological input
parameters made possible such an analysis of the total water budget of the aquifer system
(stack plus surficial aquifer).
The volumetric calculation of the budgets were made in terms of m3/day and
followed the generalized form of the continuity equation:
Input - Output = Change in Storage
Although there is a short term (weekly and seasonal) change in storage which is indicated
by water level changes in the stack ponds, it can be assumed that there is no
77
Pond Evaporation Precipitation
3
1591 m / day 3182 m 3 / day
Flank Evaporation
????
Ditch Drainage
1575 m 3 / day
Stack Infiltration
1591 m3 / day
Regional Outflow Dewatering Pipes Regional Inflow

3
62 m / day ???? 46 m3 / day
Figure 35. Water Budget Analysis. Input and output of volumetric fluxes
to the gypsum stack and the surficial aquifer are represented as
arrows.
78
change in storage over longer periods that are of the order of the residence times of water
in the gypsum stack and the surficial aquifer (i.e. several seasons and years). Thus, input
will equal output, as required in the steady-state model.
The volumetric input flux of the stack is described completely upon the
precipitation, with large contributors of output flux being pond evaporation and stack
leakance to the surficial aquifer. Pond evaporation was calculated as 50 % of the input
flux, with the leakance taken from a water budget file in MODFLOW. Actual fluxes were
only modeled after pathways that were known, so that smaller pathways of output fluxes
such as flank evaporation, dewatering pipes, and sprayers on top of the stack were not
considered. Upon determination of larger contributions of these smaller fluxes to the total
net output, a smaller vertical flux to the surficial aquifer could be calculated in the future.
The value determined here (figure 35) is, therefore, most likely overestimated by an
unspecified amount and would thus represent a worst-case scenario for the infiltration of
possibly toxic leachates from the phosphogypsum tailings into the surficial aquifer.
With these reservations, the inputs for the surficial aquifer unit include an
(overestimated) leakance from the gypsum stack and transport of regional flow from the
southeast. Outputs include the ditch system, as well as regional losses of groundwater to
the northwest. Most important of to this flux analysis is the comparison of regional flow
input and output to the relative inputs and outputs of the stack and ditches. For the most
part, volumes of water transferred from the stack are taken up entirely by the ditch
system. Any volume of water not taken up by the ditches is added into the regional flow
and seen as a hydrologic impact from primarily the stack; i.e. the mounding effect. This
conceptualization of the flux budget is important for the understanding of the hydraulic
79
control of water in the system. A relatively complete consumption of water to the ditches
indicates that engineering of the hydraulic balances used to minimize impact on the
groundwater are fairly adequate and even if toxic leachate from the gypsum’s stack
infiltrates into the surficial aquifer, it will, to a large extent, be intercepted by the ditch
drainage system. Figure 34 illustrates that only about 16 m3/day of water is bypassing
the ditch structure and being swept with the regional flow. Although such an amount of
non-captured diluted leachate may seem large at first glance, the value must be taken to
be relative to total fluxes in the system. When compared to the input of the surficial
aquifer, it is ~38% of that value, however, in comparison to the stack leakance, this
value is ~1% of the infiltrating flux. Thus, the addition of water to the system is quite
small in comparison to the amount of water that could be impacting the aquifer were
there no ditches. However, the quantity of flux to the system is quite large when
considering the regional flow and must be taken as somewhat of a considerable impact to
the groundwater environment in the vicinity of the phosphogypsum stack.
80
CHAPTER 6
CONCLUSIONS
This study investigates one particular phosphogypsum stack and its environment,
in an attempt to characterize flow processes that would be typical for many of the other
stacks in west central Florida. In an effort to assess flow and transport in a specific
phosphogypsum stack and the possible interaction of the low pH stack solutions with
groundwater in the adjacent surficial aquifer, a comprehensive investigation that included
hydrological testing and flow modeling has been carried out.
Several wells were drilled into the stack and the adjacent aquifer and various
experimental aquifer tests were performed and head measurements over a period of about
18 months taken. The aquifers tests include pressure transducer tests, pump and recovery
tests such as the Cooper-Jacob straight-line method, the Kirkham auger hole test and the
Bouwer Rice test for partially screened and partially penetrating wells, and in situ
flowmeter tests which allow the determination of the vertical stratification of the
hydraulic conductivity.
The pressure transducer tests provide evidence for small vertical gradients that are
reflecting the mounding effect of the stack, accentuated by the presence of a standing
water pond on its top. Although the pump tests result in only average values of the
transmissivity and storativity of the phosphogypsum stack, together with the vertical head
gradients, it hints of some vertical recharge into the gypsum formation and, because of a
significant head gradient between the gypsum stack and the underlying surficial aquifer,
possibly of vertical leakage of gypsum water into the surficial aquifer.
81
The Bouwer Rice pump tests resulted in an anomalously low hydraulic
conductivity beneath the gypsum stack but indicated a high conductivity zone in the
northwest section of the model area. The results of the flowmeter tests for the hydraulic
conductivity support the notion that flow may be partly only along horizontal bedding
planes that were formed during the `sedimentation' process of the phosphogypsum slurry.
The hydrological data was used in a steady-state numerical mounding model using
the MODFLOW model to simulate the hydraulic effect of the stack on the regional flow
and to quantify flux rates from the phosphogypsum stack into the surficial aquifer. The
model was calibrated to within 10% of the average deviation for any particular observed
head data set by adjusting various hydrological input parameters, namely the horizontal
conductivity values in the surficial aquifer; the stack leakance values, and the drain
conductances and elevation of the dewatering ditches.
The sensitivity analysis of the hydrologic control parameters in both the
gypsum stack and the surficial aquifer illustrates that the model is the most sensitive to
the leakance rate and the ditch specifications. By adjusting the vertical stack leakance
values in the model, such as to generate vertical fluxes that are consistent with the
-4
effective recharge of the gypsum stack from precipitation, an optimal value of 3 x10
day -1 was found for the leakance.
The volumetric flux analysis of the surficial aquifer shows the actual impact of
the stack on the surficial aquifer and illustrates furthermore the effectiveness of the ditch
drains in intercepting possible toxic leachate that may have infiltrated from the gypsum
stack into the surficial aquifer. In fact, only a small amount of ~1% of the infiltrating flux
of gypsum stack water is not captured by the ditches and is carried further horizontally
82
through the surficial aquifer. However, because of the neglect of the, heretofore,
unknown estimates of stack water losses due to flank evaporation, spray losses, and
dewatering pipes, the real rate of infiltration may even be less than the value indicated by
the budget analysis presented here. Unfortunately, a more precise evaluation of the true
flux-impact of the phosphogypsum stack onto the surficial aquifer will be possible only
after a more precise quantification of these stack water losses will have become
available.
REFERENCES
Amoozegar, A., and Warrick, A.W. (1986) Hydraulic conductivity of saturated soils:
field methods. Methods of Soil Analysis: Part 1 - Physical and Mineralogical
Methods, Agronomy Monograph no. 9, 735-770.
Anderson, M.P., and Woessner, W.W. (1992) Applied groundwater modeling: simulation
of flow and advective transport. San Diego, California: Academic Press Inc.,
381 pp.
Bear, J. (1979). Hydraulics of groundwater, Mc Graw-Hill Inc., New York.
Boast, C.W., and Kirkham, D. (1971) Auger hole Seepage theory. Soil Science Society of
America Proceedings, 35, 365-373.
Bouwer, H., and Rice, R.C. (1976) A slug test for determining hydraulic conductivity of
unconfined aquifers with completely or partially penetrating wells. Water
Resources Research, 12, 423-428.
Burnett, W.C., Hull, C.D., and Koch, M. (1995) How does phosphogypsum storage affect
groundwaters? Florida Institute of Phosphate Research, draft year-1 report of
project 94-05-042, 70 pp.
83
Chiang, W.H., and Kinzelbach, W. (1994) Processing Modflow for Windows : a
simulation system for modeling groundwater flow and pollution. Software
instructional manual, 196 pp.
Driscoll, F.G. (1986) Groundwater and Wells, Johnson Division, St. Paul, MN.
Gerathy and Miller, INC. (1983) Groundwater monitoring plan, Amax chemical
corporation, piney point plant. Final Report, prepared for Amax chemical
corporation (Ground Water Consultants, Tampa, Florida), 82 pp.
Gerathy & Miller, INC. (1986). Revised groundwater monitoring plan at the AMAX
Phosphate Inc. complex, Technical Report, Gerathy & Miller Inc., Tampa, FL.
Johnston, R.H., Healy, H.G., and Hayes, L.R. (1981) Potentiometric surfaces of the
tertiary limestone aquifer system, southeastern United States: May, 1980. U.S.
Geological Survey, open file report 81-486, 1 pp.
Johnston, R.H., Krause, R.E., Meyer, R.W., Ryder, P.D., Tibbals, C.H., and Hunn, J.D.
(1980) Estimated potentiometric surface for the tertiary limestone aquifer system,
southeastern United States, prior to development. U.S. Geological Survey, open
file report 80-406, 1 pp.
Lewelling, B.R., and Wylie, R.W. (1993) Hydrology and water quality of unmined and
reclaimed basins in phosphate mining areas, west-central Florida. U.S. Geological
Survey, water resources investigations report 93-4002, 93 pp.
May, A., and Sweeney, J.W. (1983) Evaluation of radium and toxic element leaching
characteristics of Florida phosphogypsum stockpiles. Bureau of Mines, report of
investigations 8776, Tuscaloosa AL, 18 pp.
May, A., and Sweeney, J.W. (1984) Assessment of environmental impacts associated
with phosphogypsum in Florida. The Chemistry and Technology of Gypsum,
ASTM Publication 861, 116-139.
Mcdonald, M.C., and Harbaugh, A.W. (1988) MODFLOW: a modular three-dimensional

finite difference ground-water flow model. U.S. Geological Survey, open file
84
report 83-875, 528 pp.
Miller, R.L. and H. Sutcliffe, Jr., (1982) Water-quality and hydrogeological data
for three phosphate industry waste-disposal sites in Central Florida,
U.S. Geological Survey, Water Resources Investigations Report 81-84,
Tallahassee, FL..
Miller, R.L., and Sutcliffe Jr., H. (1984) Effects of three phosphate industrial sites on
ground-water in central Florida, 1979 to 1980. U.S. Geological survey, water
resources investigations report 83-4256, 184 pp.
Molz, F.J., G.K. Boman, S.C. Young and W.R. Waltrop (1994).Borehole flowmeters:
field applications and data analysis, J. Hydrology, 163, 347—371.
Oaks Geotechnical Inc. (1980) Geotechnical investigation of the gypsum

stack complex of AMAX Phosphate Inc., Report, Oaks Geotechnical Inc.
Youngs, E.G. (1968) Shape factors for kirkham’s piezometer method for determining the
hydraulic conductivity of soil in situ for soils overlying an impermeable floor or
infinitely permeable stratum. Soil Science, 106, 235-237.
85
Appendix I: Cooper Jacob Straight-line Analyses
3.8
Well 1-1
4.0
Hydraulic Head (m)
4.2
4.4
4.6
4.8
5.0
2 3 4 5 6 7 8 9 2 3 4 5 6 7 8 9 2
101 102
Time (min)
86
5
6
Well 1-2
7
Hydraulic Head (m)
10
11
10-1.0 100.0 101.0 102.0
Time (min)
87
2.300
Well 1-3
2.575
Hydraulic Head (m)
2.850
3.125
3.400
10-1.0 100.0 101.0 102.0
Time (min)
88
2.1500
Well 1-4
2.2875
Hydraulic Head (m)
2.4250
2.5625
2.7000
6 3 8 5
100 101 102 103
Time (min)
89
0
4
Well 3-1
6
Drawdown (m)
10
12
14
16
18
2 3 4 5 6 7 8 9 2 3 4 5 6 7 8 9
100 101 102
Time (min)
90
3.75
3.95
Well 3-2
Drawdown (m)
4.15
4.35
4.55
9 2 3 4 5 6 7 8 9 2 3 4 5 6 7 8 9
100 101 102
Time (min)
91
3.0500
Well 3-3
3.1625
Drawdown (m)
3.2750
3.3875
3.5000
9 2 3 4 5 6 7 8 9 2 3 4 5 6 7 8 9
100 101 102
Time (min)
Appendix II : Pressure Transducer Tests
92
2
Well 1-1
10
Cased Section
14
18 Screened Section
22
0 2 4 6 8 10 12 14 16 18 20 22 24
Pressure (PSI)
93
1
Well 1-2
Cased Section
11
13
15 Screened Section
17
0 2 4 6 8 10 12 14 16 18
Pressure (PSI)
94
2
3
Well 1-4
5
Cased Section
6
Screened Section
8
10
0 1 2 3 4 5 6 7 8 9 10
Pressure (PSI)
95
4.0
5.5
7.0 Well 2-1

Depth below Well Riser (m)
8.5
10.0
11.5
Cased Section
13.0
14.5
16.0
Screened Section
17.5
19.0
0 2 4 6 8 10 12 14 16 18
Pressure (PSI)
96
4
Well 2-2
Screened Section
10
12
14 Screened Section
16
0 2 4 6 8 10 12 14 16
Pressure (PSI)
97
2
4
Well 3-3
Cased Section
10
Screened Section
12
-1 1 3 5 7 9 11 13
Pressure (PSI)
Appendix III : Hydraulic Head Contour Plots
98
2250
2000
5-26-96
1750
North - South (m)
1500
1250
1000
750
500
250
0
0 250 500 750 1000 1250 1500 1750 2000 2250 2500 2750
East - West (m)
99
2250
2000
9-19-96
1750
North - South (m)
1500
1250
1000
750
500
250
0
0 250 500 750 1000 1250 1500 1750 2000 2250 2500 2750
East - West (m)
100
Appendix IV : Bouwer Rice Conductivity Tests
10.000
Well # : MW-1
1.000
Drawdown (m)
0.100
0 600 1200 1800 2400 3000 3600 4200 4800 5400 6000
Time (sec)
101
10.000
Well # : MW-8
Drawdown (m)
1.000
0.100
0 800 1600 2400 3200 4000 4800 5600 6400 7200 8000
Time (sec)
102
10.000
Well # : MW-9
Drawdown (m)
1.000
0.100
0 400 800 1200 1600 2000 2400 2800 3200 3600 4000
Time (sec)
103
10.000
Well # : MW-18
1.000
Drawdown (m)
0.100
0.010
0 240 480 720 960 1200 1440 1680 1920 2160 2400
Time (sec)
104
10.000
Well # : MW 21
1.000
Drawdown (m)
0.100
0.010
0 250 500 750 1000 1250 1500 1750 2000 2250 2500
Time (sec)
105
10.000
Well # : MW 22
Drawdown (m)
1.000
0.100
-0 200 400 600 800 1000 1200 1400 1600 1800 2000
Time (sec)
106
10.000
Well # : MW 24
1.000
Drawdown (m)
0.100
0 500 1000 1500 2000 2500
Time (sec)
107
10.000
Well # : 2-0
Drawdown (m)
1.000
0 2500 5000 7500 10000 12500 15000 17500 20000 22500 25000
Time (sec)
108
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
OFFICE OF
PREVENTION, PESTICIDES AND
TOXIC SUBSTANCES
Inert Ingredients Permitted for Use in

Nonfood Use Pesticide Products
Last Updated January 7, 2008
The following inert ingredients are permitted for use in nonfood use pesticide products.
NOTE: All inert ingredients as described in 40 CFR Part 180 may also be used in
nonfood use pesticide products.
CAS Reg. No. Chemical Name

100-02-7 p-Nitrophenol
100092-50-0 Sodium dodecylphenyl polyoxyethylene phosphates
10016-20-3 α-Cyclodextrin
10024-97-2 Nitrous oxide (N2O)
10025-67-9 Sulfur chloride (S2Cl2)
10025-74-8 Dysprosium chloride (DyCl3)
10025-76-0 Europium chloride (EuCl3)
10025-77-1 Ferric chloride
10025-94-2 Yttrium chloride (YCl3), hexahydrate
1002-62-6 Decanoic acid, sodium salt
10028-21-4 Sulfuric acid, iron(2+) salt (1:1), dihydrate
10028-22-5 Ferric sulfate
1002-89-7 Octadecanoic acid, ammonium salt
10031-30-8 Tricalcium phosphate (Ca3(PO4)2)
10034-76-1 Calcium sulfate hemihydrate
10034-85-2 Hydriodic acid
10034-88-5 Sodium bisulfate monohydrate
10034-99-8 Magnesium sulfate heptahydrate
10035-04-8 Calcium chloride
10035-10-6 Hydrobromic acid
100-37-8 2-(Diethylamino)ethanol
100403-38-1 Glycerides, animal, reaction products with sucrose
100403-39-2 Glycerides, palm-oil, reaction products with sucrose
100403-40-5 Glycerides, tallow, reaction products with sucrose
100403-41-6 Glycerides, vegetable-oil, reaction products with sucrose
100-41-4 Ethylbenzene
Page 1 of 93
100-42-5 Styrene
10043-01-3 Aluminum sulfate
10043-35-3 Boric acid
10043-52-4 Calcium chloride (CaCl2)
10043-67-1 Potassium aluminum sulfate
10043-83-1 Magnesium phosphate
10045-89-3 Ferrous ammonium sulfate
10049-04-4 Chlorine dioxide
100-51-6 Benzyl alcohol
100-52-7 Benzaldehyde
10058-23-8 Monopotassium peroxymonosulfate
100-66-3 Benzene, methoxy-
100684-20-6 Fatty acids, tall-oil, maleated, compds. with triethanolamine
100852-66-2 Citric acid, bis(dimethylamine) salt
1008-72-6 Benzenesulfonic acid, 2-formyl-, sodium salt
2-Propenoic acid, 2-methyl-, polymer with methyl 2-methyl-2-propenoate and
100934-04-1 alpha-(2-methyl-1-oxo-2-propenyl)-omega-methoxypoly(oxy-1,2-ethanediyl)
10094-34-5 Butanoic acid, 1,1-dimethyl-2-phenylethyl ester
10094-62-9 D-Glycero-D-gulo-heptonic acid, sodium salt, dihydrate
100-97-0 Hexamethylenetetramine
10099-58-8 Lanthanum chloride
10101-39-0 Silicic acid (H2SiO3), calcium salt (1:1)
10101-41-4 Calcium sulfate dihydrate
10101-50-5 Sodium permanganate
10101-66-3 Diphosphoric acid, ammonium manganese(3+) salt (1:1:1)
101-02-0 Dehydrated castor oil-maleic anhydride adduct
10102-17-7 Thiosulfuric acid (H2S2O3), disodium salt, pentahydrate
10102-18-8 Sodium selenite
10102-40-6 Molybdic acid (H2MoO4), disodium salt, dihydrate
10103-46-5 Calcium phosphate
10107-99-0 Diethylene glycol abietate
10108-91-5 Dimethylditetradecylammonium chloride
10117-38-1 Potassium sulfite
10124-31-9 Ammonium phosphate
10124-41-1 Calcium thiosulfate
10124-43-3 Cobalt sulfate
10124-56-8 Sodium polymetaphosphate
10124-65-9 Dodecanoic acid, potassium salt
101-25-7 N,N'-Dinitrosopentamethylenetetramine
10137-74-3 Calcium chlorate
10138-04-2 Ferric ammonium sulfate
10143-60-9 Di(2-ethylhexyl)ether
101-86-0 alpha-Hexylcinnamaldehyde
10191-41-0 dl-α-Tocopherol
10192-30-0 Ammonium bisulfite
Page 2 of 93
10213-78-2 Ethanol, 2,2-(octadecylimino)bis-
10213-79-3 Silicic acid, disodium salt, pentahydrate
102-54-5 Ferrocene
102-60-3 2-Propanol, 1,1',1",1"'-(1,2-ethanediyldinitrilo)tetrakis-
102-71-6 Triethanolamine
102-76-1 Glyceryl triacetate
Siloxanes and silicones, 3-[(2-aminoethyl)amino]propyl Me, di-Me, methoxy-
102782-92-3 terminated
10279-57-9 Silica, hydrate
N,N-Dibutyl, N-(2-hydroxyethyl), N-hydro, ammonium mono(2-
102-81-8 methylethanol) maleate
Poly(oxyethylene/oxypropylene) monoalkyl(C6-C10)ether sodium fumarate
102900-02-7 adduct
10294-56-1 Phosphorous acid
102980-04-1 Phenolsulfonic acid-phenol-formaldehyde-urea condensate, sodium salt
103-09-3 Acetic acid, 2-ethylhexyl ester
103-11-7 2-Ethylhexyl acrylate
103-23-1 Di-n-octyl adipate (List 1 inert)
103-24-2 Di-2-ethylhexyl azelate
103-26-4 Methyl cinnamate
103-41-3 Benzyl cinnamate
10361-29-2 Carbonic acid, ammonium salt
10361-65-6 Phosphoric acid, triammonium salt
10361-84-9 Scandium chloride (ScCl3)
10361-91-8 Ytterbium chloride (YbCl3)
10361-92-9 Yttrium chloride
10377-60-3 Magnesium nitrate
10378-23-1 Ethylenediaminetetraacetic acid tetrasodium salt hydrate
104133-09-7 Tetraethoxysilane, polymer with hexamethyldisiloxane
104-15-4 p-Toluenesulfonic acid
104199-39-5 Naphthalenesulfonic acid, C6-9-alkyl Me derivs., sodium salts
104-28-9 2-Ethoxyethyl p-methoxycinnamide
104-45-0 1-Methoxy-4-propylbenzene
104-46-1 Anethole
104-54-1 Cinnamic alcohol
104-55-2 Cinnamic aldehyde
104-61-0 Nonanoic acid, 4-hydroxy-, .gamma.-lactone
104-67-6 2(3H)-Furanone, 5-heptyldihydro-
1047-16-1 C.I. Pigment Violet 19
104-76-7 1-Hexanol, 2-ethyl-
Poly(oxy-1,2-ethanediyl), α-{3-{3-(2H-benzotriazol-2-yl)-5-(1,1-
104810-47-1 dimethylethyl)-4-hydroxyphenyl}-1-oxopropyl}-ω-hydroxy-
Poly(oxy-1,2-ethanediyl), alpha-[3-[3-(2H-benzotriazol-2-yl)-5-(1,1-
104810-48-2 dimethylethyl)-4-hydroxyphenyl]-1-oxopropyl]-omega-hydroxy-
10486-00-7 Perboric acid (HBO(O2)), sodium salt, tetrahydrate
Page 3 of 93
104-87-0 Benzaldehyde, 4-methyl-
105-16-8 2-Propenoic acid, 2-methyl-, 2-(diethylamino)ethyl ester
105362-40-1 Phosphoric ester of Tristyrylphenylehtoxylated
105-37-3 Ethyl propionate
105-54-4 Ethyl butyrate
105-55-5 1,3-Diethyl-2-thiourea
105-59-9 Ethanol, 2,2'-(methylimino)bis-
105839-17-6 Castor oil, epoxidized
105859-97-0 Lignin, alkali, reaction products with disodium sulfite and formaldehyde
105-87-3 Benzenemethanol,α-methyl-,acetate
10595-49-0 1-Propanaminium, N,N,N-trimethyl-3-[(1-oxododecyl)amino]-, methyl sulfate
106-11-6 9-Octadecanoic acid 2-(2-hydroxyethoxy)ethyl ester
alpha-(p-Nonylphenyl)-omega-hydroxypoly(oxyethylene) mixture of
dihydrogen phosphate and monohydrogen phosphate esters, potassium salt; the
nonyl group is a propylene trimer isomer and the POE content averages 6
106151-63-7 moles
106-22-9 3,7-Dimethyl-6-octen-1-ol
106-23-0 Citronellal
106-24-1 Geraniol (for fragrance use only)
106-25-2 2,6-Octadien-1-ol, 3,7-dimethyl-, (Z)-
106-27-4 Isoamyl butyrate
106-30-9 Ethyl heptanoate
106392-12-5 Oxirane, polymer with methyloxirane, block
106-42-3 4-Xylene
106-43-4 4-Chlorotoluene
1064-48-8 C.I. Acid Black 1, disodium salt
106-61-6 Acetin, 1-mono-
1066-33-7 Carbonic acid, monoammonium salt
106-65-0 Butanedioic acid, dimethyl ester
106-68-3 Ethyl amyl ketone
1067-25-0 Trimethoxysilylpropane
106-88-7 1,2-Butylene oxide
106-97-8 Butane
1070-03-7 Octyl dihydrogen phosphate
107-15-3 Ethylenediamine
107-18-6 Allyl alcohol
107-19-7 Propargyl alcohol
107-21-1 Ethylene glycol
107-22-2 Ethanedial
107-41-5 Hexylene glycol
107-54-0 3,5-Dimethyl-1-hexyn-3-ol
107-64-2 Distearyl dimethyl ammonium chloride
107712-67-4 Silsesquioxanes, Me 2,4,4-trimethylpentyl, methoxy-terminated
107-75-5 Hydroxycitronellal
107-88-0 1,3-Butanediol
Page 4 of 93
107-92-6 Butyric acid
107-98-2 1-Methoxy-2-propanol
108-01-0 Ethanol, 2-(dimethylamino)-
108-05-4 Acetic acid ethenyl ester
108-10-1 Methyl isobutyl ketone
108137-17-3 Polyoxyethylene polyoxypropylene block polymer, mono(nonylphenyl) ether
108171-28-4 Methylnaphthalenesulfonic acids, polymers with formaldehyde, sodium salts
108-21-4 Isopropyl acetate
108-24-7 Acetic anhydride
108-31-6 Maleic anhydride
108-32-7 Propylene carbonate
108-38-3 3-Xylene
108389-12-4 Naphthalenesulfonic acid, methylenebis[methyl-, disodium salt
108419-32-5 Acetic acid, C7-9-branched alkyl ester, C8-rich
108419-33-6 Acetic acid, C8-10 branched alkyl esters, C9-rich
108419-34-7 Acetic acid, C9-11-branched alkyl esters, C10-rich
108419-35-8 Acetic acid, C11-14-branched alkyl ester, C13-rich
108-46-3 Resorcinol
108-63-4 Adipic acid, bis(1-methylheptyl) ester
108-65-6 1-Methoxy-2-propyl acetate
108-78-1 1,3,5-Triazine-2,4,6-triamine
1-Propanaminium, 3-butoxy-2-hydroxy-N-(2-hydroxy-3-sulfopropyl)-N,N-
108797-84-8 dimethyl-, inner salt
1-Propanaminium, 3-[(2-ethylhexyl)oxy]-2-hydroxy-N-(2-hydroxy-3-
108797-85-9 sulfopropyl)-N,N-dimethyl-, inner salt
108-80-5 Cyanuric acid
108818-88-8 Poly(oxy-1,2-ethanediyl), α-isodecyl-ω-hydroxy-, phosphate
108-83-8 Diisobutyl ketone
108-88-3 Toluene
108-90-7 Monochlorobenzene
108-93-0 Cyclohexanol
108-94-1 Cyclohexanone
108-95-2 Phenol (List 1 Inert)
109-02-4 Morpholime, 4-methyl-
109027-47-6 Benzenesulfonic acid, coctadecyl-, sodium salt
109-21-7 Butyl butyrate
109-46-6 Dibutyl thiourea
109-52-4 n-Valeric acid
1095-66-5 Morpholine oleate
109-60-4 Propyl acetate
109-89-7 Diethylamine
Poly(oxy-1,2-ethanediyl), alpha-sulfo-omega-(2,4,6-tris(1-
109909-39-9 methylpropyl)phenoxy)-, sodium salt
109961-42-4 2-Propenenitrile, polymer with 1,2,4-triethenylcyclohexane, hydrolyzed
109-99-9 Tetrahydrofuran
Page 5 of 93
110-05-4 Di-tert-butyl peroxide
110-11-2 Sulfuric acid, monooctyl ester
110-12-3 Methyl isoamyl ketone
110-15-6 Butanedioic acid
110-16-7 Maleic acid
110-17-8 Fumaric acid
110-19-0 Isobutyl acetate
110-25-8 Glycine, N-methyl-N-[(9Z)-1-oxo-9-octadecenyl]
110-27-0 Tetradecanoic acid, 1-methylethyl ester
110-30-5 Octadecanamide, N,N'-1,2-ethanediylbis-
110-43-0 Methyl n-amyl ketone
110-54-3 Hexane (List 1 Inert)
110-44-1 Sorbic acid
110615-47-9 D-Glucopyranose, oligomeric, C10-16-alkyl glycosides
110-63-4 1,4-Butanediol
110-64-5 2-Butene-1,4-diol
110-69-0 Butyraldoxime
110720-64-4 Siloxanes and silicones, 3-aminopropyl Me, Me stearyl
110-73-6 Ethyl ethanolamine
110-80-5 Ethylene glycol monethyl ether (List 1 Inert)
110-82-7 Cyclohexane
110-87-2 [(Tetrahydro-2H-pyran-yl)thio]ethyl tallate
110-91-8 Morpholine
11092-32-3 Aluminum oxide
11096-42-7 Ethoxylated nonylphenol comp. with iodine
110-97-4 Diisopropanolamine
Aluminate (Al(OH)63-), (OC-6-11)-, magnesium carbonate hydroxide
11097-59-9 (2:6:1:4)
11099-07-3 Octadecanoic acid, ester with 1,2,3-propanetriol
111-01-3 Squalane
111-03-5 9-Octadecenoic acid (Z)-, 2,3-dihydroxypropyl ester
Oxirane, methyl-, polymer with oxirane, ether with (1,2-ethanediyldinitrilo)
11111-34-5 tetrakis[propanol] (4:1)
Distallates (petroleum), catalytic reformer fractionator residue, low-boiling,
111163-74-7 sulfonated, sodium salts
1111-78-0 Ammonium carbamate
111-20-6 Decanedioic acid
111-27-3 1-Hexanol
11130-12-4 Boric acid, sodium salt, pentahydrate
111-30-8 Glutaraldehyde
111330-30-4 Naphthalenesulfonic acid, (1-methylpropyl)-, sodium salt
11138-05-9 Dicocodimethylammonium nitrite
11138-66-2 Xanthan gum
111-40-0 Diethylenetriamine
111-41-1 N-(2-Hydroxyethyl)ethylenediamine
Page 6 of 93
111-42-2 Diethanolamine
111-43-3 Propane, 1,1'-oxybis-
111-46-6 Diethylene glycol
111-57-9 N-(2-Hydroxyethyl)octadecanamide
111-60-4 Octadecanoic acid, 2-hydroxyethyl ester
111-62-6 Ethyl oleate
1H-Pyrazole-3-carboxylic acid, 4,5-dihydro-5-oxo-1-(4-sulfophenyl)-4-{(4-
111636-30-7 sulfophenyl)azo}-, sodium salt
111-70-6 1-Heptanol B29
111-76-2 2-Butoxyethanol
111-77-3 2-(2-Methoxyethoxy)ethanol
111-82-0 Dodecanoic acid, methyl ester
111-87-5 n-Octanol
1118-92-9 Octanamide, N,N-dimethyl-
111-90-0 Diethylene glycol monoethyl ether
1119-40-0 Pentanedioic acid, dimethyl ester
1120-01-0 Sodium hexadecyl sulfate
1120-04-3 Sodium octadecyl sulfate
112-00-5 1-Dodecanaminium, N,N,N-trimethyl-, chloride
112-02-7 N,N,N-Trimethyl-1-hexadecanaminium chloride
1120-34-9 Erucic acid, methyl ester
112-03-8 1-Octadecanaminium, N,N,N-trimethyl-, chloride
112-05-0 n-Nonanoic acid
112-07-2 2-Butoxyethanol acetate
112-10-7 Isopropyl stearate
112-18-5 1-Dodecanamine, N,N-dimethyl-
112-24-3 Triethylenetetramine
112-25-4 Ethanol, 2-(hexyloxy)-
112-27-6 Ethanol, 2,2'-(1,2-ethanediylbis(oxy)bis-
112-30-1 n-Decanol
112-31-2 Decanal
112-34-5 Ethanol, 2-(2-butoxyethoxy)-
112-35-6 Triethylene glycol methyl ether
112-39-0 Methyl palmitate
112-42-5 1-Undecanol
112-50-5 Triethylene glycol ethyl ether
112-53-8 Lauryl alcohol
112-54-9 Dodecanal
112-55-0 Dodecyl mercaptan
112567-52-9 Naphthalenesulfonic acid, bis(1-methylpropyl)-, sodium salt
112-57-2 Tetraethylenepentamine
112-60-7 Ethanol, 2,2'-[oxybis(2,1-ethanediyloxy)]bis-
112-61-8 Methyl stearate
112-62-9 9-Octadecenoic acid (Z)-, methyl ester
112-63-0 Linoleic acid, methyl ester
Page 7 of 93
112-69-6 1-Hexadecanamine, N,N-dimethyl-
112-70-9 Tridecyl alcohol
112-80-1 Oleic acid
112-85-6 Behenic acid
112-88-9 1-Octadecene
112-90-3 Oleylamine
112-92-5 Stearyl alcohol
112926-00-8 Silica gel, pptd., cryst.-free
112945-52-5 Silica, amorphous, fumed, cryst. -free
113133-74-7 2-Propenoic acid, polymers with acrylic acid-iso-pr alc. reaction products
α-(1,1,3,3-Tetramethylbutyl)phenoxy-omega-polyoxypropylene block polymer
113213-81-3 with polyoxylethylene
113221-69-5 Maleic anhydride, polymer with ethyl acrylate and vinyl acetate, hydrolyzed
113-48-4 5-Norbornene-2,3-dicarboximide, N-(2-ethylhexyl)-
113609-83-9 Oxirane, methyl-, polymer with oxirane, mono(4-nonylphenyl) ether, block
113652-56-5 1-octanesulfonic-2- sulfinic acid
113669-58-2 1,2-Octanedisulfonic acid
113894-85-2 Amylopectin, acid-hydrolyzed, 1-octenylbutanedioate
2-Propenoic acid, polymer with 2-propanol, reaction products with sodium
114033-68-0 acrylate
Hexanedioic acid, polymer with N-(2-aminoethyl)-1,3-propanediamine,
aziridine, (chloromethyl)oxirane, 1,2-ethanediamine, N,N''-1,2-
ethanediylbis?1,3-propanediamineU,formic acid and alpha-hydro-omega-
114133-44-7 hydroxypoly(oxy-1,2-ethanediyl)
114355-33-8 Polyamine-epichlorohydrin resin
Poly(oxy-1,2-ethanediyl), alpha-phosphono-omega-[2,4,6-tris(1-
114535-82-9 phenylethyl)phenoxy]-
114795-97-0 Dodecylbenzenesulfonic acid, compd. with 1,2-propanediamine (1:1)
115-10-6 Dimethyl ether
115321-78-3 Iron chloride (FeCl3), hydrate (2:3)
115-39-9 Phenol, 4,4'-(3H-2,1-benzoxathiol-3-ylidene)bis(2,6-dibromo-, S,S-dioxide
2-Propenoic acid, 2-methyl-, butyl ester, telomer with 2-[(1,1-
dimethylethyl)amino]ethyl 2-methyl-2-propenoate, 1-dodecanethiol,methyl 2-
methyl-2-propenoate and rel-(1R,2R,4R)-1,7,7-trimethylbicyclo[2.2.1]hept-2-
115593-69-6 yl 2-methyl-2-propenoate
115-77-5 Pentaerythritol
Cyclohexanemethanamine, 5-amino-1,3,3-trimethyl-, polymer with
(chloromethyl)oxirane, 4,4'-(1-methylethylidene)bis(phenol) and C,C,C-
115793-94-7 trimethyl-1,6-hexanediamine
115-83-3 Pentaerythritol tetrastearate
115-86-6 Phosphoric acid, triphenyl ester
115-95-7 Linalool acetate
1163-19-5 Benzene, 1.1'-oxybis[2,3,4,5,6-pentabromo-
116469-86-4 Wheat bran
116-75-6 9,10-Anthracenedione, 1,4-bis{(2,4,6-trimethylphenyl)amino}-
Page 8 of 93
Siloxanes and silicones, 3-hydroxypropyl Me, ethers with polyethylene glycol
117272-76-1 mono-Me ether
117-81-7 1,2-Benzenedicarboxylic acid, bis(2-ethylhexyl) ester (List 1 Inert)
117-84-0 Dioctyl phthalate
117875-77-1 Sulfuric acid, mono-C10-16-alkyl esters, compds. with triethanolamine
117989-77-2 Oxirane, methyl-, polymer with oxirane, monobutyl ether, block
118-47-8 1H-Pyrazole-3-carboxyliccid, 4,5-dihydro-5-oxo-1-(4-sulfophenyl)-
118-56-9 Homomenthyl salicylate
118-58-1 Benzyl salicylate
118-60-5 2-Ethylhexyl salicylate
118-71-8 4H-Pyran-4-one, 3-hydroxy-2-methyl-
118-93-4 Ethanone, 1-(2-hydroxyphenyl)- (tolerance exemption is pending)
119060-15-0 D-Glucitol, 1-deoxy-1(methylamino)-, N-C16 acyl derivs.
1191-50-0 Sodium tetradecyl sulfate
2-Propenoic acid, 2-methyl-, cyclohexyl ester, polymer with 2-hydroxyethyl 2-
methyl-2-propenoate, isodecyl 2-methyl-2-propenoate, and 2-(4-
119239-21-3 morpholinyl)ethyl 2-methyl-2-propenoate
119345-04-9 Benzene, 1,1'-oxybis-, tetrapropylene derivs., sulfonated, sodium salts
119-36-8 Methyl salicylate
Poly(oxy-1,2-ethanediyl), α-sulfo-ω-[2,4,6-tris(1-phenylethyl)phenoxy]-
119432-41-6 ,ammonium salt
119-47-1 2,2'-Methylenebis(4-methyl-6-tert-butylphenol)
119-61-9 Benzophenone
2-Propenoic acid, 2-methyl-, polymer with α-methyl-ω-
119724-54-8 hydroxypoly(oxy-1,2-ethanediyl) and methyl 2-methyl-2-propenoate, graft
12001-26-2 Mica-group minerals
12001-27-3 Lime (chemical) dolomitic
12001-27-3 Magnesium lime
12001-76-2 Vitamin B
12001-85-3 Zinc naphthenate
12002-43-6 Gilsonite
12003-38-2 Mica
12003-51-9 Silicic acid (H4SiO4), aluminum sodium salt (1:1:1)
12008-41-2 Disodium octaborate
120-32-1 2-Benzyl 4-chlorophenol
120-36-5 2-(2,4-Dichlorophenoxy)propionic acid
120-40-1 Lauric acid diethanolamide
12042-91-0 Aluminum chlorohydrate (Al2 (OH)5 Cl)
12045-78-2 Potassium borate tetrahydrate
12045-88-4 Boron sodium oxide (B4Na2O7), pentahydrate
120-46-7 Dibenzoylmethane
120-47-8 Ethyl p-hydroxybenzoate
120-51-4 Benzyl benzoate
120-55-8 Diethylene glycol, dibenzoate
120-56-9 Ethanol, 2,2'-[1,2-ethanediylbis(oxy)]bis-, dibenzoate
Page 9 of 93
120-57-0 1,3-Benzodioxole-5-carboxaldehyde
12058-66-1 Sodium stannate
12063-19-3 Zinc iron oxide
120-65-0 2-((Dimethylamino)methyl)phenol
12068-03-0 Sodium toluenesulfonate
12068-04-1 Isopropylamine methylnaphthalene sulfonate
12068-07-4 Dodecylbenzenesulfonic acid, 1,2-propylenediamine salt
12068-08-5 Morpholine dodecylbenzenesulfonate
12068-09-6 Butylamine dodecylbenzenesulfonate
12068-13-2 1,1,2,3-Tetramethylbutylamine dodecylbenzenesulfonate
12068-15-4 Strontium dodecylbenzene sulfonate
12068-17-6 Sodium dodecylphenoxybenzene disulfonate
12068-86-9 Iron magnesium oxide (Fe2MgO4) (For colorant use only)
12069-69-1 Copper carbonate
120-72-9 1H-Indole
120-94-5 N-Methylpyrrolidine
120962-03-0 Canola oil
121116-34-5 Poly (oxy-1,2-ethanediyl), alpha-methyl-omega-[(2-methyl-2-propenyl) oxy]-
12124-97-9 Ammonium bromide
12125-02-9 Ammonium chloride
12125-28-9 Magnesium carbonate hydroxide
121-32-4 Ethylvanillin
121-33-5 Benzaldehyde, 4-hydroxy-3-methoxy-
12141-46-7 Aluminum oxide silicate
12142-33-5 Stannate (SnO3(2-)), dipotassium
1214-39-7 1H-Purin-6-amine, N-(phenylmethyl)-
121-44-8 Triethylamine
121-54-0 Diisobutylphenoxyethoxyethyl dimethyl benzyl ammonium chloride
Poly(oxy-1,2-ethanediyl), α-sulfo-ω-hydroxy-, C12-15-alkyl ethers, sodium
121546-77-8 salts
12167-74-7 Calcium hydroxide phosphate (Ca5(OH)(PO4)3)
12168-85-3 Calcium oxide silicate (Ca3O(SiO4))
1217-08-9 1H-Indene-5-ethanol, 2,3-dihydro-beta,1,1,2,3,3-hexamethyl-
12173-47-6 Hectorite
12174-11-7 Attapulgite
12174-11-7 Attapulgite-type clay
121776-33-8 3-(Dichloroacetyl)-5-(2-furanyl)-2,2-dimethyloxazolidine
12179-04-3 Boric acid (H2B4O7), disodium salt, pentaborate
121-79-9 Propyl gallate
Quaternary ammonium compounds, benzylbis (hydrogenated tallow
alkyl)methyl, bis(hydrogenated tallow alkyl)dimethylammonium salt with
121888-67-3 hectorite
Quaternary ammonium compounds, benzyl (hydrogenated tallow alkyl)
121888-68-4 dimethyl, stearates, salts with bentonite
121-91-5 Isophthalic acid
Page 10 of 93
12199-37-0 Smectite-group minerals
12207-97-5 Magnesium oxide silicate (Mg3O(Si2O5)2), monohydrate
12217-48-0 C.I. Basic Red 14
122-19-0 Stearyl dimethyl benzyl ammonium chloride
12219-26-0 C.I. Acid Blue 182
122-20-3 Triisopropanolamine
3-((4-Amino-9,10-dihydro-9,10-dioxo-3-(sulfo-4-(1,1,3,3-
tetramethylbutyl)phenoxy)-1-anthracenyl)amino)-2,4,6-
12220-51-8 trimethylbenzenesulfonic acid disodium salt
1222-05-5 Cyclopenta{g}-2-benzopyran,1,3,4,6,7,8-hexahydro-4,6,6,7,8,8-hexamethyl-
12222-04-7 C.I. Direct Blue 199
12225-18-2 C.I. Pigment Yellow 97
12225-21-7 FD&C Yellow No. 5 aluminum lake
12227-62-2 C.I. Pigment Red 193
Butanamide, 2-{(4-chloro-2-nitrophenyl)azo}-N-(2,3-dihydro-2-oxo-1H-
12236-62-3 benzimidazol-5-yl)-3-oxo-
12239-87-1 Copper, {C-chloro-29H,31H-phthalocyaninato(2-)-N29,N30,N31,N32}-
122-40-7 Heptanal, 2-(phenylmethylene)-
Benzenesulfonic acid, 4-amino-, polymer with formaldehyde and 3-
122436-67-3 methylphenol
122-51-0 Triethoxymethane
12251-44-4 Orthoclase
122-57-6 3-Buten-2-one, 4-phenyl-
12259-21-1 Iron oxide (Fe2O3), hydrate
12269-78-2 Pyrophyllite (AlH(SiO3)2)
12270-13-2 C.I. Basic Blue 41
12271-01-1 C.I. Solvent Yellow 85
122-78-1 Benzeneacetaldehyde
12280-03-4 Disodium octaborate, tetrahydrate
122-99-6 Phenoxy ethanol
123-11-5 Benzaldehyde, 4-methoxy-
123-17-1 Trimethylnonyl-4-alcohol
123175-37-1 Lignosulfonic acid, ammonium magnesium salt
123-25-1 Butanoic acid, diethylester-
123-26-2 N,N'-Ethylenebis-12-hydroxystearamide
123-31-9 1,4-Benzenediol
123-38-6 Propionaldehyde
123-42-2 Diacetone alcohol
123465-33-8 Glycerides, C8-12
123-66-0 Ethyl hexanoate
123-77-3 Azodicarbonamide
123-79-5 Adipic acid, dioctyl ester
123-86-4 Butyl acetate
12389-75-2 Sodium ferric diethylenetriaminepentaacetate
123-92-2 1-Butanol, 3-methyl-, acetate
Page 11 of 93
123-94-4 Octadecanoic acid, 2,3-dihydroxypropyl ester
123-95-5 Octadecanoic acid, butyl ester
123-95-5 Butyl stearate
124018-38-8 Fatty acids, canola-oil
124-04-9 Adipic acid
124-07-2 Octanoic acid
124-10-7 Methyl tetradecanoate
124-13-0 Octanal
124-16-3 Butoxyethoxypropanol
1241-94-7 Phosphoric acid, decyl diphenyl ester
124-22-1 1-Dodecanamine
12427-27-9 Perlite
124-28-7 Dimethyloctadecylamine
124-38-9 Carbon dioxide
124-40-3 Dimethylamine
124-41-4 Sodium methylate
124-68-5 2-Amino-2-methyl-1-propanol
124-76-5 Isoborneol
125109-81-1 Amylopectin, hydrogen 1-octadecenylbutanedioate
12511-31-8 Aluminum magnesium silicate
125-12-2 Isobornyl acetate
125220-70-4 Benzenesulfonic acid, dodecyl-, compd. with 1,3-propanediamine
125279-66-5 Poly(oxy-1,2-ethanediyl, alpha-(tripropylenephenyl)-omega-hydroxy-
Poly(oxy-1,2-ethanediyl), alpha,alpha'-phosphinicobis[omega-[2,4,6-tris(1-
125302-22-9 phenylethyl)phenoxy]-
Castor oil, hydrogenated, polymer with adipic acid, ethylenediamine and 12-
125303-89-1 hydroxyoctadecanoic ac
1254-78-0 Phenyl didecyl phosphite
125496-22-2 Isoarachidyl neopentanoate
125590-73-0 alpha-D-Glucopyranoside, 2-ethylhexyl
Hexanedioic acid, polymer with 2,2-dimethyl-1,3-propanediol, 1,6-hexanediol,
125826-44-0 hydrazine, 3-hydro
Poly(oxy-1,2-ethandiyl),α-acetyl-ω-{3-{1,3,3,3-tetramethyl-1-
125997-17-3 {(trimethylsilyl)oxy}d
126-14-7 Sucrose octaacetate
126-30-7 Poly(oxy-1,2-ethanediyl),α,α',α'',α'''-[1,2-ethanediylbis[(3-sulfo-4,1-
Poly(oxy-1,2-ethanediyl), α,α',α'',α'''-[[[4-
(dimethylamino)phenyl]methyliumdiyl]bis(4,1-phenylenenitrilodi-2,1-
126324-38-7 ethanediyl)]tetrakis[ω-hydroxy-
12656-57-4 C.I. Pigment Orange 20
12656-85-8 C.I. Pigment Red 104
126-73-8 Tributyl phosphate
12676-37-8 Sodium N-coco beta-aminopropionate (No established approval)
126-86-3 5-Decyne-4,7-diol, 2,4,7,9-tetramethyl-
126-92-1 Sodium 2-ethylhexyl sulfate
Page 12 of 93
12694-22-3 9-Octadecanoic acid, monoester with oxybis(propanediol)
12694-22-3 9-Octadecanoic acid, monoester with oxybis (propanediol)
126-96-5 Acetic acid, sodium salt (2:1)
127036-24-2 Poly(oxy-1,2-ethanediyl),α-undecyl-ω-hydroxy-, branched and linear
127-08-2 Acetic acid, potassium salt
127087-87-0 Poly(oxy-1,2-ethanediyl), α-(4-nonylphenyl)-ω-hydroxy-, branched
127-09-3 Sodium acetate
12710-04-2 Lignosulfonic acid, ammonium calcium salt
12713-03-0 Burnt umber
127184-52-5 Benzenesulfonic acid, 4-C10-13-sec-alkyl derivs., sodium salts
127252-82-8 Ethoxylated methyl beta-glucopyranoside dioleate
12736-96-8 Silicic acid, aluminum potassium sodium salt
127-39-9 Sodium 1,4-diisobutyl sulfosuccinate
127-41-3 alpha-Ionone
127-47-9 Retinol acetate
12751-36-9 Pharmamedia
127-51-5 3-Buten-2-one, 3-methyl-4-(2,6,6-trimethyl-2-cyclohexen-1-yl)-
Benzenepropanoic acid, 3-(2H-benzotriazol-2-yl)-5-(1,1-dimethylethyl)-4-
127519-17-9 hydroxy-, C7-9-branched
127646-44-0 Naphthalenesulfonic acid, iso-Pr derivs, sodium salts
12768-78-4 C.I. Acid Green 16
12788-84-0 Sodium salt of n-coco beta amino butric acid
12788-93-1 n-Butyl acid phosphate
127-91-3 Bicyclo[3.1.1]heptane, 6,6-dimethyl-2-methylene-
Siloxanes and Silicones, di-Me, 3-hydroxypropyl Me, 3-hydroxypropyl group-
128192-17-6 terminated, ethoxylated propoxylated
128-37-0 Phenol, 2,6-bis(1,1-dimethylethyl)-4-methyl-
128446-33-3 .alpha.-Cyclodextrin, 2-hydroxypropyl ethers
128446-36-6 .beta.-Cyclodextrin, methyl ethers
128-44-9 Sodium 1,1-dioxide benzisothiazol-3(H)-one
128497-20-1 Oils, macadamia
128-80-3 1,4-Di-p-toluidinoanthraquinone
128-95-0 C.I. Disperse Violet 1
129037-80-5 Ball Powder
129-17-9 C.I. Acid Blue 1, sodium salt
129291-73-2 Disodium dodecylimidazolinum dicarboxylate
2- Propenoic acid, 2-methyl-, 2-methylpropyl ester, polymer with 2- propenoic
129702-02-9 acid and N-(1,1,3,3- tetramethylbutyl)-2-propenamide
Decanedioic acid, bis(2,2,6,6-tetramethyl-4-piperidinyl) ester, reaction
129757-67-1 products with tert-Bu hy
13006-05-8 Sulfuric acid, monooctadecyl ester, magnesium salt
1300-72-7 Sodium xylene sulfonate
1302-42-7 Sodium aluminate
1302-78-9 Bentonite
Page 13 of 93
13035-04-6 2-Naphthalenesulfonic acid, 6-methyl-, sodium salt
2-Propenenitrile, polymer with diethenylbenzene, ethenylethylbenzene and 1,7-
130353-60-5 octadiene, hydrolyzed
1303-86-2 Boron oxide (B2O3)
1303-96-4 Borax (Na2B4O7.10H2O) (1303-96-4)
13040-18-1 Decanoic acid, potassium salt
130498-22-5 Wheat flour
Poly(oxy-1,2-ethanediyl(dimethyliminio)-1,3-propanediyliminocarbonylimino-
1,3-propanediyl(dimethyliminio)-1,2-ethanediyl dichloride), α-(2-chloroethyl)-
130547-87-4 ω-(2-chloroethoxy)-
1305-62-0 Calcium hydroxide
1305-78-8 Calcium oxide (CaO)
1306-05-4 Fluorapatite
13081-34-0 Polyoxyethylene* dodecylmercaptan *(8-12 moles)
1308-14-1 Chromium hydroxide (Cr(OH)3)
Octadecanoic acid, 2-2,bis(hydroxymethyl)-1,3-propanediyl ester (clearance
13081-97-5 pending)
1308-38-9 Chrome oxide (Cr2O3)
130885-09-5 Perlite
13092-66-5 Magnesium phosphate, monobasic
1309-33-7 Ferric hydroxide
1309-37-1 Iron oxide (Fe2O3)
1309-42-8 Magnesium hydroxide (Mg(OH)2)
1309-48-4 Magnesium oxide
1309-64-4 Antimony trioxide
1310-58-3 Potassium hydroxide (K(OH))
1310-73-2 Sodium hydroxide (Na(OH))
131-11-3 Dimethyl phthalate
131-17-9 Diallyl phthalate
1312-76-1 Potassium silicate
13127-82-7 Oleyl diethanolamide
1313-13-9 Manganese oxide (MnO2)
131324-06-6 Poly(difluoromethylene), alpha-chloro-omega-(1-chloro-1-fluoroethyl)-
1314-13-2 Zinc oxide (ZnO)
131-55-5 2,2',4,4'-Tetrahydroxybenzophenone
131-56-6 Methanone, (2,4-dihydroxyphenyl)phenyl-
131-57-7 Methanone, (2-hydroxy-4-methoxyphenyl)phenyl-
1317-33-5 Molybdenum disulfide
1317-39-1 Cuprous oxide
1317-60-8 Hematite (Fe2O3)
1317-61-9 Iron oxide (Fe3O4)
1317-63-1 Limonite
1317-65-3 Limestone
13177-52-1 Sulfuric acid, monodecyl ester, ammonium salt
1317-95-9 Tripoli
Page 14 of 93
1318-00-9 Vermiculite
1318-02-1 Zeolites (excluding erionite (CAS Reg. No. 66733-21-9))
1318-23-6 Boehmite (Al(OH)O)
1318-74-7 Kaolinite (Al2(OH)4(Si2O5))
1318-93-0 Montmorillonite
1319-77-3 Cresol
1320-06-5 2-Naphthalenol, 1-{{4-{(dimethylphenyl)azo}dimethylphenyl}azo}-
Benzenesulfonic acid, 4-{{3-{(dimethylphenyl)azo}-2,4-
1320-07-6 dihydroxyphenyl}azo}-, monosodium salt
1320-37-2 Dichlorotetrafluoroethane
1321-69-3 Naphthalenesulfonic acid, sodium salt
1321-74-0 Divinyl benzene
Polyethylene glycol-polyisobutenyl anhydride-tall oil fatty acid copolymer
132175-04-3 (minimum number averag
132-27-4 Sodium 2-phenylphenate
1322-93-6 Sodium diisopropylnaphthalene sulfonate
1322-98-1 Sodium decylbenzene sulfonate
1323-19-9 Sodium triisopropylnaphthalene sulfonate
9-Octadecenoic acid, 12-hydroxy-, (9Z,12R)-, monoester with 1,2,3-
1323-38-2 propanetriol
Glycine, N,N'-1,2-ethanediylbis[N-(carboxymethyl)-, tetrasodium salt,
13235-36-4 tetrahydrate
1323-83-7 Glyceryl distearate
132-43-4 Taurine, N-cyclohexyl-N-palmitoyl-, sodium salt
132538-94-4 Oils, orange-juice, citrus sinensis
13254-34-7 2-Heptanol, 2,6-dimethyl-
Alpha-{2,4,6-Tris{1-(phenyl)ethyl}phenyl}-omega-
132580-45-1 hydroxypoly(oxyethylene)poly(oxypropylene)copolym
Fatty acids, coco, reaction products with 2-{(2-aminoethyl)amino}ethanol,
132647-09-7 bis(2-carboxyethyl)deri
1327-36-2 Aluminatesilicate
1327-41-9 Aluminum chloride, basic
1327-43-1 Silicic acid, aluminum magnesium salt
1327-44-2 Potassium aluminum silicate, anhydrous
132778-08-6 D-Glucopyranose, oligomeric, C9-11-alkyl glycosides
1328-53-6 C.I. Pigment Green 7
1330-20-7 Xylene
1330-38-7 Copper, (dihydrogen phthalocyaninedisulfonato(2-)), disodium salt
1330-43-4 Boron sodium oxide (B4Na2O7)
133-07-3 N-(Trichloromethylthio)phthalamide
1330-76-3 Dioctyl-2-butenedioate
1330-80-9 Propylene glycol monooleate
1331-61-9 Dodecylbenzenesulfonic acid, ammonium salt
1332-09-8 Pumice
1332-37-2 Iron oxide
Page 15 of 93
1332-58-7 Kaolin
1333-86-4 Carbon black
133-42-6 Gluconic acid
1335-30-4 Aluminum silicate
1335-46-2 Ionone, methyl-
1336-08-9 Aluminum oxide silicate (Al2O(SiO4))
1336-21-6 Ammonium hydroxide ((NH4)(OH))
1336-36-3 Chlorinated biphenyl
Spiro{bicyclo{3.1.1}heptane-3,1'-{2}cyclohexen}-4'-one,2,6,6-trimethyl-
133636-82-5 ,{1S-(1α,2.beta.,3.
1336-93-2 Manganese naphthenate
1338-02-9 Copper naphthenate
1338-24-5 Naphthenic acid
1338-39-2 Sorbitan monolaurate
1338-41-6 Sorbitan monostearate
1338-43-8 Sorbitan monooleate
13393-71-0 1-Pentadecanol, hydrogen sulfate, sodium salt
13397-24-5 Gypsum (Ca(SO4).2H2O)
13397-26-7 Calcite (Ca(Co3))
134-03-2 Sodium ascorbate
134134-87-5 Proteins, specific of class, oat
Oxirane, methyl-,polymer with oxirane, mono[3-[1,3,3,3-tetramethyl-1-
134180-76-0 [(trimethylsilyl)oxy]disil
13419-37-9 1-Tetradecanol, hydrogen sulfate, potassium salt
13419-59-5 Trisodium sulfosuccinate
13429-27-1 Tetradecanoic acid, potassium salt
134-31-6 8-Quinolinol sulfate
13438-45-4 Benzenesulfonic acid, 4-methyl-, zinc salt
1343-88-0 Magnesium silicate
1343-90-4 Magnesium silicate hydrate
1343-98-2 Silicic acid
1344-00-9 Silicic acid, aluminum sodium salt
1344-09-8 Sodium silicate
1344-28-1 Aluminum oxide (Al2O3)
1344-43-0 Manganous oxide
13446-18-9 Magnesium(II) nitrate (1:2), hexahydrate
1344-67-8 Copper chloride
1344-95-2 Silicic acid, calcium salt
1344-98-5 C.I. Pigment Green 23
13450-80-1 Sulfuric acid, iron(2+) salt (1:1), pentahydrate
1345-25-1 Iron oxide (FeO)
13453-71-9 Lithium chlorate
13463-41-7 Zinc 2-pyridinethiol-1-oxide
13463-67-7 Titanium oxide (TiO2)
13463-98-4 Calcium abietate
Page 16 of 93
13472-39-4 Sulfuric acid disodium salt, heptahydrate
13475-82-6 Heptane, 2,2,4,6,6-pentamethyl-
13477-29-7 Calcium chloride (CaCl2), monohydrate
13477-39-9 Metaphosphoric acid (HPO3), calcium salt
135-19-3 2-Naphthol
135-37-5 Glycine, N-(carboxymethyl)-N-(2-hydroxyethyl)-, disodium salt
13547-17-6 Urea, N,N"-methylenebis-
Diethyl-1-(2,4-dichlorophenyl)-5-methyl-2-pyrazolin-3,5-dicarboxylate
135590-91-9 (Mefenpyr-diethyl)
136303-47-4 Sollac PPA
136445-69-7 Alkenes, C>10 α-, polymers with vinylpyrrolidone
136-51-6 Hexanoic acid, 2-ethyl,- calcium salt
136-52-7 Cobalt 2-ethylhexanoate
136-53-8 Zinc 2-ethylhexoate
13693-11-3 Titanium sulfate
.beta.-Alanine,N-(2,4-dihydroxy-3,3-dimethyl-1-oxobutyl)-, calcium salt (2:1),
137-08-6 (R)-
Actic acid ethenyl ester,polymer with ethanol and alpha-2-propenyl-omega-
137091-12-4 hydroxypoly(oxy-1,2-etha
137-16-6 Glycine, N-methyl-N-(1-oxododecyl)-, sodium salt
13717-00-5 Magnesite
137-20-2 Sodium N-cis-1-oxo-9-octadecenyl-N-methyltaurine
13721-43-2 Sodium hypophosphate
137-30-4 Zinc dimethyldithiocarbamate
137-40-6 Sodium propionate
13747-30-3 Decanoic acid, calcium salt
13759-92-7 Europium chloride (EuCl3), hexahydrate
137-66-6 Ascorbyl palmitate
137672-70-9 Soprophor 4D384
13776-74-4 Silicic acid (H2SiO3), magnesium salt (1:1)
Poly{oxy(methyl-1,2-ethanediyl)}, α-{2-(trimethylammonio)ethyl}- ω-
138003-56-2 hydroxy-, chlor
13822-56-5 1-Propanamine, 3-(trimethoxysilyl)-
138-22-7 Lactic acid-, n-butyl ester
13840-33-0 Lithium hypochlorite
13845-18-6 Sodium sulfamate
13845-36-8 Potassium tripolyphosphate
Benzenesulfonic acid, 2,2'-(1,2-ethanediyl)bis[5-[[4-[(2-
hydroxyethyl)methylamino]-6-(phenylamino)-1,3,5-triazin-2-yl]amino]-,
13863-31-5 disodium salt
13870-28-5 Silicic acid (H2Si2O5), disodium salt
13870-29-6 Disulfuric acid, disodium salt
138-86-3 Cyclohexene, 1-methyl-4-(1-methylethenyl)-
139-05-9 Sodium cyclamate
Page 17 of 93
139-08-2 N,N-Dimethyl-N-tetradecylbenzenemethaneaminium chloride
139-13-9 Aminotriethanoic acid
Fatty acids, tall oil,polymers with bisphenol A, epichlorohydrin, ethylene-
139168-80-2 manuf.-by-product di
139-44-6 Glyceryl tris(12-hydroxystearate)
13961-86-9 Diethanolamine oleate
13983-17-0 Wollastonite (Ca(SiO3))
13983-17-0 Soapbark (Quillaja saponin)
13986-24-8 Sulfuric acid, zinc salt (1:1), hexahydrate
139871-83-3 2-Butenedioic acid (Z)-, polymer with ethenol and ethenyl acetate, sodium salt
139-87-7 Ethyl diethanolamine
139-88-8 Sodium tetradecyl sulfate
139895-03-7 Diethoxylated methyl .alpha.-glucopyranoside 2,6-dioleate
139-89-9 Trisodium (2-hydroxyethyl)ethylenediaminetriacetate
139-96-8 Triethanolamine lauryl sulfate
140-01-2 Pentasodium diethylenetriaminepentaacetate
140-11-4 Benzyl acetate
1401-55-4 Tannic acid
14025-15-1 Ethylenediaminetetraacetic acid (EDTA), disodium copper(II) salt
Potassium 3-(2-(2-((2-(2-
14025-21-9 hydroxyethyl)ethyl)octadecylamino)ethoxy)propionate
14038-43-8 C.I. Blue Pigment 27
1406-18-4 Vitamin E
140-66-9 4-(1,1,3,3-Tetramethylbutyl)phenol
140-95-4 N,N'-bis(Hydroxymethyl)urea
141-04-8 Diisobutyl adipate
141-22-0 9-Octadecenoic acid, 12-hydroxy-, (9Z,12R)-
141-32-2 Butyl acrylate
2-Propenoic acid, polymer with ethenylbenzene and 2-methyl-2-[(1-oxo-2-
141370-38-9 propenyl}amino]-1-propanesulfonic acid, sodium salt
141-43-5 Ethanol, 2-amino-
141-53-7 Sodium formate
1415-93-6 Humic acids
14167-87-4 Decyl diphenyl phosphate
14168-73-1 Sulfuric acid magnesium salt (1:1), monohydrate
141754-64-5 2-Propenoic acid, telomer with 2-propanol, ammonium salt
141-78-6 Ethyl acetate
141-79-7 Mesityl oxide
141-97-9 Butanoic acid, 3-oxo-, ethyl ester
142-03-0 Aluminum acetate, basic
142-15-4 Sodium isethionate, oleic acid ester
142-17-6 9-Octadecenoic acid (9Z)-, calcium salt
142-18-7 Dodecanoic acid, 2, 3-dihydroxypropyl ester
142-31-4 Sodium octyl sulfate
14233-37-5 C.I. Solvent Blue 36
Page 18 of 93
142-47-2 Monosodium glutamate
142-48-3 Glycine, N-methyl-N-(1-oxooctadecyl)-
142540-51-0 Pylam Oil Yellow
142-62-1 Hexanoic acid
142-71-2 Copper acetate
142-72-3 Acetic acid, magnesium salt
142-78-9 N-(2-Hydroxyethyl)dodecanamide
142-82-5 Heptane
142-87-0 Sulfuric acid, monodecyl ester, sodium salt
142-91-6 Isopropyl palmitate
14297-82-6 Chrysanthemic anhydride
142-98-3 Sulfuric acid, monodecy ester
Copper, {1,3,8,16,18,24-hexabromo-2,4,9,10,11,15,17,22,23,25,-decachloro-
14302-13-7 29H,31H-phthalocyaninato(2-)-N29,N30,N31,N32}-,(SP-4-2)-
143-03-3 Sulfuric acid, monooctadecyl ester
143-07-7 Lauric acid
143-08-8 1-Nonanol
143-18-0 Octadecenoic acid (9Z)-, potassium salt
143-19-1 Sodium oleate
143-28-2 Oleyl alcohol
14351-50-9 Dimethylcocoamine oxide
14351-66-7 Sodium salt of rosin
14356-36-6 4-Dodecylbenzenesulfonic acid, butylamine salt
143-74-8 Phenol Red
Poly(oxy-1,2-ethanediyl), α-hydro-ω-hydroxy-, monoether with
143819-63-0 (hydroxymethyl)decane
Acetic acid ethenyl ester, polymer with 2-methyl-3-[(1-propenyl) amino] -1-
144097-18-7 propanesulfonic acid monosodium salt
144-33-2 1,2,3-Propanetricarboxylic acid, 2-hydroxy- disodium salt
144538-83-0 Aspartic acid, N-(1,2-dicarboxyethyl)-, tetrasodium salt
144-55-8 Sodium bicarbonate
144-62-7 Oxalic acid
14464-46-1 Cristobalite
14492-68-3 Pyridinium, 1-(((2-hydroxyethyl)carbamoyl)methyl)-, chloride, stearate
14548-60-8 Benzyl hemiformal (approval pending do not use)
145578-88-7 Naphthalenesulfonic acid, Bu derivs, sodium salts
14576-08-0 Cyclohexene,4-(1-methoxy-1-methylethyl)-1-methyl-
146340-15-0 Alcohols, C12-14-secondary, beta-(2-hydroxyethoxy-, Ethoxylated (POE-10)
Siloxanes and silicones, di-Me, Bu group- and 3-{(2-methyl-1-oxo-2-
146632-08-8 propenyl)oxy}propyl group-te
2-Propenoic acid, 2-methyl-, polymer with ethenylbenzene, 2-ethylhexyl 2-
propenoate, 2-hydroxyethyl 2-propenoate, N-(hydroxymethyl) -2-methyl-2-
146753-99-3 propenamide and methyl 2-methyl-2-propenoate, ammonium salt
147-14-8 Copper, {29H,31H-phthalocyaninato(2-)-N29,N30,N31,N32}-, (SP-4-1)-
14729-89-6 Disodium ferrous ethylenediaminetetraacetate
Page 19 of 93
14765-30-1 Cyclohexanone, 2-(1-methylpropyl)-
147-81-9 Arabinose
147900-93-4 Fatty acids, C18-unsatd.,trimers, compds. with oleylamine
14807-96-6 Talc (Mg3H2(SiO3)4)
14808-60-7 Quartz (SiO2)
Amines, tallow alkyl, ethoxylated, compds. with polyethylene glycol hydrogen
148373-01-7 sulfate nonylphenyl ether
14899-09-3 Xanthylium, 3,6-bis(diethylamino)-9-(2-(ethoxycarbonyl)phenyl)-, chloride
14901-07-6 3-Buten-2-one, 4-(2,6,6-trimethyl-1-cyclohexen-1-yl)-
149022-20-8 5'-Adenylic acid, sodium salt, hydrate
14906-97-9 D-Gluconic acid, sodium salt
149-30-4 2-Mercaptobenzothiazole
149-44-0 Methanesulfinic acid, hydroxy-, monosodium salt
149458-07-1 Fatty acids, C12-18, Me esters, sulfonated, sodium salts
149-57-5 Hexanoic acid, 2-ethyl-
14960-06-6 .beta.-Alanine, N-(2-carboxyethyl)-N-dodecyl-, monosodium salt
14977-37-8 Potassium magnesium sulfate (Mg2K2(SO4)3)
14987-04-3 Magnesium silicon oxide (Mg2Si3O8)
14989-29-8 Magnesium chloride
150-13-0 4-Aminobenzoic acid
150-25-4 N,N-(2-Dihydroxyethyl) glycine
150-38-9 Trisodium ethylenediaminetetraacetate
15046-75-0 Benzenesulfonic acid, 2-methyl-, sodium salt
15059-52-6 Dysprosium chloride (DyCl3), hexahydrate
1506-02-1 6-Acetyl-1,1,2,4,4,7-hexamethyl tetralin
Poly(oxy-1,2-ethanediyl), alpha-(carboxymethyl)-omega-(4-nonylphenoxy)- ,
150678-63-0 branched
150-76-5 p-Methoxyphenol
2-Propenoic acid, telomer with 2-methyl-2-((1-oxo-2-propenyl)amino)-1-
propanesulfonic acid monosodium salt, sodium 4-ethenylbenzenesulfonate and
151006-66-5 sodium hydrogen sulfite, sodium salt
151-05-3 Dimethylbenzylcarbinyl acetate
151-21-3 Sodium lauryl sulfate
151-41-7 Lauryl sulfate
2-Propenoic acid, 2-methyl-, telomer with 2-propanol and 2-propenoic acid,
151574-10-6 sodium salt
15163-46-9 Benzenesulfonic acid, 2-dodecyl-, sodium salt
D-Glucopyranose, oligomeric, 6-(dihydrogen 2-hydroxy-1,2,,3-
151911-51-2 propanetricarboxylate), 1-(coco alkyl) ethers, sodium salts
Poly(oxy-1,2-ethanediyl), alpha-(4-nonylphenyl)-omega-hydroxy-, branched,
152143-22-1 phosphates
15245-12-2 Nitric acid, ammonium calcium salt
152698-66-3 Distillates (petroleum), C3-6, piperylene-rich, polymers with isobutylene
15284-51-2 Tetradecanoic acid, calcium salt
Page 20 of 93
2-Propenoic acid, 2-methyl-, polymer with butyl 2-propenoate, methyl 2-
methyl-2-propenoate, methyl 2-propenoate and 2-propenoic acid, graft,
153163-36-1 compd. with 2-amino-2-methyl-1-propanol
1533-45-5 4,4'-Di (benzoxazol-2-yl) stilbene
15375-84-5 Ethylenediaminetetraacetic acid (EDTA), disodium manganese (II) salt
15414-89-8 1,3-Dimethyl-5,5-dimethylhydantoin
1541-81-7 Morpholine, 4-dodecyl-
154518-36-2 Alcohols, C9-11-iso-, C10-rich, ethoxylated propoxylated
15468-32-3 Silica, crystalline - tridymite
15537-82-3 Hypophosphoric acid, sodium salt
1555-53-9 9-Octadecenoic acid (9Z)-, magnesium salt
1559-34-8 Tetraethylene glycol butyl ether
15593-82-5 Silicic acid (H6Si2O7), hexasodium salt
1560-69-6 Cobalt propionate
15630-89-4 Sodium percarbonate
15662-33-6 Ryanodine
1569-01-3 2-Propanol, 1-propoxy-
1569-02-4 2-Propanol, 1-ethoxy-
15708-41-5 Sodium ferric ethylenediaminetetraacetate
Formaldehyde, polymer with alpha-[bis(1-phenylethyl)phenyl]-omega-
157291-93-5 hydroxypoly(oxy-1,2-ethanediyl)
2-Propenoic acid, 2-methyl-, 2-ethyl-2-{{(2-methyl-1-oxo-2-
propenyl)oxy}methyl}-1,3-propanediyl ester, polymer with 1-ethenyl-2-
pyrrolidinone, 1,2-propanediol mono(2-methyl-2-propenoate) and tridecyl 2-
157544-93-9 methyl-2-propenoate
2-Naphthalenecarboxylic acid, 4-{(5-chloro-4-methyl-2-sulfophenyl)azo}-3-
15782-05-5 hydroxy-, strontium salt (1:1)
15790-07-5 C.I. Pigment Yellow No. 104
15792-67-3 C.I. Acid Blue 9, aluminum salt (3:2)
15821-83-7 1-Buthoxy-2-propanol
Phosphonic acid, [[(phosphonomethyl)imino]bis[2,1-
15827-60-8 ethanediylnitrilobis(methylene)]]tetrakis-
Siloxanes and silicones, di-Me, polymers with silica-1,1,1-trimethyl-N-
(trimethylsilyl)silanamine hydrolysis products and silicic acid trimethylsilyl
159002-21-8 ester
1592-23-0 Octadecanoic acid, calcium salt
15956-58-8 Manganese 2-ethylhexanoate
15974-07-9 Calcium zinc phosphate (CaZn2(PO4)2)
Copper, {2,9,16,23-tetrachloro-29H,31H-phthalocyaninato(2-)-N29, N30, N31,
16040-69-0 N32}-, (SP-4-1)-
16058-19-8 (Z)-2-(9-Octadecenyl)-2-imidazoline-1-ethanol
Benzene, ethenyl-, telomer with 2,5-furandione and (1-methylethyl)benzene, 2-
160611-49-4 butoxyethyl ester, a
2,5-Furandione, telomer with ethenylbenzene and (1-methylethyl)benzene, 2-
160611-50-7 butoxyethyl ester
16068-46-5 Potassium phosphate
Page 21 of 93
160875-66-1 Poly(oxy-1,2-ethanediyl), alpha-(2-propylheptyl)-omega-hydroxy-
16106-44-8 Benzenesulfonic acid, 4-methyl-, potassium salt ()
2,5-Furandione, polymer with ethenylbenzene, reaction products with
162568-32-3 polyethylene-polypropylene glycol 2-aminopropyl Me ether
162627-18-1 Fatty acids, C18-unsatd., trimers, reaction products with triethylenetetramine
16291-96-6 Charcoal, activated
16298-74-1 Phosphoric acid, dibutyl ester, sodium salt
1632-73-1 Bicyclo(2.2.1)heptan-2-ol, 1,3,3-trimethyl-
163436-84-8 Polyoxyethylene tristyrylphenol phosphate, potassium salt
163440-89-9 Poly(difluoromethylene), alpha-(2,2-dichloro-2-fluoroethyl)-omega-hydro-
163520-33-0 3-Isoxazolecarboxylic acid, 4,5-dihydro-5,5-diphenyl-, ethyl ester
1638-16-0 Tripropylene glycol
16389-88-1 Dolomite
1639-66-3 Di-n-octyl sodium sulfosuccinate
16423-68-0 Erythrosine B
1643-20-5 N,N-Dimethyldodecylamine oxide
164462-16-2 Alanine, N,N-bis(carboxymethyl)-, trisodium salt
1-Propanaminium, 3-{{(heptadecafluorooctyl)sulfonyl}amino}-N,N,N-
1652-63-7 trimethyl-, iodide
1655-29-4 Disodium 1,5-naphthalenedisulfonate
1-Naphthalenesulfonic acid, 4-{(2-hydroxy-1-naphthalenyl)azo}-,
1658-56-6 monosodium salt
16589-43-8 Sodium methylsiliconate
166798-73-8 Lignosulfonic acid, ammonium sodium salt
16693-91-7 Benzenesulfonic acid, 4-hexadecyl-, sodium salt
1675-54-3 Bisphenol A diglycidyl ether
16800-11-6 Boric acid (HBO2), sodium salt, dihydrate
16893-85-9 Sodium fluosilicate
16919-19-0 Ammonium fluosilicate
16938-22-0 Hexane, 1,6-diisocyanato-2,2,4-trimethyl-
1694-09-3 FD&C Violet No. 1
17018-84-7 1-Hexadecanol, hydrogen sulfate, magnesium salt
Siloxanes and silicones, 3-aminopropyl Me, di-Me, [[(3-aminopropyl)
170212-40-5 ethoxymethylsilyl] oxy]-terminated, 4-hydroxybenzoates
Siloxanes and silicons, hydroxy Me, Me octyl, Me(gamma-omega-perfluoro
170424-64-3 C8-14-alkyl)-oxy, ether
17099-81-9 Iron chelate of ethylenediaminetetraacetic acid
17157-03-8 Octadecanoic acid, calcium zinc salt
17217-76-4 1,2,3-Propanetricarboxylic acid, 2-hydroxy-, iron (3+) salt (1:1), trihydrate
17272-45-6 Lanthanum chloride (LaCl3), hexahydrate
173145-38-5 D-Glucitol, 1-deoxy-1-(methylamino)-, N-C10-16 acyl derivs.
17354-14-2 9,10-Anthracenedione, 1,4-bis(butylamino)-
17372-87-1 Eosin Yellowish
17421-79-3 Sodium ethylenediaminetetraacetate
17465-86-0 gama-Cyclodextrin
Page 22 of 93
17511-60-3 4,7-Methano-1H-inden-6-ol, 3a,4,5,6,7,7a-hexahydro-, propanoate
17557-23-2 Oxirane, 2,2-{(2,2-dimethyl-1,3-propanediyl)bis(oxymethylene)}bis-
17572-97-3 Tripotassium ethylenediaminetetraacetate
Poly[oxy(methyl-1,2-ethanediyl)], α-[2-[bis(2-hydroxyethyl)amino]propyl]-ω-
hydroxy-, ether with α-hydro-ω-hydroxypoly(oxy-1,2-ethanediyl) (1:2), mono-
176022-82-5 C12-16-alkyl ethers
1762-95-4 Ammonium thiocyanate
17675-60-4 Urea, (aminoiminomethyl)-, phosphate
2,5-Furandione, polymer with alpha-ethenyl-omega-methoxypoly(oxy-1,2-
177038-04-9 ethanediyl), sodium salt
Octadecanoic acid, ester with 1,2-propanediol, phosphate, anhydride with
177771-31-2 silicic acid (H4SiO4) (9
Octadecanoic acid, monoester with 1,2,3-propanetriol, phosphate, anhydride
177771-33-4 with silicic acid (H4S
2-Naphthalenecarboxylic acid, 4-{(4-chloro-5-methyl-2-sulfophenyl)azo}-3-
17852-99-2 hydroxy-, calcium salt (1:1)
17955-88-3 Trisiloxane, 1,1,1,3,5,5,5-heptamethyl-3-octyl-
1797-33-7 Benzenesulfonic acid, 4-tetradecyl-, sodium salt
18015-76-4 C.I. Basic Green 4, oxalate
180294-41-1 1-Naphthalenesulfonic acid, 4,8-dibutyl-, sodium salt
1812-53-9 Dihexadecyldimethylammonium
18172-67-3 Bicyclo[3.1.1]heptane, 6,6-dimethyl-2-methylene-,(1S,5S)-
18282-10-5 Tin oxide (SnO2)
18312-04-4 Zirconium octanoate
18312-31-7 Cetyl stearyl octanoate
1843-05-6 2-Hydroxy-4-n-octyloxybenzophenone
18472-87-2 Phloxine B
1847-55-8 Sodium cis-9-octadecenyl sulfate
18479-58-8 7-Octen-2-ol, 2,6-dimethyl-
18483-17-5 beta-D-Glucopyranose, 1,3,6-tris(3,4,5-trihydroxybenzoate)
1863-63-4 Benzoic acid, ammonium salt
18662-52-7 Carbonic acid, dipotassium salt, trihydrate
186817-80-1 Propanoic acid, 2-hydroxy-, 2-ethylhexyl ester, (2S)-
beta-Cyclodextrin, 6-chloro-1,4-dihydro-4-oxo-1,3,5-triazin-2-yl ethers,sodium
187820-08-2 salts
5H-1,3-Dioxolo[4,5-f]benzimidazole, 6-chloro-5-[(3,5-dimethyl-4-
188027-78-3 isoxazolyl)sulfonyl]-2,2-difluoro
18917-93-6 Magnesium lactate
18924-66-8 Ethanol, 2,2'-(tetradecylimino)bis-
18924-67-9 Ethanol, 2,2'-(hexadecylimino)bis-
1897-45-6 2,4,5,6-Tetrachloroisophthalonitrile
18996-35-5 1,2,3-Propanetricarboxylic acid, 2-hydroxy-, monosodium salt
190012-21-6 1-Hexanethiol, telomer with butyl 2-propenoate and ethenylbenzene
Glycine,N-(carboxymethyl)-N-[2-[(carboxymethyl)amino]ethyl]-, trisodium
19019-43-3 salt
Page 23 of 93
1907-65-9 Benzenesulfonamide, N-butyl-4-methyl-
19125-99-6 1H-Benz[de]isoquinoline-1,3(2H)-dione, 2-butyl-6-(butylamino)-
Amides, from acetic acid, C5-9 carboxylic acids and diethylenetriamine-
192230-19-6 ethylenimine polymer
19224-26-1 1,2-Propanediol, dibenzoate
Siloxanes and Silicones, di-Me, hydroxy-terminated, dthers with polyethylene-
192726-52-6 polypropylene glycol monoallyl ether
1H-Pyrazole-3-carboxylic acid, 4,5-dihydro-5-oxo-1-(4-sulfophenyl)-4-((4-
1934-21-0 sulfophenyl)azo)-, trisodium salt
19381-50-1 C.I. Acid Green 1
19423-76-8 Cerium chloride (CeCl3), hydrate
19589-59-4 Benzenesulfonic acid, 3dodecyl-, sodium salt
197178-94-2 Propanol, 1(or 2)-(2-propenyloxy)-, benzoate
1984-06-1 Octanoic acid, sodium salt
199111-50-7 1-Octadecanaminium, N,N-dimethyl-N-[3-(trihydroxysilyl)propyl]- chloride
2016-56-0 Dodecylamine acetate
2031-67-6 Methyl triethoxysilane
20324-32-7 1-(2-Methoxy-1-methylethoxy)-2-propanol
20324-33-8 Tripropylene glycol monomethyl ether
20344-49-4 Iron hydroxide oxide (Fe(OH)O)
20427-58-1 Zinc hydroxide (Zn(OH)2)
20427-59-2 Copper hydroxide
2050-08-0 Benzoic acid, 2-hydroxy-, pentyl ester
2-Butenedioic acid (2Z)-, monobutyl ester, polymer with methoxyethene,
20526-58-3 Sodium sulfosuccinate
20587-61-5 Diethylene glycol monobenzoate
20662-14-0 Scandium chloride (ScCl3), hexahydrate
20727-33-7 Butanedioic acid, sulfo-, 1,4-bis(1-methylheptyl) ester, sodium salt
20749-68-2 12H-Phthaloperin-12-one, 8,9,10,11-tetrachloro-
20780-48-7 Tetrahydrolinalyl acetate
1,3-Benzenedicarboxylic acid, polymer with 2,2-dimethyl-1,3-propanediol,
hexanedioic acid, 1,6-hexanediol, 3-hydroxy-2-(hydroxymethyl)-2-
methylpropanoic acid and 5-isocyanato-1-(isocyanatomethyl)-1,3.3-
208054-84-6 trimethylcyclohexane, compd. with 2-amino
20824-56-0 Diammonium ethylenediaminetetraacetate
2082-79-3 Octadecyl 3-(3',5'-di-tert-butyl-4'-hydroxyphenyl)propionate
208408-46-2 Vitamin D, 1,25-dihydroxy-, 26, 23-lactone, (1-alpha)-
20846-91-7 L-Aspartic acid, N,N'-1,2-ethanediylbis-
2090-05-3 Calcium benzoate
20908-72-9 Sulfuric acid, iron(2+) salt (1:1), tetrahydrate
2091-29-4 9-Hexadecenoic acid
2110-18-1 Pyridine, 2-(3-phenylpropyl)-
21142-28-9 Sulfuric acid, monododecyl ester, comp. with 1-amino-2-propanol (1:1)
2116-84-9 Phenyl tris(trimethylsiloxy)silane
Page 24 of 93
21245-02-3 4-(Dimethylamino)benzoic acid, 2-ethylhexyl ester
1,3 benzene dicarboxylic acid, 5-sulfo-, 1,3-dimethyl ester, sodium salt,
polymer with 1,3-benzene dicarboxylic acid, 1,4-
benzene dicarboxylic acid, dimethyl 1,4-benzene dicarboxylate and 1,2-
212842-88-1 ethanediol
21564-17-0 2-(Thiocyanomethylthio)benzothiazole
2,5-Furandione, polymer with alpha-ethenyl-omega-hydroxypoly(oxy-1,2-
215731-95-6 ethanediyl), sodium salt
2163-42-0 2-Methyl-1,3-propanediol
21645-51-2 Aluminum hydroxide (Al(OH)3)
21652-27-7 2-[(Z)-8-Heptadecenyl]-2-imidazoline-1-ethanol
21662-09-9 4-Decenal, (4Z)-
219714-96-2 Penoxsulam
22047-49-0 Octadecanoic acid, 2-ethylhexyl ester
2211-98-5 Sodium p-dodecylbenzenesulfonate
2211-99-6 Benzenesulfonic acid, 4-(1 -methylundecyl)-, sodium salt
2212-50-2 Benzenesulfonic acid, 4-(1 -ethyldecyl)-, sodium salt
2212-51-3 Benzenesulfonic acid, 4-(1 -propylnonyl)-, sodium salt
2212-52-4 Benzenesulfonic acid, 4-(1 -pentylheptyl)-, sodium salt
221667-31-8 Cyprosulfamide ( approval pending do not use)
Fatty acids, tall-oil, esters with polyethylene glycol mono(hydrogen maleate),
222716-38-3 compds. with amides from diethylenetriamine and tall-oil fatty acids
Siloxanes and silicones, di-Me, hydroxy Me, ethers with polypropylene glycol
222716-82-7 mono-Bu ether
2235-54-3 Ammonium dodecyl sulfate
2244-21-5 Troclosene potassium [USAN:INN]
22464-99-9 2-Ethylhexanoic acid, zirconium salt
225234-12-8 Borage seed oil
22620-93-5 Decanoic acid, aluminum salt
22691-02-7 Calcium chloride (CaCl2), hydrate
2269-22-9 2-Butanol, aluminum salt
3-Cyclohexene-1-methanol,α,4-dimethyl-α-(4-methyl-3-pentenyl)-, {S-
23089-26-1 (R*,R*)}-
2321-07-5 Spiro(isobenzofuran-1(3H), 9'-(9H)xanthen)-3-one, 3',6'-dihydroxy-
23328-53-2 Phenol, 2-(2H-benzotriazol-2-yl)-6-dodecyl-4-methyl-
23386-52-9 Butanedioic acid, sulfo-, 1,4-dicyclohexyl ester, sodium salt
2353-45-9 FD&C Green No. 3
23696-85-7 2-Buten-1-one, 1-(2,6,6-trimethyl-1,3-cyclohexadien-1-yl)-
23783-42-8 Tetraethylene glycol methyl ether
2390-60-5 C.I. Basic Blue 7
Poly(oxy-1,2-ethanediyl), alpha-methyl-omega-hydroxy-, maleated, calcium
241483-16-9 salts
2425-77-6 1-Decanol, 2-hexyl-
2425-85-6 C.I. Pigment Red 3
24360-05-2 Hexamethylene tetramine monohydrochloride
Page 25 of 93
2440-22-4 2-(2H-Benzotriazol-2-yl)-4-methylphenol
244149-17-5 3,6,9,12,15,18,21,24,27-Nonaoxanonacosan-1-ol, 29-(4-nonylphenoxy)-
2445-77-4 Butanoic acid, 3-methyl-, 2-methylbutyl ester
2452-01-9 Dodecanoic acid, zinc salt
2457-01-4 Barium 2-ethylhexanoate
24634-61-5 Sorbic acid, potassium salt
2465-27-2 C.I. Basic Yellow 2
2475-46-9 C.I. Disperse Blue 3
24800-44-0 Tripropylene glycol
2481-94-9 Benzenamine, N,N-diethyl-4-(phenylazo)-
24851-98-7 Cyclopentaneacetai acid, 3-oxo-2-pentyl-, methyl ester
2492-26-4 2-Mercaptobenzothiazole, sodium salt
24936-68-3 Poly[oxycarbonyloxy-1,4-phenylene(1-methylethylidene)-1,4-phenylene
24937-16-4 Poly[imino(1-oxo-1,12-dodecanediyl)]
24937-78-8 Vinyl acrylate-dioctylmaleate copolymer
24937-79-9 Ethene, 1,1-difluoro-, homopolymer
24938-04-3 Polyethylene terephthalate - polyethylene isophthalate film
2-Propenoic acid, 2-methyl-, butyl ester, polymer with 2-(dimethylamino)ethyl
24938-16-7 2-methyl-2-propen
24938-91-8 Poly(oxy-1,2-ethanediyl), α-tridecyl-ω-hydroxy-
24968-79-4 Methyl acrylate acrylonitrile graft copolymer
24991-31-9 Polyvinyl butyrate
25013-15-4 Vinyl toluene
25013-16-5 Butylated hydroxyanisole
25014-41-9 Polyacrylonitrile
25035-26-1 Acetic acid ethenyl ester, polymer with 2-butenoic acid and ethenyl propanoate
25035-68-1 Methacrylic acid butyl acrylate methyl methacrylate polymer
2-Propenoic acid, 2-methyl-, polymer with butyl-2-propenoate and methyl 2-
25035-97-6 2-Propenoic acid, ethyl ester, polymer with chloroethene
25035-98-7 2-Propenoic acid, methyl ester, polymer with chloroethene
2-Propenoic acid, 2-methyl-, polymer with butyl 2-propenoate and
25036-16-2 ethenylbenzene
25036-25-3 Bisphenol A-bisphenol A diglycidyl ether polymer
2503-73-3 C.I. Direct Blue 78, tetrasodium salt
25038-54-4 Polycaprolactam
25038-59-9 Polyethylene terephthalate
2,5-Furandione, polymer with alpha-[4-(ethenyloxy)butyl]-omega-
250591-55-0 hydroxypoly(oxy-1,2-ethanediyl), sodium salt
25067-01-0 Vinyl acetate, polymer with n-butyl acrylate
25067-11-2 Hexafluoropropene, polymer with tetrafluoroethylene
25068-38-6 4,4'-(1-Methylethylidene)bisphenol polymer with (chloromethyl) oxirane
25084-90-6 Ethylene butyl acrylate copolymer
25085-02-3 Sodium acrylate, polymer with acrylamide
25085-34-1 Styrene acrylic acid copolymer
Page 26 of 93
25085-39-6 2-Propenoic acid, polymer with 1,3-butadiene and ethenylbenzene
25085-41-0 Vinyl acetate-butyl acrylate-acrylic acid terpolymer
Oxirane,2,2'-[(1-methylethylidene)bis(4,1-phenyleneoxymethylene)]bis-,
25085-99-8 homopolymer-
25086-15-1 2-propenoic acid, 2-methyl-, polymer with methyl 2-methyl-2-propenoate
25086-29-7 Vinyl pyrrolidone - styrene copolymer latex
25086-48-0 Acetic acid ethenyl ester, polymer with chloroethene and ethenol
25086-89-9 2-Pyrrolidinone, 1-ethenyl-, polymer with ethenyl acetate
25087-06-3 Maleic acid monoethyl ester-vinyl methyl ether copolymer
25087-34-7 1-Butene, polymer with ethene
25103-23-5 Triisooctyl phosphate
25104-37-4 Polyvinyl ether ether
25119-68-0 Maleic acid monobutyl ester-vinyl methyl ether copolymer,
25119-83-9 2-Propenoic acid, polymer with butyl 2-propenoate
2512-29-0 Butanamide, 2-{(4-methyl-2-nitrophenyl)azo}-3-oxo-N-phenyl-
2-Propenoic acid, 2-methyl-, polymer with ethyl 2-propenoate and methyl 2-
2-Propenoic acid, 2-methyl-, methyl ester, polymer with ethyl 2-propenoate
25135-39-1 and 2-propenoic acid
2-Propene-1-aminium, N,N-dimethyl-N-2-propenyl-, chloride, polymer with 2-
25136-75-8 propenamide and 2-propenoic acid
2,5-Furandione, polymer with alpha-ethenyl-omega-methoxypoly(oxy-1,2-
251479-93-3 ethanediyl) and 2-propenoic acid, sodium salt
25153-40-6 Methyl vinyl ether-maleic acid copolymer ,minimum average molecular weigh
25153-46-2 2-propenoic acid, 2-ethylhexyl ester, polymer with ethenylbenzene
25154-52-3 Nonylphenol
25154-85-2 Propane, 1-(ethenyloxy)-2-methyl-, polymer with chloroethene
25155-30-0 Sodium dodecylbenzenesulfonate
251553-55-6 Alcohols, C>14, ethoxylated
25167-81-1 Dichlorophenol
25168-05-2 Benzene, chloromethyl-
2-Naphthalenesulfonic acid, 7-(benzoylamino)-4-hydroxy-3-((4-((4-
25188-42-5 sulfophenyl)azo)phenyl)azo)-
25189-83-7 2H-Azepin-2-one, 1-ethenylhexahydro-, homopolymer
25212-83-3 Ethylene-acrylic acid copolymer, ammonium salt
25212-88-8 Ethyl acrylate- methacrylic acid copolymer
25213-02-9 1-Hexene, polymer with ethene
25213-24-5 Acetic acid ethenyl ester, polymer with ethenol
2-Propenoic acid, 2-methyl-, methyl ester, polymer with ethenylbenzene and 2-
25213-88-1 propenenitrile
25214-39-5 Acrylonitrile-methyl methacrylate-vinylidene chloride polymer
25214-69-1 Hydrolyzed polyacrylonitrile
25231-21-4 Polypropylene glycol stearyl ether
25231-46-3 Benzenesulfonic acid, methyl-
25265-15-0 2-Propenoic acid, 2-methyl-, methyl ester, polymer with 2-ethylhexyl 2-
Page 27 of 93
propenoate
25265-71-8 Dipropylene glycol
25265-77-4 2,2,4-Trimethylpentane-1,3-diol monoisobutyrate
25265-93-4 Polyethylene polysulfide
25266-02-8 Maleic anhydride-1-octadecene copolymer
Xylene sulfonic acid and its ammonium, calcium, magnesium, potassium,
25321-41-9 sodium, and zinc salts
25322-68-3 Polyethylene glycol
25322-69-4 Polypropylene glycol
2-Propenoic acid, 2-methyl-, butyl ester, polymer with butyl 2-propenoate and
25322-99-0 methyl 2-methyl-2-propenoate
25338-55-0 Dimethylaminomethylphenol
25339-17-7 Isodecanol
25395-31-7 Diacetin
25417-20-3 Dibutylnaphthalenesulfonic acid, sodium salt
25446-78-0 Ethanol, 2-?2-?2-(tridecyloxy)ethoxyUethoxyU-, hydrogen sulfate, sodiumsalt
25446-90-6 Sulfuric acid, monodecyl ester, calcium salt
25446-91-7 1-tetradecanol, hydrogen sulfate, magnesium salt
25446-93-9 Sulfuric acid, monodecyl ester, magnesium salt
25455-73-6 Silver oxide (Ag2O2)
25496-72-4 9-Octadecenoic acid (9Z)-, monoester with 1,2,3-propanetriol
25498-49-1 [2-(2-Methoxymethylethoxy)methylethoxy]propanol
25512-39-4 Silane, (3-chloropropyl)trimethoxy-
25550-98-5 Phosphorous acid, diisodecyl phenyl ester
25585-77-7 2-Propenoic acid, polymer with ethenylbenzene and ethyl 2-propenoate
25608-12-2 2-Propenoic acid, homopolymer, potassium salt
2-Propenoic acid, 2-methyl-, butyl ester, polymer with methyl 2-methyl-2-
25608-33-7 propenoate
25618-55-7 Polyoxypropylene triol
25637-84-7 9-Octadecenoic acid (9Z)-, diester with 1,2,3-propanetriol
25638-17-9 Naphthalenesulfonic acid, butyl-, sodium salt
1,4-Benzenedicarbixylic acid, dimethyl ester,polymer with 1,4-
25640-14-6 cyclohexanedimethanol and 1,2-ethanediol
25719-52-2 Lauryl methacrylate polymer
25719-60-2 Bicyclo(3.1.1)heptene, 6,6-dimethyl-2-methylene-, homopolymer
25722-70-7 Polyglycidol
25750-06-5 Styrene-methyl methacrylate-2-ethylhexyl acrylate copolymer
25750-82-7 Ethylene-acrylic acid copolymer, sodium salt
25750-84-9 2-Propenoic acid, butyl ester, polymer with ethene
25766-18-1 Bicyclo [3.1.1] hept-2-ene, 2,6,6-trimethyl- , homopolymer
Poly(oxy(methyl-1,2-ethanediyl)), alpha,alpha',alpha",-1,2,3-
25791-96-2 propanetriyltris(omega-hydroxy-
25852-37-3 2-Propenoic acid, 2-methyl-, methyl ester, polymer with butyl 2-propenoate
25951-38-6 Butyl acrylate-hydroxyethyl acrylate-methyl methacrylate copolymer
25956-17-6 2-Naphthalenesulfonic acid, 6-hydroxy-5-{(6-methoxy-4-sulfo-m-tolyl)azo}-,
Page 28 of 93
disodium salt
25973-55-1 Phenol, 2-(2H-benzotriazol-2-yl)-4,6-bis(1,1-dimethylpropyl)-
25987-30-8 Acrylamide, polymer with sodium acrylate
25987-55-7 Calcium polyacrylate
Acrylic acid butyl ester, polymer with methacrylic acid, methyl methacrylate
25987-66-0 and styrene
2601-33-4 1-Tetradecanaminium, N-(carboxymethyl)-N,N-dimethyl-, inner salt
2601-98-1 Hexadecanoic acid, magnesium salt
26027-37-2 Polyethylene glycol mono-2-(oleylamido)ethyl ether
26027-38-3 Poly(oxyethylene) p-nonylphenol
26038-87-9 Monoethanolamine, boric acid salt
26038-90-4 Boric acid, monoisopropanolamine salt
2605-44-9 Dodecanoic acid, barium cadmium salt
2605-78-9 Octyl dimethyl amine oxide
26061-64-3 2-butenedioic acid (2Z)-, dioctyl ester, polymer with ethenyl acetate
26062-79-3 2-Propen-1-aminium, N,N-dimethyl-N-2-propenyl-, chloride, homopolymer
26099-09-2 Maleic acid, polymers
1,3-Naphthalenedisulfonic acid, 6,6'-{(3,3'-dimethoxy(1,1'-biphenyl-)-4,4'-
2610-05-1 diyl}bis(azo)}bis{4-amino-5-hydroxy-, tetrasodium salt
2610-11-9 sulfophenyl)azo)phenyl)azo)-, disodium salt
2611-82-7 C.I. Acid Red 18, trisodium salt
26160-96-3 Polyvinylpyrrolidone, butylated
Ethanaminium, N,N,N-trimethyl-2-[(2-methyl-1-oxo-2-propenyl)oxy]-,
26161-33-1 chloride, homopolymer
26172-55-4 3(2H)-Isothiazolone, 5-chloro-2-methyl-
26183-44-8 Lauryl polyoxyethylene sulfate
26183-52-8 Polyoxyethylene* decyl alcohol *(5.5 moles)
26221-73-8 1-Octene, polymer with ethene
2624-31-9 Hexadecanoic acid, potassium salt
Lignin, alkali, reaction products with formaldehyde, sodium bisulfite and
262435-04-1 sodium chloroacetate
26248-24-8 Benzenesulfonic acid, tridecyl-, sodium salt
26254-89-7 Butanal, 2,2-diethyl-
26256-79-1 Sodium . beta.-.beta.-(laurylimino)dipropinate
26264-05-1 Benzenesulfonic acid, dodecyl-, compd. with 2-propanamine (1:1)
26264-06-2 Calcium dodecylbenzene sulfonate
26264-58-4 Sodium isopropylisohexylnaphthalenesulfonate
26266-57-9 Monohexadecanoate sorbitan
26266-58-0 Sorbitan trioleate
1H-Imidazolium, 1-ethyl-2-(heptadecenyl)-4,5-dihydro-1-(2-hydroxyethyl)-,
26266-76-2 ethyl sulfate (salt)
2627-06-7 Benzenesulfonic acid, 4-decyl-, sodium salt
2-Propenoic acid, 2-methyl, methyl ester, polymer with butyl 2-propenoate and
26300-51-6 2-propenoic acid
Page 29 of 93
26316-40-5 1,2-Ethanediamine, polymer with methyloxirane and oxirane
26337-35-9 Acetic acid ethenyl ester, polymer with carbon monoxide and ethene
2634-33-5 1,2-Benzisothiazolin-3-one
2-Propenoic acid, ethyl ester, polymer with 2-propenoic acid, 2-ethylhexyl
26376-86-3 ester
26401-27-4 Isooctyl diphenyl phosphite
26401-47-8 Poly(oxy-1,2-ethanediyl), alpha-(4-dodecylphenyl)-omega-hydroxy-
26402-22-2 Decanoic acid, monoester with 1,2,3-propanetriol
26402-26-6 Octanoic acid, monoester with 1,2,3-propanetriol
Poly[oxy(methyl-1,2-ethanediyl)], alpha-(1-oxooctadecyl)-omega-[(1-
26403-62-3 oxooctadecyl)oxy]-
26446-35-5 Monoacetin
26447-09-6 Benzenesulfonic acid, methyl-, ammonium salt
26447-10-9 Ammonium xylenesulfonate
26468-86-0 Poly(oxy-1,2-ethanediyl), alpha-(2-ethylhexyl)-omega-hydroxy-
26499-65-0 Plaster of paris
Benzenemethanaminium, N-ethyl-N-[4-[[4-[ethyl[(3-
sulfophenyl)methyl]amino]phenyl](2-sulfophenyl)methylene]-2,5-
2650-18-2 cyclohexadien-1-ylidine]-3-sulfo-, inner salt, diammonium salt
26523-78-4 Phenol, nonyl-, phosphite (3:1)
26544-23-0 Diphenyl isodecyl phosphite
26545-53-9 Diethanolamine dodecylbenzenesulfonate
26545-58-4 Naphthalenesulfonic acid, methylenebis-, disodium salt
Butyl acrylate, 2-hydroxyethyl methacrylate, methyl methacrylate and styrene
26588-80-7 copolymer
2-Propen-1-aminium, N,N-dimethyl-N-2-propenyl-, chloride, polymer with 2-
26590-05-6 propenamide
Acrylic acid,polymer with acrylonitrile,ethyl acrylate and N-
26604-01-3 (hydroxymethyl)acrylamide
26635-76-7 Ethoxylated tallowamine
26635-92-7 N,N'-Bis(poly(oxyethylene))stearylamine
26635-93-8 Polyoxyethylenated oleylamine
26635-94-9 Polyoxyethylenated cetylamine
26636-40-8 Docosyl polyethylene glycol ether
2664-42-8 N,N-Dimethyloleamide
26655-10-7 Butyl methacrylate, 2-ethylhexyl acrylate and styrene copolymer
26657-95-4 Hexadecanoic acid, diester with 1, 2, 3-propanetriol
26657-96-5 Hexadecanoic acid, monoester with 1, 2, 3-propanetriol
26658-19-5 Sorbitan tristearate
26658-42-4 Epichlorohydrin, polymer with tetraethylenepentamine
2673-22-5 Sodium ditridecyl sulfosuccinate
26761-40-0 Diisodecyl phthalate (Clearance pending)
26793-35-1 2-Propenoic acid, polymer with N,N-dimethyl-2-propenamide
2682-20-4 3(2H)-Isothiazolone, 2-methyl-
26836-07-7 Ethanolamine dodecylbenzenesulfonate
Page 30 of 93
26856-96-2 Sulfuric acid, monoisononyl ester, sodium salt
2-Propenoic acid, 2-methyl-, polymer with ethenylbenzene, 2-ethylhexyl 2-
26873-77-8 propenoate and 2-propene
2687-94-7 2-Pyrrolidinone, 1-octyl-
2687-96-9 2-Pyrrolidinone, 1-dodecyl-
26885-07-4 Ethanesulfonic acid, 2-(methyl(1-oxoeicosyl)amino)-, sodium salt
26896-20-8 Neodecanoic acid
26915-70-8 Tridecyloxypoly(ethyleneoxy)ethyl phosphate
27012-62-0 Nitrile rubber modified acrylonitrile-methyl acrylate copolymers
27134-27-6 Benzenamine, ar,ar-dichloro-
27138-31-4 Propanol, oxybis-, dibenzoate
2717-15-9 Triethanolamine oleate
27176-87-0 Benzenesulfonic acid, dodecyl-
27177-77-1 Benzenesulfonic acid, dodecyl-, potassium salt
27177-79-3 Benzenesulfonic acid, octadecyl-, sodium salt
27178-87-6 Sodium dimethylnaphthalene sulfonate
2718-67-4 Tris(butoxyethyl) phosphite
27193-28-8 Phenol, (1,1,3,3-tetramethylbutyl)-
27193-86-8 Dodecylphenol
27213-90-7 Sodium diisobutylnaphthalene sulfonate
27214-38-6 Tetradecanoic acid, monoester with 1,2,3-propanetriol
27215-38-9 Dodecanoic acid, monoester with 1, 2, 3-propanetriol
27252-80-8 Poly(oxy-1,2-ethanediyl), alpha-methyl-omega-(2-propenyloxy)-
27252-83-1 Poly(oxy-1,2-ethanediyl),α-acetyl-ω-(acetyloxy)-
27252-87-5 Poly(oxy-1,2-ethanediyl),α-acetyl-ω-2-propenyl-
27253-30-1 Lithium neodecanoate
27253-31-2 Cobalt neodeconoate
27253-33-4 Calcium neodecanoate
27274-31-3 Poly(oxy-1,2-ethanediyl),α-2-propenyl-ω-hydroxy-
27277-00-5 [1,2,4]Triazolo[1,5-a]pyrimidin-5(4H)-one, 2-amino-6-methyl-4-propyl-
Poly(oxy-1,2-ethanediyl),α-methyl-ω-{3-{1,3,3,3-tetramethyl-1-
27306-78-1 {(trimethylsilyl)oxy}
27323-41-7 Triethanolamine dodecylbenzenesulfonate
27344-41-8 Benzenesulfonic acid,2,2'-(4,4'-biphenylylenedivinylene)di-, disodium salt
27354-18-3 C.I. Solvent Red 169
27360-07-2 Butane, 1,1-bis(ethenyloxy)-, polymer with ethenol & ethenyl acetate
27458-92-0 Isotridecyl alcohol
27458-93-1 Isooctadecyl alcohol
27479-45-4 Benzenesulfonic acid, dodecyl-, magnesium salt
27519-02-4 cis-9-Tricosene
27536-89-6 Poly(ethylbenzene)
Butyl acrylate, 2-hydroxyethyl methacrylate, methacrylic acid and styrene
27554-26-3 Diisooctyl phthalate (Clearance pending)
2756-56-1 Bicyclo(2.2.1)heptan-2-ol, 1,7,7-trimethyl-, propanoate, exo-
Page 31 of 93
2761-24-2 Amyl triethoxysilane
27636-21-1 Epichlorohydrin, polymer with hexamethylenediamine
27636-75-5 Benzenesulfonic acid, undecyl-, sodium salt
27636-82-4 Monomethylol-5,5-dimethylhydantoin
27638-00-2 Dodecanoic acid, diester with 1, 2, 3-propanetriol
27731-61-9 Poly(oxy-1,2-ethanediyl), α-sulfo-ω-(tetradecyloxy)-, ammonium salt
27731-62-0 Poly(oxy-1,2-ethanediyl), α-sulfo-ω-(tetradecyloxy)-, sodium salt
27756-15-6 Acrylic acid-stearyl methacrylate copolymer
2782-57-2 Troclosene
2783-94-0 6-Hydroxy-5-((4-sulfophenyl)azo)-2-naphthalenesulfonic acid, disodium salt
2-Naphthalenecarboxamide, 4-((4-(aminocarbonyl)phenyl)azo)-N-(2-
2786-76-7 ethoxyphenyl)-3-hydroxy-
27987-00-4 Benzenesulfonic acid, (1-methylundecyl)-, sodium salt
28062-44-4 Acrylic acid-N-vinylpyrrolidone copolymer
1,3-Benzenedicarboxylic acid, 5-sulfo-monosodium salt, polymer with 1,3-
2807-30-9 benzenedicarboxylic acid
28088-63-3 Xylenesulfonic acid, calcium salt
2809-21-4 Etidronic acid
28182-81-2 Hexamethylene diisocyanate (HDI) homopolymer
Octadecanoic acid, 2-(hydroxymethyl)-2-(((1-oxooctadecyl)oxy)methyl)-1,3-
28188-24-1 propanediyl ester
28205-96-1 Acrylic acid-methacrylic acid copolymer, sodium salt
28211-18-9 2-Pyrrolidinone, 1-ethenyl-, polymer with 1-eicosene
28212-44-4 Poly(oxy-1,2-ethanediyl), α-(carboxymethyl)-ω-(4-nonylphenoxy)-
28231-03-0 1H-3a,7-Methanoazulen-5-ol, octahydro-3,8,8-trimethyl-6-methylene-
28299-18-5 Poly(oxy-1,2-ethanediyl), alpha-(2,4-dinonylphenyl)-omega-hydroxy-
28300-74-5 Antimony potassium tartrate
28348-27-8 Diethylene glycol, polyester with maleic acid and sebacic acid
28348-53-0 Sodium cumene sulfonate
28348-61-0 Benzenesulfonic acid, tetradecyl-, sodium salt
28348-64-3 Isopropylnapthalenesulfonic acid, sodium salt
28348-65-4 Naphthalenesulfonic acid, (2-methylpropyl)-, sodium salt
28349-72-6 2-Propenoic acid, polymer with 2-propenal
2836-32-0 Sodium glycolate
2-Chloro-1,1,1,2-tetrafluoroethane (For use in sterilant mixture with ethylene
2837-89-0 oxide only)
28430-58-2 Vinyl acetate, polymer with methyl acrylate and methyl methacrylate
28514-75-2 Resorcinol, bis(xylylazo)-
28519-02-0 Benzenesulfonic acid, dodecyl(sulfophenoxy)-, disodium salt
28553-12-0 Diisononyl phthalate
28631-66-5 C.I. Acid Blue 22
Benzenesulfonic acid, 2,2'-(1,2-ethenediyl)bis{5-{(4-ethoxyphenyl)azo}-,
28804-88-8 Dimethylnaphthalene
Page 32 of 93
28805-58-5 Butanedioic acid, octenyl-
2893-78-9 Troclosene sodium
28983-56-4 C.I. Acid Blue 93
28984-69-2 2-(Heptadecenyl)-4,4(5H)-oxazoledimethanol
28987-17-9 Barium nonylphenate
29061-61-8 Dodecylbenzenesulfonic acid, diisopropylamine salt
29061-63-0 Dodecylbenzenesulfonic acid, triethylamine salt
29066-34-0 Cyclohexanol, 5-methyl-2-(1-methylethyl)-, acetate, (1α,2.beta.,5α)-(.+-.)-
29116-98-1 Sorbide dioleate
29169-69-5 Sodium N-oleyl taurine
Ethanesulfonic acid, 2-(2-(2-(4-(1,1,3,3-
2917-94-4 tetramethylbutyl)phenoxy)ethoxy)ethoxy)-, sodium salt
29190-28-1 Resorcinol, 2,4-bis(xylylazo)-
2934-05-6 Diisopropylphenols
2934-07-8 2,4,6-Triisopropylphenol
29383-26-4 Octadecanoic acid, hydroxy-, 2-ethylhexyl ester
29385-43-1 1H-Benzotriazole, 4(or 5)-methyl-, sodium salt
29387-86-8 Propylene glycol monobutyl ether
29405-16-1 Benzenesulfonic acid, 4-hydroxy-, polymer with formaldehyde and urea
2-Propenoic acid, butyl ester, polymer with N-(hydroxymethyl)-2-methyl-2-
29434-28-4 propenamide and 2-propenenitrile
2-Propenoic acid, butyl ester, polymer with ethyl 2-propenoate and 2-
29437-34-1 propenenitrile
29658-97-7 3-(2-Dodecenyl)dihydro-2,5-furandione
29710-25-6 2-Ethylhexyl 12-hydroxystearate
29710-31-4 Cetyl octanoate
29733-18-4 Glutaric acid, diisodecyl ester
29781-80-4 alpha-D-Glucopyranoside, octyl
29781-81-5 alpha-D-Glucopyranoside, decyl
29806-73-3 Hexadecanoic acid, 2-ethylhexyl ester
298-07-7 2-Ethylhexyl monohydrogen phosphate
298-14-6 Carbonic acid, monopotassium salt
29836-26-8 (beta-D-Glucopyranoside, octyl
29887-08-9 1,4-Bis[(2-ethylhexyl)amino] anthraquinone
29911-27-1 2-Propanol, 1-(1-methyl-2-propoxyethoxy)-
29911-28-2 Dipropylene glycol monobutyl ether
299-27-4 Potassium gluconate
30025-38-8 Dipropylene glycol monoethyl ethyl
3006-15-3 Sodium 1,4-dihexyl sulfosuccinate
300-92-5 Aluminum, hydroxybis(octadecanoato-O)-
301-00-8 Methyl linolenate
3010-24-0 1-Octadecanaminium, N,N-bis(2-hydroxyethyl)-N-methyl-, chloride
3012-65-5 Diammonium citrate
30136-13-1 Propylene glycol monopropyl ether
Page 33 of 93
30227-71-5 Benzenesulfonic acid, pentadecyl-, sodium salt
3025-30-7 Ethyl (2E,4Z)-2,4-decadienoate
30260-72-1 Benzenesulfonic acid, dodecyl(sulfophenoxy)-
30260-73-2 Benzenesulfonic acid, oxybis(dodecyl-
3026-63-9 Sodium tridecyl sulfate
3032-58-4 Sulfuric acid, monododecyl ester, compd. with 2-propanamine (1:1)
30346-73-7 Potassium xylene sulfonate
30364-51-3 Glycine, N-methyl-N-(1-oxotetradecyl)-, sodium salt
30526-22-8 Potassium toluene sulfonate
30581-59-0 Vinyl pyrrolidone-dimethylaminoethylmethacrylate copolymer
30587-85-0 Benzenesulfonic acid, 2,4(2,6 or 3,5)-dimethyl-,sodium salt
30704-63-3 Poly(methylene-p-tert-butylphenoxy-poly(ethyleneoxy) ethanol)
30704-64-4 Formaldehyde, polymer with p-tert-butylphenol, methyloxirane and oxirane
2-Propenoic acid, butyl ester, polymer with ethenylbenzene and 2-ethylhexyl 2-
308066-19-5 Biosolids (conforming to 40 CFR part 503)
308075-07-2 Sand
308076-02-0 Soapstone
30846-35-6 Poly(methylene-p-nonylphenoxy)poly(ethyleneoxy)ethanol
30862-33-0 1-Tridecanol, hydrogen sulfate, sodium salt
30938-41-1 Acrylic acid, butyl acrylate, vinyl chloride, vinyl acetate polymer
30968-45-7 Hydrogenated methyl abietate
Magnesium dodecyl sulfate
1,2-Ethanediamine, N,N,N',N'-tetramethyl-, polymer with 1,1'-oxybis[2-
31075-24-8 chloroethane]
3118-97-6 2-Naphthalenol,l-((2,4-dimethylphenyl)azo)-
31212-13-2 2-Propenoic acid, potassium salt, polymer with 2-propenamide
31212-99-4 Vinyl acetate-vinyl alcohol-alkyl lactone copolymer
31307-92-3 Polyoxyethylene sorbitol
Maleic acid monoisopropyl ester-vinyl methyl ether copolymer, minimum
31307-95-6 average
Bicyclo[3.1.1]hept-2-ene, 2,6,6-trimethyl-, polymer with 6,6-dimethyl-2-
31393-98-3 methylene bicyclo[3.1.1] heptane
31394-71-5 Polypropylene glycol monooleate
3147-75-9 2-(2-Hydroxy-5-tert-octylphenyl)benzotriazole
Poly[oxy-1,2-ethanediyl (dimethyliminio)-1,2-ethanediyl (dimethyliminio)-1,2-
31512-74-0 ethanediyl dichloride]
31556-45-3 Octadecanoic acid, tridecyl ester
31566-31-1 Octadecanoic acid, monoester with 1,2,3-propanetriol
3164-85-0 Hexanoic acid, 2-ethyl-, potassium salt
31671-74-6 2-Hydroxy-2-(methylamino)-1,3-propanediol
Poly(oxy-1,2-ethanediyl), alpha,alpha',alpha''-1,2,3-propanetriyltris[omega-
31694-55-0 hydroxy-
31800-88-1 Polyoxyethylene octyl ester of phosphoric acid
Page 34 of 93
31906-04-4 3-Cyclohexene-1-carboxaldehyde, 4-(4-hydroxy-4-methylpentyl)-
Benzenesulfonic acid, dodecyl-, branched, compds. with N,N,-dimethyl-1,3-
319926-68-6 propanediamine (2:1)
32131-17-2 1,6-hexanediamine, polymer with hexanedioic acid
3214-47-9 C.I. Direct Yellow 50, tetrasodium salt
32171-27-0 Poly(oxy-1,2-ethanediyl), alpha-[4-(1-phenylethyl)phenyl]-omega-hydro
32345-29-2 Phosphorothioic acid, O,O-diethyl O-phenyl ester
3234-84-2 Dodecanoic acid, octadecyl ester
3234-85-3 Tetradecanoic acid, tetradecyl ester
32388-55-9 Acetyl cedrene (odor masking agent only)
32426-11-2 Decyl dimethyl octyl ammonium chloride
Benzenesulfonic acid, 2-amino-5-[(4-amino-3-sulfophenyl)(4-imino-3-sulfo-
3244-88-0 2,5-cyclohexadien-1-ylidene)methyl]-3-methyl-, disodium salt
Polymer of butyl methacrylate, 2-hydroxyethyl acrylate, methyl methacrylate
3246-20-6 Sodium dinonyl sulfosuccinate
32492-61-8 Polyoxyethylene* isopropylidenediphenol *(7-7.5 moles)
3251-23-8 Nitric acid, copper(2+) salt
32612-48-9 Poly (oxy-1,2-ethanediyl) , alpha-sulfo-omega- (dodecyloxy)-, ammonium salt
32649-30-2 2-Butenedioic acid (Z)-, polymer with ethenol, sodium salt
32686-95-6 Dipropylene glycol, monobenzoate
Benzenepropanoic acid, 3,5-bis(1,1-dimethylethyl)-4-hydroxy-, 2-(3-(3,5-
32687-78-8 bis(1,1-dimethylethyl)-4-hydroxyphenyl)-1-oxopropyl)hydrazide
32687-84-6 2-Decanol, hydrogen sulfate, sodium salt
3282-85-7 Sodium heptadecyl sulfate
[alpha]-hydro-[]-hydroxy-poly(oxyethylene) C8-C18-alkyl ether citrates,
330977-00-9 poly(oxyethylene) content is 4-12 moles which represent C8 alkyl ether citrate
330980-61-5 alpha-D-Glucopyranoside, 2-ethylhexyl 6-O-alpha-D-glucopyranosyl-
poly(oxyethylene) content is 4-12 moles which represent C10-C16 alkyl ether
330985-58-5 citrates
poly(oxyethylene) content is 4-12 moles which represent C16-C18-alkyl ether
330985-61-0 citrates
519290 C.I. Solvent Yellow 30
3332-27-2 1-Tetradecanamine, N,N- dimethyl-, N-oxide
2-Propenoic acid, butyl ester, polymer with ethyl 2-propenoate and N-
33438-19-6 (hydroxymethyl)-2-propenamide
334-48-5 Decanoic acid
33734-57-5 Peroxyoctanoic acid
3386-57-0 Octanoic acid, magnesium salt
3391-86-4 1-Octen-3-ol
33939-64-9 Laureth-11 carboxylic acid, sodium salt
3414-89-9 9,12-Octadecadienoic acid (9Z, 12Z)-, potassium salt
34247-28-4 Sodium lauryl glyceryl ether sulfonate
Page 35 of 93
343-27-1 7-Methoxy-1-methyl-9H-pyrido?3,4-b|-indole hydrochloride
34363-01-4 p-Menth-1-ene, dimer
34396-03-7 Silane, trimethoxy(2,4,4-trimethylpentyl)-
343978-15-4 Heptadecanol, hydrogen sulfate, sodium salt, branched
343978-24-5 Hexadecanol, hydrogen sulfate, sodium salt, branched
34398-01-1 Poly(oxy-1,2-ethanediyl), α-undecyl-ω-hydroxy-
34451-19-9 Propanoic acid, 2-hydroxy-, ethyl ester (S)
34506-45-1 1-Tridecanol, hydrogen sulfate, ammonium salt
3452-97-9 1-Hexanol,3,5,5-trimethyl-
34590-94-8 Propanol, 1(or 2)-(2-methoxymethylethoxy)-
3468-63-1 2-Naphthalenol, 1-{(2,4-dinitrophenyl)azo}-
Phosphonic acid, [[(phosphonomethyl)imino]bis[6,1-
34690-00-1 hexanediylnitrilobis(methylene)]]tetrakis-
2-Propenoic acid, 2-methyl-, methyl ester, polymer with ethyl 2-propenoate, 2-
methoxyethyl 2-propenoate, zinc bis(2-methyl-2-propenoate) and ZINC di-2-
propenoate,2,2'-azobis[2-methylbutanenitrile]- and 2,2'-azobis[2-
348137-48-4 methylpropanenitrile]-initiated
Benzenemethanaminium, N-(4-((2,4-disulfophenyl)(4-
(ethyl(phenylmethyl)amino)phenyl)methylene)-2,5-cyclohexadien-1-ylidene)-
3486-30-4 N-ethyl-, hydroxide, inner salt, sodium salt
34902-57-3 Oxacyclohexadecen-2-one
35087-77-5 D-Gluconic acid, potassium salt
3520-42-1 C.I. Acid Red 52
2-Propenoic acid, polymer with butyl 2-propenoate, chloroethene and N-
35239-21-5 (hydroxymethyl)-2-propenamide
35285-68-8 Sodium ethylparaben
35285-69-9 Sodium propylparaben
3531-23-5 Benzenepropanenitrile, beta-hydroxy-beta-phenyl-
35355-77-2 C.I. Pigment Red 63:2
35365-94-7 Triethyl ammonium phosphate
3539-43-3 1-Hexadecanol, dihydrogen phosphate
354-33-6 Ethane,1,1,1,2,2-pentafluoro-
3555-47-3 Trisiloxane, 1,1,1,5,5,5-hexamethyl-3,3-bis((trimethylsilyl)oxy)-
4-((5-Chloro-4-methyl-2-sulfophenyl)azo)-3-hydroxy-2-naphthalenec-
3564-21-4 arboxylic acid, disodium salt
35674-65-8 Urea, N,N''-1,3-prpanediylbis?N'-octadecyl-
1,3-Naphthalenedisulfonic acid, 7-hydroxy-8-{{4'-{{4-{{(4-
methylphenyl)sulfonyl}oxy}phenyl}azo} {1,1'-biphenyl}-4-yl}azo}-,
3567-66-6 C.I. Acid Red 33
1-Naphthalenesulfonic acid, 4-hydroxy-3-{(4-sulfo-1-naphthalenyl)azo}-,
35691-65-7 2-Bromo-2-(bromomethyl)pentanedinitrile
3586-55-8 Methanol, {1,2-ethanediylbis(oxy)}bis-
3609-96-9 1,2,3-Propanetricarboxylic acid, 2-hydroxy-, dipotassium salt
Page 36 of 93
9,12-Octadecadienoic acid (Z,Z)-, 3,4-dihydro-2,5,7,8-tetramethyl-2-(4,8,12-
36148-84-2 trimethyltridecyl)-2H-1-benzopyran-6-yl ester, {2R*(4R*,8R*)}-(.+-.}-
3622-84-2 Benzenesulfonamide, N-butyl-
3624-77-9 Glycine, N-methyl-N-(1-oxo-9-octadecenyl)-, sodium salt
36311-34-9 Isohexadecanol
Ethanaminium, N,N,N-trimethyl-2-[(2-methyl-1-oxo-2-propenyl)oxy]-,
36347-52-1 chloride, polymer with methyl 2-methyl-2-propenoate
36354-80-0 Octanoic acid, diester with 1,2,3-propanetriol
36366-93-5 Phenyltetraethylene glycol
364066-68-2 propenoic acid, sodium salt, reaction products with disodium (disulfite)
36445-71-3 Decyl phenoxybenzenedisulfonic acid, disodium salt
36452-21-8 1,3,5-Triazine-2,4,6(1H,3H,5H)-trione, disodium salt
36457-20-2 Sodium butylparaben
36653-82-4 1-Hexadecanol
36729-43-8 Xylenesulfonic acid, magnesium salt
36729-46-1 Xylenesulfonic acid, zinc salt
36747-44-1 Benzenesulfonic acid, 4-methyl-, calcium salt ()
3681-71-8 3-Hexen-1-ol, acetate, (3Z)-
3687-46-5 Decyl oleate
Sodium isethionate, coconut fatty acid ester trimer isomer and the POE content
36915-65-8 averages 6 moles
3696-28-4 Pyridine, 2,2'-dithiobis-, 1,1'-dioxide
37086-84-3 1,2-Propanediol, 1-benzoate
3710-84-7 N,N-Diethylhydroxylamine
37189-83-6 Linoleic acid dimer-diethylenetriamine copolymer
37199-81-8 Sodium salt of a copolymer of maleic anhydride and diisobutylene
37205-87-1 Poly(oxy-1,2-ethanediyl),[alpha]-(isononylphenyl)-ω-hydroxy-
37207-89-9 Lignosulfonic acid, sodium salt, sulfomethylated
Oxirane, methyl-, polymer with oxirane, mono(bis(1-methylpropyl)phenyl)
37211-53-3 ether
tert-Alkyl* amine (ethylene oxide)** (propylene oxide)*** *(100% C12-C13)
37211-54-4 **(35%) ***(45%) (Mol. Wt. 3150)
37220-82-9 9-Octadecenoic acid (Z)-, ester with 1,2,3-propanetriol
37244-96-5 Nepheline syenite
37251-69-7 Oxirane, methyl-, polymer with oxirane, mono(nonylphenyl) ether
37271-20-8 SK (surfactant)
37280-82-3 Oxirane, methyl-, polymer with oxirane, phosphate
37281-47-3 Triton DF 12
37281-48-4 Triton H 66
37281-78-0 Poly(oxy(methyl-1,3-ethanediyl)), α-(1-oxo-9-octadecenyl)-ω-butoxy-, (Z)-
37286-64-9 Polypropylene glycol methyl ether
37294-49-8 Butanedioic acid, sulfo-, 4-isodecyl ester, disodium salt
37299-86-8 Rhodamine WT
37310-83-1 Oleyl ether phosphate (neutral)
Page 37 of 93
37311-02-7 Oxirane, methyl-, polymer with oxirane, monooctyl ether
37314-65-1 Lignosulfonic acid, potassium salt
37325-33-0 Lignosulfonic acid, calcium sodium salt
37332-31-3 C8-12 triglycerides
Poly(oxy-1,2-ethanediyl), alpha-nonylphenyl-omega-hydroxy, phosphate,
Benzenemethanaminium, N-[2-[(2,6-dimethylphenyl)amino]-2-oxoethyl]-N,N-
3734-33-6 diethyl-, benzoate
3734-67-6 C.I. Acid Red 1
3737-55-1 Sodium N-hexadecanoyl-N-methyltaurine
3738-00-9 Naphtho{2,1-b}furan, dodecahydro-3a,6,6,9a-tetramethyl-
37449-19-7 Manganese isooctanoate
37452-11-2 Dimethylamine dodecylbenzenesulfonate
374602-90-1 Ashes (residues), sunflower seed hull
37523-33-4 Poly(methylene-p-nonylphenoxy) poly(propyleneoxy) propanol
375348-43-9 Xanthan gum, polymer with ethanedial
3758-54-1 Stearamidopropyl dimethyl 2-hydroxyethyl ammonium dihydrogen phosphate
3761-53-3 C.I. Acid Red 26
37764-25-3 Acetamide, 2,2-dichloro-N,N-di-2-propenyl-
L-Aspartic acid, N-(3-carboxy-1-oxosulfopropyl)-N-octadecyl-, tetrasodium
37767-39-8 salt
37971-36-1 2-Phosphonobutane-1,2,4-tricarboxylic acid
38011-25-5 Glycine, N,N'-1,2-ethanediylbis-, disodium salt
3811-04-9 Potassium chlorate
1-Propanesulfonic acid, 2-methyl-2-[(1-oxo-2-propenyl)amino]-,monosodium
38193-60-1 saltpolymer with 2-propenamide
38251-37-5 Benzenesulfonic acid, 3-methyl-, sodium salt)
3843-16-1 Dihydrogenated tallow dimethyl ammonium methosulfate
Benzenemethanaminium, N-ethyl-N-(4-((4-(ethyl((3-
sulfophenyl)methyl)amino)phenyl)(2-sulfophenyl)methylene)-2,5-
3844-45-9 cyclohexadien-1-ylidene)-3-sulfo-, hydroxide, inner salt, disodium salt
38640-62-9 Diisorpropyl naphthalene
38660-45-6 9,12,15-Octadecatrienoic acid, potassium salt, (9Z, 12Z, 15Z)-
38916-42-6 Aspartic acid, N-Carboxy-1-oxo-3-sulfopropyl)-N-octadecyl-, tetrasodium salt
3896-11-5 2-(2-Hydroxy-3-tert-butyl-5-methylphenyl)-5-chloro-2H-benzotriazole
2-Naphthalenecarboxamide, N,N'-1,4-phenylenebis[4-[(2,5-
3905-19-9 dichlorophenyl)azo]-3-hydroxy-
39105-95-8 2,2-Dichloro-N-(1-methylethyl)-N-phenylacetamide
39236-46-9 Imidazolinidyl urea
3926-62-3 Acetic acid, chloro-, sodium salt
Benzenesulfonamide, ar-methyl-, polymer with formaldehyde and 1,3,5-
39277-28-6 triazine-2,4,6-triamine
39310-05-9 Polymethylene polyphenyl isocyanate
2-Propenoic acid, 2-methyl-, polymer with methyl 2-methyl-2-propenoate and
39332-53-1 2-propenoic acid
Page 38 of 93
39354-45-5 Sodium salt of lauryl alcohol polyglycol ether sulfosuccinate
39362-51-1 Oxirane,methyl-, polymer with oxirane, acetate
39393-37-8 Santicizer 711
39421-75-5 Hydroxypropyl guar gum
alpha-Alkyl(C8-15)-omega-hydroxypolyoxyethylene* polyoxypropylene
39443-63-5 polyoxyethylene* *(9.5 to 10 moles)
39444-23-0 Ammonyx 4080
Cyclohexane, 1,1'-methylenebis[4-isocyanato-, polymer with α-hydro-ω-
39444-87-6 hydroxypoly(ox
39445-23-3 Calcium magnesium hydroxide (CaMg (OH)4)
3944-72-7 1-Octanesulfonic acid
Poly(oxy-1,2-ethanediyl), [alpha]-(dinonylphenyl)-[omega]-hydroxy-
39464-64-7 ,phosphate
39464-70-5 Phenoxy tri(ethoxy) phosphoric acid
39471-52-8 Phosphoric acid, octadecyl ester
39587-22-9 Alcohol, C9, ethoxylated
Poly(oxy-1,2-ethanediyl, alpha-[2,4,6-tris(1-phenylethyl(phenyl)]-omega-
396089-99-9 hydroxy-,sulfate
2-Propenoic acid, polymer with sodium ethanesulfonate, peroxydisulfuric acid,
disodium salt- initiated, reaction products with tetrasodium ethenylidenebis
397256-50-7 (phosphonata)
3982-82-9 Trisiloxane, 1,3,3,5-tetramethyl-1,1,5,5-tetraphenyl-
3999-01-7 (Z,Z)-9,12-Octadecadienamide
40372-66-5 1,2,4-Butanetricarboxylic acid, 2-phosphono-, sodium salt
40379-24-6 Acetic acid, isononyl ester
40382-75-0 Sodium dodecylnaphthalene sulfonate
4040-48-6 Dodecanoic acid, magnesium salt
4040-50-0 Tetradecanoic acid, alumnium salt
4065-45-6 2-Hydroxy-4-methoxybenzophenone-5-sulfonic acid
40716-42-5 N,N-Bis(2-hydroxyethyl)ricinoleamide
4075-81-4 Calcium propionate
40798-65-0 Phenol, polymer with formaldehyde, sodium salt
3,5,7-Triaza-1-azoniatricyclo(3.3.1.13,7)decane,1-(3-chloro-2-propenyl)-,
4080-31-3 chloride
408-35-5 Hexadecanoic acid, sodium salt
4086-70-8 Tetradecanoic acid, magnesium salt
4107-98-6 N,N-Diisopropylaniline
4124-42-9 Benzenesulfonic acid, 4-methyl-, ammonium salt
Benzenemethanaminium, N-[4-[[4-(diethylamino)phenyl][4-[ethyl[(3-
sulfophenyl)methyl]amino]phenyl]methylene]-2,5-cyclohexadien-1-ylidene]-
4129-84-4 N-ethyl-3-sulfo-, inner salt, sodium salt
41444-50-2 n-Octyl glucoside
41444-55-7 Decyl glucoside
41451-28-9 Diisoheptyl phthalate (Clearance pending)
41487-53-0 2-Propenoic acid, 2-methyl-,polymer with ethyl 2-propenoate, sodium salt
Page 39 of 93
41556-26-7 Bis(1,2,2,6,6-pentamethyl-4-piperidinyl) decanedioate
2-Propenoic acid, 2-hydroxypropyl ester, polymer with chloroethene and
41618-91-1 ethenyl acetate
41928-09-0 Polyoxyethylene* methylenebis(octylphenol) *12 moles
1H-Perimidine, 2,3-dihydro-2,2-dimethyl-6-{{4-(phenylazo)-1-
4197-25-5 naphthalenyl}azo}-
42003-39-4 2,8,9-Trioxa-5-aza-1-silabicyclo{3.3.3}undecane, 1-(chloromethyl)-
42065-76-9 Isopropylamine sulfonate
Poly(oxy(methyl(3,3,3-trifluoropropyl)silylene)), alpha-(trimethylsilyl)-
42557-13-1 omega((trimethylsilyl)oxy)-
4270-70-6 Triphenylsulfonium chloride
42808-36-6 Sodium salt of sulfonated butyl oleate
1-Propanaminium,N-(carboxymethyl)-N,N-dimethyl-3-[(1-
4292-10-8 oxododecyl)amino]-,inner salt
42966-30-3 Decanoic acid, magnesium salt
Benzenesulfonic acid, 4-{{3-{{2-hydroxy-3-{{(4-
methoxyphenyl)amino}carbonyl}-1-naphthalenyl}azo}-4-
43035-18-3 methylbenzoyl}amino}-, calcium salt (2:1)
2-Propanamine, compd. with alpha-phosphono-omega-butoxypoly(oxy-1,2-
431040-31-2 ethanediyl) (2:1)
2-Propanamine, compds. with polyethylene glycol dihydrogen phosphate C8-
431062-72-5 10-alkyl ether (2:1)
Butanedioic acid, sulfo-, 1-[1-methyl-2-[(1-oxo-9-octadecenyl)amino]ethyl]
43154-85-4 ester, disodium salt ()
4316-73-8 Sodium sarcosinate
431-89-0 Propane, 1,1,1,2,3,3,3-Heptafluoro-
2,7-Naphthalenedisulfonic acid, 5-(acetylamino)-3-{{4-
4321-69-1 (acetylamino)phenyl}azo}-4-hydroxy-, disodium salt
4337-75-1 Sodium N-dodecanoyl-N-methyltaurine
4365-60-0 Phosphonium, (2-carboxyethyl)triphenyl-, hydroxide-, inner salt
2-Anthracenesulfonic acid,1-amino-4-(cyclohexylamino)-9,10-dihydro-9,10-
4368-56-3 dioxo-, monosodium sal
4395-65-7 9,10-Anthracenedione, 1-amino-4-(phenylamino)-
Benezenesulfonic acid, 2,2'-{(9,10-dihydro-9,10-dioxo-1,4-
4403-90-1 anthracenediyl)diimino}bis{5-methyl-, disodium salt
Benenesulfonic acid, 2,2'-(1,2-ethenediyl)bis{5-{{4-{bis(2-hydroxyethy)
4404-43-7 amino}-6-(phenylamino)-1,3,5-triazin-2-yl}amino}-
Sulfuric acid, monododecyl ester, compds. with hydrolyzed
hexamethylenediamine-N,N'''-1,6-hexanediylbis[N'-cyanoguanidine]-N,N'-
(methylenedi-4,1-phenylene)bis[N-
441045-43-8 (oxiranylmethyl)oxiranemethanamine]polymer hydrochloride
Benzenesulfonic acid, 2-{(9,10-dihydro-4-hydroxy-9,10-dioxo-1-
4430-18-6 anthracenyl)amino}-5-methyl-, monosodium salt
4437-85-8 1,3-Dioxolan-2-one, 4-ethyl-
3097-08-3 D-Gluconic acid, zinc complex
4468-42-2 Benzene,(1-ethylbutyl)-
Page 40 of 93
Benzenesulfonic acid, 3,3'-((9,10-dihydro-9,10-dioxo-1,4-
4474-24-2 anthracenediyl)diimino)bis(2,4,6-trimethyl-, disodium salt
4477-79-6 2-Naphthalenol, 1-{{2,5-dimethyl-4-{(2-methylphenyl)azo}phenyl}azo}-
4542-57-8 Dodecyl ether
1-Naphthlenesulfonic acid, 4-hydroxy-3-((6-sulfo-2,4-xylyl)azo)-, disodium
4548-53-2 salt
4574-04-3 1-Tetradecanaminium, N,N,N-trimethyl-, chloride
461-58-5 Dicyanodiamide
461679-05-0 Amines, tallow alkyl, ethoxylated, compds. with polyethylene glycol
463-40-1 9,12,15-Octadecatrienoic acid, (9Z, 12Z, 15Z)-
4696-46-2 Sulfuric acid, monooctadecyl ester, ammonium salt
4696-56-4 Dodecanoic acid, calcium salt
470-08-6 1,3,3-Trimethyl-2-norbornanol, (1S-exo)-
470-67-7 7-Oxabicyclo(2.2.1.)heptane, 1-methyl-4-(1-methylethyl)-
4706-78-9 Potassium dodecyl sulfate
4707-47-5 Benzoic acid,2,4-dihydroxy-3,6-dimethyl-,methyl ester
4712-55-4 Diphenyl phosphite
471-34-1 Calcium carbonate
47236-10-2 Benzenesulfonic acid, 4-dodecyl-, calcium salt
4754-44-3 1-Tetradecanol, hydrogen sulfate
479-61-8 Chlorophyll a
480-16-0 Morin
4845-99-2 Brucine sulfate
487-06-9 2H-1-Benzopyran-2-one, 5,7-dimethoxy-
488-30-2 D-Arabinonic acid
489-01-0 2,6-Di-tert-butyl-4-methoxyphenol
493-52-7 Benzoic acid, 2-((4-(dimethylamino)phenyl)azo)-
4940-11-8 4H-Pyran-4-one, 2-ethyl-3-hydroxy-
Anthra{2,1,9-def:6,5,10-d'e'f'}diisoquinoline-1,3,8,10 (2H, 9H)-tetrone, 2,9-
4948-15-6 bis(3,5-dimethylphenyl)-
49553-76-6 9-Octadecenoic acid, ester with 1,2,3-propanetriol
496-46-8 Imidazo(4,5-d)imidazole-2,5(1H,3H)-dione, tetrahydro-
497-19-8 Carbonic acid, disodium salt
498-81-7 Cyclohexanemethanol, alpha, alpha, 4-trimethyl-
499-83-2 2,6-Pyridinedicarboxylic acid
50-14-6 9,10-Secoergosta-5,7,10(19),22-tetraen-3-ol, (3.beta.,5Z,7E,22E)-
50-21-5 Lactic acid
5026-62-0 Sodium methylparaben
504-60-9 1,3-Pentadiene
506-12-7 Heptadecanoic acid
5064-31-3 Trisodium nitrilotriacetate
50643-20-4 Poly(oxy-1,2-ethanediyl), α-hexadecyl-ω-hydroxy-, phosphate
506-87-6 Carbonic acid, diammonium salt
Page 41 of 93
506-93-4 Guanidine nitrate
50-70-4 Sorbitol
50769-39-6 Butylpolyethoxyethanol esters of phosphoric acid
50-81-7 L-Ascorbic acid
509-34-2 Spiro(isobenzofuran-1(3H),9'-(9H)xanthen)-3-one, 3',6'-bis(diethylamino)-
5098-94-2 1-Naphthalenol, 4-{(2-methylphenyl)azo}-
50-99-7 D-Glucose, anhydrous
51-05-8 Procaine hydrochloride
51142-18-8 Bactopeptone
5116-94-9 1-Tridecanol, dihydrogen phosphate
5116-95-0 1-Tridecanol, hydrogen phosphate
51192-09-7 Polyoxyethylene glycerin monooleate
51200-87-4 Oxazolidine, 4,4-dimethyl-
512-13-0 1,3,3-Trimethyl-2-norbornanol, (1S-endo)-
51229-78-8 cis-1-(3-Chloroallyl)-3,5,7-triaza-1-azoniaadamandtine chloride
512-42-5 Sodium methyl sulfate
5131-66-8 1,2-Propylene glycol 1-monobutyl ether
51344-60-6 Ethoxylated abietylamine
Poly(oxy-1,2-ethanediyl), α,α'-((((1,2,3,4,4a,9,10,10a-octahydro-1,4a-
dimethyl-7-(1-methylethyl)-1-phenanthrenyl)methyl)imino)di-2,1-
51344-62-8 ethanediyl)bis(ω-hydroxy-,(1R-(1α,4a.beta.,10aα))-
5136-55-0 Glycine, N-methyl-N-(1-oxooctadecyl)-, sodium salt
5137-55-3 Tricaprylyl methyl ammonium chloride
513-77-9 Barium carbonate
513-79-1 Cobalt carbonate
5138-18-1 Sulfosuccinic acid
51395-75-6 Cellulose, mixt. with cellulose carboxymethyl ether sodium salt
5146-66-7 2,6-octadienenitrile, 3,7-dimethyl-
51-55-8 Atropine
515-98-0 Ammonium lactate
Poly(oxy-1,2-ethanediyl), [alpha]-(4-nonylphenyl)-[omega]-hydroxy-,
51609-41-7 phosphate
51609-52-0 Egg solids
51617-79-9 Polyoxyethylene octadecyl phenol
51650-46-5 Benzenesulfonic acid, 4-methyl-, magnesium salt
51811-79-1 Poly(oxy-1,2-ethanediyl),α-(nonylphenyl)-ω-hydroxy-,phosphate
518-47-8 Fluorescein, disodium
51937-00-9 9,12-Tetradecadien-1-ol, (9E,12Z)-
519-62-0 Chlorophyll b
52019-36-0 Poly(oxy-1,2-ethanediyl),α-decyl-ω-hydroy-,phosphate
520-45-6 2H-Pyran-2,4(3H)-dione, 3-acetyl-6-methyl-
52225-20-4 Vitamin E acetate (dl-form)
52232-27-6 Methyl oxirane polymer with oxirane, methyl 2-propenyl ether
52238-92-3 C.I. Pigment Red 242
Page 42 of 93
Phenol, polymer with formaldehyde, hydroxybenzenesulfonic acid and urea,
52286-56-3 Benzenesulfonic acid, octyl-, potassium salt
52299-20-4 2-((Hydroxymethyl)amino)-2-methyl propanol
52304-21-9 1-Hexadecanol, hydrogen sulfate, ammonium salt
52337-77-6 Benzoic acid, 2-methyl-, barium salt
2,5-Furandione, telomer with ethenylbenzene and (1-methylethyl)benzene,
Poly (oxy-1,2-ethanediyl), [alpha]-(nonylphenyl) -[omega]-hydroxy-
52503-15-8 ,phosphate, potassium salt
52-51-7 Bronopol
52558-73-3 Glycine, N-methyl-N-(1-oxotetradecyl)-
Poly(oxy-1,2-ethanediyl), α-((1,1,3,3-tetramethylbutyl)phenyl)- ω-hydroxy-,
52668-97-0 Poly(oxy-1,2-ethanediyl), α-(1-oxooctadecenyl)-ω-[(1-oxooctadecenyl)oxy]-
Poly(oxy(methyl-1,2-ethanediyl)), α-hydro-ω-hydroxy-, ether with methyl
52673-60-6 .beta.-D-glucopyranoside (4:1)
1-Naphthalenesulfonic acid, 4-{{4,5-dihydro-3-methyl-5-oxo-1-(3-
52677-44-8 sulfophenyl)-1H-pyrazol-4-yl}azo}-3-hydroxy-, chromium complex
526-95-4 D-Gluconic acid
527-07-1 Sodium gluconate
527-09-3 Cupric gluconate
5280-66-0 C.I. Pigment Red 48:4
1234986 C.I. Pigment Red 57:1
1H-Benz(de)isoquinoline-1,3(2H)-dione, 2-(3-hydroxypropyl)-6-((3-
52821-24-6 hydroxypropyl)amino)-
52829-07-9 Bis(2,2,6,6-tetramethyl-4-piperidinyl)sebacate
52831-04-6 2-propenoic acid, polymer with ethenylbenzene and (1-methylethenyl)benzene
Butanedioic acid, methylene-, polymer with 1,3-butadiene, ethenylbenzene and
52831-07-9 2-methyl-2-propenoic acid
52836-31-4 Oxazolidine, 3-(dichloroacetyl)-2,2,5-trimethyl-
52880-57-6 Acrylic acid homopolymer, trimethanolamine salt
52-90-4 Cysteine
53124-00-8 Starch, hydrogen phosphate, 2-hydroxypropyl ether
532-02-5 2-Naphthalenesulfonic acid, sodium salt
53219-21-9 Myrcenol, dihydro-
532-32-1 Benzoic acid, sodium salt
5323-95-5 9-Octadecenoic acid, 12-hydroxy-, monosodium salt, (9Z,12R)-
5324-84-5 Sodium octyl sulfonate
5329-14-6 Sulfamic acid
533-00-6 Benzoic acid, barium salt
53306-54-0 1,2-Benzenedicarboxylic acid, bis (2-propylheptyl) ester
Toluene diisocyanate, oligomeric reaction products with 2,2'-oxydiethanol and.
53317-61-6 propylidenetrimethanol
53320-86-8 Lithium magnesium sodium silicate
Page 43 of 93
5333-42-6 2-Octyl dodecanol
533-74-4 Tetrahydro-3,5-dimethyl-2H-1,3,5-thiadiazine-2-thione
533-96-0 Carbonic acid, sodium salt (2:3)
53404-44-7 9-Octadecenoic acid, 12-(sulfooxy)-, dipotassium salt
53404-45-8 Phosphoric acid, disodium salt, compd. with 2-aminoethanol (1:1)
53404-49-2 Ethylene glycol ether of pinene
53404-78-7 Ethanol, 2-amino-, hydrogen phosphate (ester), monosodium salt
534-13-4 Thiourea, N,N'-dimethyl-
53467-00-8 Sodium dodecyldiphenyl oxide sulfonate
53504-41-9 Polyurethane
53516-76-0 BTC 776
53563-63-6 Tetradecanoic acid, diester with 1,2,3-propanetriol
53610-02-9 Poly(oxy-1,2-ethanediyl),[alpha]-(carboxymethyl)-[omega]-(nonylphenoxy)-
2-propenoic acid, 2-methyl-, 2-(dimethylamino)ethyl ester, polymer with 1-
53633-54-8 ethenyl-2-pyrrolidinone, compd. with diethyl sulfate
53651-69-7 Propyl L-lactate
Poly(oxy-1,2-ethanediyl),alpha-hydro-omega-hydroxy-, ether with D-glucitol
53694-15-8 (6:1)
53801-42-6 Isobutyl methacrylate homopolymer
53850-34-3 Proteins, thaumatins
5392-40-5 Citral
alpha-D-Glucopyranosiduronic acid, (3beta, 20beta)-20-carboxy-11-oxo-30-
53956-04-0 norolean-12-en-3-yl 2-O-beta-D-glucopyranuronosyl-, monoammonium salt
53980-88-4 2-Cyclohexene-1-octanoic acid, 5(or6)-carboxy-4-hexyl-
53988-05-9 Calcium isononanoate
53988-07-1 Decanoic acid, diester with 1, 2 ,3-propanetriol
53998-07-1 Decanoic acid,diester with 1,2,3-propanetriol
540-10-3 Hexadecanoic acid, hexadecyl ester
540-18-1 Amyl butrate
540-69-2 Ammonium formate
540-88-5 Tert-butyl acetate
541-02-6 Cyclopentasiloxane, decamethyl-
54116-08-4 Tridecyl polyoxyethylene sodium sulfate
5413-60-5 4,7-Methano-1H-inden-6-ol, 3a,4,5,6,7,7a-hexahydro-, acetate
5413-75-2 C.I. Acid Red 73
54193-36-1 Sodium polymethacrylate
54-21-7 Sodium salicylate
542-42-7 Hexadecanoic acid, calcium salt
5437-45-6 Acetic acid, bromo-, phenylmethyl ester
54390-90-8 Hypophosphoric acid, ammonium salt
544-31-0 N-(2-Hydroxyethyl)hexadecanamide
54452-17-4 2-Propenoic acid, polymer with ethenylbenzene, sodium salt
544-60-5 Ammonium oleate
544-63-8 Myristic acid
544-64-9 9-Tetradecenoic acid, (9Z)-
Page 44 of 93
54549-23-4 D-Glucoside, octyl
54549-24-5 D-Glucopyranoside, hexyl
54579-44-1 Formaldehyde, polymer with p-tert-butylphenol and Bisphenol A
54612-36-1 Nonylphenylpolyoxyethylene sulfosuccinate
5466-77-3 Octyl p-methoxycinnamate
Butanamide, 2,2'-[(3,3'-dichloro[1,1'-biphenyl]-4,4'-diyl)bis(azo)]bis[N-(2-
5468-75-7 methylphenyl)-3-oxo
546-93-0 Carbonic acid, magnesium salt (1:1)
Isocyanic acid, polymethylenepolyphenylene ester, polymer with N-(2-
54811-79-9 aminoethyl)-1,2-ethanediamine, decanedioyl dichloride and 1,2-ethanediamine
Spiro(isobenzofuran-1(3H),9'-(9H)xanthen)-3-one, 2',4',5',7',-tetrabromo-3',6'-
548-26-5 dihydroxy-, disodium salt
54846-79-6 Polyoxyethylene sorbitan heptaoleate
54862-84-9 Iron chloride (FeCl3), dihydrate
2-Propenoic acid, 2-methyl- 2-(dimethylamino)ethyl ester, polymer with 1-
55008-57-6 ethenyl-2-pyrrolidinone, compd. with dimethyl sulfate
Polyethylene glycol hexaether with sorbitol, diester with dodecanoic and oleic
55069-68-6 acids
55172-98-0 Neodecanoic acid, barium salt
552-30-7 Trimellitic acid andydride (TMA)
55349-01-4 Octadecanamide, N,N'-1,6-hexanediylbis[12-hydroxy-
5536-61-8 Sodium methacrylate
553-70-8 Magnesium benzoate
5538-94-3 1-Octanaminium, N,N-dimethyl-N-octyl-, chloride
55406-53-6 Carbamic acid, butyl-, 3-iodo-2-propynyl ester
554-13-2 Lithium carbonate
55470-69-4 N,N-Dimethyl-1,3-propandiamine dodecyl-4-benzenesulfonate
555-31-7 2-Propanol, aluminum salt
555-35-1 Hexadecanoic acid, aluminum salt
555-43-1 Octadecanoic acid, 1,2,3-propanetriyl ester
55589-62-3 1,2,3-Oxathiazin-4(3H)-one, 6-methyl-, 2,2-dioxide, potassium salt
55598-86-2 Lignosulfonic acid, calcium magnesium salt
55622-30-5 Lithium hydroxide
556-67-2 Cyclotetrasiloxane, octamethyl-
557-04-0 Octadecanoic acid, magnesium salt
557-05-1 Octadecanoic acid, zinc salt
557-09-5 Zinc octanoate
Propanoic acid, 2-hydroxy-, compd. with N-{3-
55819-53-9 (dimethylamino)propyl}octadecanamide (1:1)
55840-82-9 C.I. Basic Blue 3
5590-18-1 Isoindolinone yellow
55934-93-5 Tripropylene glycol n-butyl ether
2-Propenoic acid, 2-methyl-, polymer with ethyl 2-propenoate and methyl 2-
55989-05-4 methyl-2-propenoate, ammonium salt
56073-24-6 Calcium chloride (CaCl2), hydrate (3:1)
Page 45 of 93
56090-69-8 Oxirane, methyl-, polymer with oxirane,monoacetate, 2-propenyl ether
563-71-3 Ferrous carbonate
56388-96-6 Poly(oxyethylene)tridecylacetic acid
56399-31-6 Carbonic acid, disodium salt, heptahydrate
56590-81-9 Plurafac RA 40
56633-27-3 Ethanol, 2-amino-, sulfate (salt)
Poly(oxymethylene),alpha-(1H,3H,5H-oxazolo{3,4-c}oxazol-7a(7H)-
56709-13-8 ylmethyl)- omega -hydroxy-
56780-58-6 Starch, 2-hydroxy-3-(trimethylammonio)propyl ether, chloride
56-81-5 Glycerin
56-85-9 Glutamine
56-86-0 L-Glutamic acid
56863-02-6 9,12-Octadecadienamide, N,N-bis(2-hydroxyethyl)-, (Z,Z)-
Spiro(isobenzofuran-1(3H),9'-(9H)xanthen)-3-one,3',6'-dihydroxy-2',4',5',7'-
568-63-8 tetraiodo-, disodium salt
56-95-1 Chlorhexidine diacetate
56970-73-1 Bis(1-methylheptyl) maleate
5700-49-2 Ethylenediamine dihydroiodide
57-09-0 N,N,N-Trimethyl-1-hexadecanaminium bromide
57-10-3 Hexadecanoic acid
57-11-4 Octadecanoic acid
57-13-6 Urea
57345-19-4 5H-3,5a-Epoxynaphth{2,1-c}oxepin, dodecahydro-3,8,8,11a-tetramethyl-
5743-26-0 Acetic acid, calcium salt, monohydrate
5743-27-1 L-Ascorbic acid, calcium salt (2:1)
57451-03-3 Triethanolamine nonylphenyl polyoxyethylene* sulfuric acid *(6 moles)
57455-37-5 C.I. Pigment Blue 29
57-48-7 D-Fructose
574-93-6 Phthalocyanine
57-50-1 Sucrose
57-55-6 Propylene glycol
57689-21-1 2-Decanol, hydrogen sulfate, sodium salt
577-11-7 Dioctyl sodium sulfosuccinate
5785-44-4 Calcium citrate tetrahydrate
57866-49-6 Lignosulfonic acid, zinc salt
57-88-5 Cholest-5-en-3-ol (3.beta.)-
58048-89-8 Butyl acrylate, butyl methacrylate, methacrylic acid and styrene copolymer
58-08-2 1H-Purine-2,6-dione, 3,7-dihydro-1,3,7-trimethyl-
58128-22-6 Octadecanoic acid, 12-hydroxy-, homopolymer, octadecanoate
58145-14-5 Ethanol, 2-[bis(2-aminoethyl)amino]-
582-25-2 Benzoic acid, potassium salt
582-25-2 Potassium benzoate
584-08-7 Carbonic acid, dipotassium salt
58430-94-7 3,5,5-Trimethylhexyl acetate
5850-16-8 1-Naphthalenesulfonic acid, 4,4'-{(2,4-dihydroxy-1,3-phenylene)bis(azo)}bis-,
Page 46 of 93
disodium salt
Benzenesulfonic acid,4-[(2-hydroxy-1-naphthalenyl)azo]-3-methyl-,
5850-86-2 monosodium salt
58-56-0 Thiamine mononitrate
58572-79-5 Polyflo 130
5858-33-3 C.I. Acid Red 17, disodium salt
5858-82-2 C.I. Pigment Red 52, disodium salt
58-61-7 Adenosine
58654-67-4 2-Octanone, 5-methyl-
586-62-9 Cyclohexene, 1-methyl-4-(1-methylethylidene)-
58694-75-0 Iron chloride (FeCl3), trihydrate
58694-79-4 Iron chloride (FeCl3), nonahydrate
58694-80-7 Iron chloride (FeCl3), dodecahydrate
5870-93-9 Heptyl butyrate
58748-27-9 Fatty acids, C8-10, propylene esters
Neodecanoic acid, ethenyl ester, polymer with 2-butenoic acid and ethenyl
58748-38-2 acetate
587-65-5 2-Chloroacetanilide
587-98-4 Benzenesulfonic acid, 3-((4-(phenylamino)phenyl)azo)-, monosodium salt
58846-77-8 n-Decyl glucoside
58-85-5 Biotin
Ethanol, 2,2',2''-nitrilotris-, compd. with alpha-tridecyl-omega-
58855-61-1 hydroxypoly(oxy-1,2-ethanediyl) phosphate
Ethanol,2,2'-iminobis-,compd. with (9Z)-α-9-octadecenyl-ω-h ydroxypoly(oxy-
58855-63-3 1,2-ethanediyl)phosphate
58-86-6 D-Xylose
58-95-7 D-Vitamin E acetate
589-68-4 Tetradecanoic acid, 2,3-dihydroxypropyl ester
58985-18-5 Terpineol, dihydro-, acetate
590-00-1 2,4-Hexadienoic acid, potassium salt
59-02-9 (+)-[alpha] - Tocopherol
59029-17-3 9-Octadecenoic acid (9Z)-, ester with oxybis [propanediol]
5905-52-2 Ferrous lactate
59113-22-3 Varisoft 222
59139-23-0 Polyethylene glycol nonylphenyl ether phosphate ethanolamine salt
59189-82-1 4,4'-Isopropylidenediphenol alkyl(C12-C15) phosphites
59219-59-9 Butanoic acid, 4-(dodecylamino)-4-oxo-3-sulfo-, disodium salt
59227-89-3 2H-Azepin-2-one, 1-dodecylhexahydro-
1-Propanaminium,N-(carboxymethyl)-N,N-dimethyl-3-[(1-
59272-84-3 oxotetradecyl)amino]-,inner salt
59-30-3 Folic acid
593-29-3 Octadecanoic acid, potassium salt
593-70-4 Fluorochloromethane
593-81-7 Trimethylamine hydrochloride
59-40-5 N-(2-Quinoxalinyl)sulfanilide
Page 47 of 93
Thiazolium, 3-[(4-amino-2-methyl-5-pyrimidinyl)methyl]-5-(2-hydroxyethyl)-
59-43-8 4-methyl- chloride
2-Naphthalenecarboxamide, 4-{{5-{{{4-
(aminocarbonyl)phenyl}amino}carbonyl}-2-methoxyphenyl}azo}-N-(5-
59487-23-9 chloro-2,4-dimethoxyphenyl)-3-hydroxy-
5949-29-1 Citric acid monohydrate
59-51-8 Racemethionine
59572-10-0 1,3,6,8-Pyrenetetrasulfonic acid, tetrasodium salt
5964-35-2 Ethylenediaminetetraacetic acid (EDTA) tetrapotassium salt
5964-35-2 Tetrapotassium ethylenediaminetetraacetate
59-67-6 Nicotinic acid
Sodium carbonate
59720-42-2 1H,3H,5H-Oxazolo(3,4-c)oxazole, methanol deriv.
59766-31-3 Potassium titanium oxide (K2 Ti8 O17)
59766-35-7 Zinc oxide sulfate (Zn4O3(SO4))
Poly(oxy-1,2-ethanediyl), alpha-hydro-omega-hydroxy-, ether with D-glucitol
59800-21-4 (6:1), (z)-9-octadec
59862-22-5 4-Hexadecanol, hydrogen sulfate, ammonium salt
598-62-9 Carbonic acid, manganese(2+) salt (1:1)
5989-27-5 d-Limonene
59947-98-7 Triton X 193
59947-99-8 beta-D-Glucoside, decyl
59952-82-8 Benzenesulfonic acid, isododecyl-, sodium salt
60-00-4 Ethylenediaminetetraacetic acid
60092-15-1 Maleic anhydride-methylstyrene copolymer sodium salt
60-12-8 Phenyl ethyl alcohol
60177-39-1 Styrene-divinyl benzene copolymer resin matrix
6028-57-5 Octanoic acid, aluminum salt
60-29-7 Ethane, 1,1'-oxybis-
6031-02-3 Benzene,(1-methylpentyl)-
60-33-3 Linoleic acid
60381-61-5 2-Propenoic acid, 2-ethylhexyl ester, polymer with ethenylmethylbenzene
60676-86-0 Silica, vitreous
60684-13-1 Iron chloride (FeCl3), monohydrate
60789-81-3 Dimethylamine citrate
1-Octadecanaminium, N-(2-(2-carboxyethoxy)ethyl)-N-(2-hydroxyethyl)-N-
60789-83-5 methyl-
60816-37-7 Dodecylbenzenesulfonic acid, compd. with 1,3-propanediamine
60816-39-9 N,N-Dimethyl-1,3-propanediamine dodecylbenzenesulfonate
60816-63-9 Triethylamine ethylenediaminetetraacetate
60828-78-6 Polyoxyethylene* trimethylnonyl ether *(6 moles)
60828-92-4 Isopropylamine sulfate
60840-85-9 Glycine, N,N-bis(carboxymethyl)-, compd. with N,N-diethylethanamine (1:3)
Page 48 of 93
60840-87-1 Ethanesulfonic acid, 2-(9-octadecenylamino)-, monosodium salt, (Z)-
60864-33-7 Benzyl ether of 1,1,3,3-tetramethylbutylphenoxypolyethoxy ethanol
60874-89-7 Polyoxyethylene* methylenebis(diamylphenol) *(18 moles)
60874-90-0 Sodium isopropyl isobutyl naphthalene sulfonate
60883-84-3 Sodium methylnonylnaphthalene sulfonate
60883-89-8 Tridecylbenzenesulfonic acid, dimethylamine salt
60883-90-1 Dimethylamine propylamine tridecylbenzenesulfonate
60933-42-8 Trimethylnaphthalenesulfonic acid sodium salt
609-54-1 Benzenesulfonic acid, 2,5-dimethyl-
6100-05-6 Citric acid, tripotassium salt, monohydrate
6104-30-9 Isobutylidenediurea
6104-58-1 C.I. Acid Blue 90
6104-59-2 C.I. Acid Blue 83
6107-56-8 Calcium octanoate
2-Propenoic acid, 2-methyl-, dodecyl ester, polymer with 1,2-ethanediyl bis(2-
61181-29-1 methyl-2-propenoate)
6131-90-4 Acetic acid, sodium salt, trihydrate
6132-02-1 Carbonic acid, disodium salt, decahydrate
6132-04-3 Citric acid, trisodium salt, dihydrate
614-45-9 tert-Butyl perbenzoate
6152-33-6 [1,1'-Biphenyl]-2-ol, sodium salt, tetrahydrate
61524-98-9 Polyoxyethylene* hydroabietyl alcohol *(16 moles)
6153-56-6 Ethanedioic acid, dihydrate
61693-41-2 Ethanol, 2,2'-iminobis-, compd. with hexadecyl dihydrogen phosphate
1H-Imidiazolium, 1,1-bis(carboxymethyl)-4,5-dihydro-2-undecyl-, hydroxide,
Tridecyloxypoly(ethyleneoxy)* poly(propyleneoxy)**-2-propanol *(9 moles)
61725-89-1 **(3 moles)
61-73-4 3,7-Bis(dimethylamino)-phenothiazin-5-ium chloride
61757-59-3 Poly(oxy-1,2-ethanediyl), α-(carboxymethyl)-ω-(tridecyloxy)-, sodium salt
61788-44-1 Styrenated phenol
61788-47-4 Fatty acids, coco
61788-48-5 Acetylated lanolin
61788-59-8 Fatty acids, coco, Me esters
61788-60-1 Methyl esters of cottonseed oil
61788-61-2 Fatty acid esters, tallow, Me ester
61788-65-6 Fattys acids, vegetable-oil, potassium salts
61788-66-7 Fatty acids, vegetable-oil
61788-67-8 Fatty acids, vegetable-oil, sulfated, sodium salts
61788-72-5 Octyl epoxytallate
61788-85-0 Castor oil, hydrogenated, ethoxylated
61788-89-4 Fatty acids, C18-unsatd., dimers
61788-92-9 Dimethyl soya alkyl ammonium chloride
61788-93-0 Coco dimethylamine
61789-01-3 Tall oil, epoxidized, 2-ethylhexyl esters
Page 49 of 93
61789-14-8 Glycerides, tallow sesqui-, hydrogenated
61789-18-2 Coco alkyltrimethyl quaternary ammonium chlorides
61789-23-9 Fatty acids, corn-oil, potassium salts
61789-24-0 Fatty acids, corn-oil, sodium salts
61789-30-8 Fatty acids, coco, potassium salts
61789-31-9 Fatty acids, coco, sodium salts
61789-36-4 Calcium naphthenate
1-Propanaminium, 3-amino-N-(carboxymethyl)-N,N-dimethyl-, N-coco acyl
61789-39-7 derivs., chlorides, sodium salts
61789-40-0 Cocamidopropyl betaine
61789-51-3 Cobalt naphthenate
61789-56-8 Fatty acids, peanut-oil, potassium salts
61789-57-9 Fatty acids, peanut-oil, sodium salts
61789-60-4 Coal tar
61789-65-9 Resin acids and rosin acids, aluminum salts
61789-72-8 Dimethyl benzyl hydrogenated tallow ammonium cation
61789-73-9 Dialkyl(hydrogenated tallow)benzylmethylammonium chloride
61789-75-1 Benzyldimethyl-9-octadecenylammonium chloride
61789-76-2 Cocodiamine
61789-77-3 Dialkyl* dimethyl ammonium chloride *(as in fatty acids of coconut oil)
Quaternary ammonium compounds, bis(hydrogenated tallow alkyl)dimethyl,
61789-80-8 chlorides
61789-86-4 Calcium petroleum sulfonates
61789-91-1 Jojoba seed oil
61789-97-7 Tallow
61789-98-8 Cork
61789-99-9 Lard
61790-12-3 Fatty acids, tall-oil
61790-24-7 Fatty acids, soya, potassium salts
61790-25-8 Fatty acids, soya, sodium salts
61790-31-6 Amides, tallow, hydrogenated
61790-33-8 Amines, tallow alkyl
61790-37-2 Fatty acids, tallow
61790-38-3 Fatty acids, tallow, hydrogenated
61790-41-8 Quaternary ammonium compounds,trimethylsoya alkyl, chlorides
61790-47-4 Amines, rosin alkyl
61790-50-9 Potassium salt of wood rosin acids
61790-51-0 Sodium salt of hydrocarbon insoluble fraction of rosin
61790-53-2 Kieselguhr (less than !% crystalline silica)
61790-59-8 Hydrogenated tallow alkyl amine acetate
61790-63-4 Diethanolamine cocoate
61790-66-7 Fatty acids, tall-oil, compds. with diethanolamine
61790-85-0 Ethoxylated N-tallow alkyltrimethylene diamines
61790-86-1 Fatty acids, tall-oil, monoesters with sorbitan, ethoxylated
61790-88-3 Fatty acids, tall-oil, triesters with sorbitan, ethoxylated
Page 50 of 93
61790-90-7 Polyoxyethylene* sorbitol hexa tall oil ester *(40 moles)
61790-92-9 Polyoxyethylene* sorbitol penta tall oil ester *(40 moles)
61791-00-2 Polyethylene glycol ester of tall oil fatty acids
61791-01-3 Fatty acids, tall-oil, diesters with polyethylene glycol
61791-06-8 Polyethylene glycol sesquiester of tallow acids
61791-07-9 Fatty acids, soya, ethoxylated
61791-08-0 Polyoxyethylene* monoethanolamide of coconut oil fatty acids *(2 moles)
Quaternary ammonium compounds, coco alkylbis(hydroxyethyl)methyl,
61791-10-4 ethoxylated, chlorides
61791-12-6 Castor oil, ethoxylated
61791-14-8 Amines, cocoakyl, ethoxylated
61791-23-9 Soybean oil, ethoxylated
61791-24-0 Amines, soya alkyl, ethoxylated
61791-26-2 Polyoxyethylene* tallow amine *(20 moles)
61791-28-4 Alcohols, tallow, ethoxylated
61791-29-5 Fatty acids, coco, ethoxylated
61791-31-9 N,N-Bis(2-hydroxyethyl)(coconut oil alkyl)amine
61791-34-2 Onium compounds, morpholinium, 4-ethyl-4-soya alkyl, Et sulfates
61791-41-1 Sodium N-methyl-N-(tall-oil alkyl) taurate
61791-44-4 Alkyl* N,N-bis(2-hydroxyethyl)amine *(100% C12-C18)
61791-47-7 Bis(2-hydroxyethyl) cocoamine oxide
61791-48-8 Fatty acid, tall-oil, monoesters with sorbitan
61791-53-5 N-Tallow alkyltrimethylenediamines, oleates
61791-56-8 .beta.-Alanine, N-(2-carboxyethyl)-, N-tallow alkyl derivs., disodium salts
61791-59-1 Glycine, N-methyl-, N-coco acyl derivs., sodium salts
61792-31-2 Dodecanamide, N-[3-(dimethyloxidoamino) propyl]-
617-97-0 Benzenesulfonic acid, 3-methyl-
61814-79-7 C.I. Direct Blue 189
Poly(oxy-1,2-ethanediyl), . alpha.-hydro-ω-hydroxy-, ether with D-glucitol
61824-34-8 (1:1), penta-9-octadecenoate, (all-Z)-
61827-84-7 (Octyloxy) poly(oxyethylene) poly(oxypropylene)
Benzoic acid, 4-{{(2,5-dichlorophenyl)amino}carbonyl}-2-{{2-hydroxy-3-
61847-48-1 {{(2-methoxyphenyl)amino}carbonyl}-1-naphthalenyl}azo}-, methyl ester
61849-72-7 Polypropylene glycol beta-methyl glucoside ether (4:1)
61916-40-3 Disodium cupric ethylenediaminetetraacetate
61931-75-7 Benzenesulfonic acid, undecyl-, ammonium salt
6197-30-4 2-Ethylhexyl 2-cyano-3,3-diphenylacrylate
Urea, N,N'bis(hydroxymethyl)-, polymer with formaldehyde and
62073-57-8 (hydroxymethyl)urea
Poly(oxy-1,2-ethanediyl), α, α'-{{{4-{(2,5-
disulfophenyl)azo}phenyl}imino}di-2,1-ethanediyl}bis{ω-hydroxy-, disodium
62147-77-7 salt
6227-14-1 C.I. Direct Violet 9, disodium salt
62-33-9 Calcium disodium ethylenediaminetetraacetate
62386-95-2 Methyl vinyl ether-maleic acid copolymer calcium sodium salt,minimum numb
Page 51 of 93
624-15-7 2,6-Octadien-1-ol, 3,7-dimethyl-
624-41-9 2-Methyl butyl acetate
62449-33-6 1-Heptadecenyl-2-(hydroxyethyl)imidazolinium chloride
6252-76-2 FD&C Red No. 3
62-54-4 Calcium acetate
62563-36-4 N-Coco beta-aminopropionic acid (No established approval)
62587-57-9 Disodium N-tallow beta-iminodipropionate (No established approval)
6259-76-3 Hexyl salicylate
6272-74-8 N-Lauroyl ester of colaminoformylmethylpyridinium chloride
627-83-8 Octadecanoic acid, 1,2-ethanediyl ester
627-93-0 Hexanedioic acid, dimethyl ester
6283-86-9 2-Ethylhexyl lactate
628-63-7 Amyl acetate
629-25-4 Dodecanoic acid, sodium salt
629-70-9 Cetyl acetate
6303-21-5 Hypophosphorus acid
63089-86-1 Polyoxyethylene sorbitol tetraoleate
63148-52-7 Siloxanes and silicones, di-Me, Me Ph
63148-55-0 Siloxanes and Silicones, di-Me, hydroxy-terminated, ethoxylated
63148-56-1 Siloxanes and silicones, Me 3,3,3-trifluoropropyl
63148-57-2 Poly(methylhydrosiloxane)
63148-62-9 Polydimethylsiloxane, methyl end-blocked
63148-65-2 Polyvinyl butyral
63148-69-6 Alkyd resins
Butyl methacrylate styrene 2-hydroxyethyl acrylate methyl methacrylate
63150-02-7 polymer
2-Propenoic acid, 2-methyl-, dodecyl ester, polymer with eicosyl 2-methyl-2-
propenoate, hexadecyl 2-methyl-2-propenoate, octadecyl 2-methyl-2-
propenoate, pentadecyl 2-methyl-2-propenoate, tetradecyl 2-methyl-2-
63150-03-8 propenoate and tridecyl 2-methyl-2-propenoate
631-61-8 Ammonium acetate
63182-08-1 Sodium vinylbenzenesulfonate, polymer with divinylbenzene
63231-60-7 Paraffin waxes and hydrocarbon waxes, microcryst
63231-67-4 Silica gel
63231-81-2 Poly(vinylpyrrolidone-1-hexadecene)
633-03-4 C.I. Basic Green 1
63393-89-5 Coumarone-indene resins
63393-93-1 Isopropyl lanolin
633-96-5 Benezenesulfonic acid, 4-((2-hydroxy-1-naphthalenyl)azo)-, monosodium salt
63-42-3 Lactose
63428-83-1 Polyamides
63428-91-1 Formaldehyde, polymer with p-tert-amylphenol, methyloxirane and oxirane
63428-93-3 Polyoxyethylene p-(tert-amyl)phenol-formaldehyde resin
63449-39-8 Chlorinated wax
63466-93-3 Oxirane, methyl-, polymer with oxirane, ether with oxybis(propanol) (2:1)
Page 52 of 93
6358-30-1 C.I. Pigment Violet 23
6358-31-2 Butanamide,2-?(2-methoxy-4-nitrophenyl)azoU-N-(2-methoxyphenyl)-3-oxo-
6358-69-6 1,3,6-Pyrenetrisulfonic acid, 8-hydroxy-, trisodium salt
2-Anthracenesulfonic acid, 1-amino-9,10-dihydro-4-{(4-
63589-10-6 methoxyphenyl)amino}-9,10-dioxo-, monosod
6359-45-1 C.I. Basic Violet 16
Benzenesulfonic acid, 4-(4,5-dihydro-3-methyl-5-oxo-4-(phenylazo)-1H-
6359-82-6 pyrazol-1-yl)-, sodium salt
Benezenesulfonic acid, 4-chloro-3-(4,5-dihydro-3-methyl-5-oxo-4-
6359-90-6 (phenylazo)-1H-pyrazol-1-yl)-, sodium salt
Benzenesulfonic acid, 2,5-dichloro-4-{4,5-dihydro-3-methyl-5-oxo-4{(4-
6359-98-4 sulfophenyl)azo}-1H-pyrazol-1-yl}-, disodium salt
63-68-3 L-Methionine
63705-03-3 1,2,3-Propanetriol, homopolymer, diisooctadecanoate
637-12-7 Octadecanoic acid, aluminum salt
637-39-8 Triethanolamine hydrochloride
Butyl acrylate-ethyl acrylate-methacrylic acid-methyl methacrylate-styrene
63798-35-6 Starch acetate adipate
6381-77-7 D-erythro-Hex-2-enoic acid, gamma-lactone, monosodium salt
6381-92-6 Glycine, N,N'-1,2-ethanediylbis[N-(carboxymethyl)-, dispdium salt, dihydrate
64-02-8 EDTA tetrasodium salt
64044-51-5 Lactose, monohydrate
Benzenesulfonic acid, 2,2'-{(9,10-dihydro-9,10-dioxo-1,5-
6408-63-5 anthracenediyl)diimino}bis{5-methyl-, disodium salt
6408-78-2 C.I. Acid Blue 25
2-Anthracenesulfonic acid, 1-amino-9,10-dihydro-4-((4-methyl-2-
6408-80-6 sulfophenyl)amino)-9,10-dioxo-, disodium salt
2-Naphthalenecarboxamide, N-(5-chloro-2,4-dimethoxyphenyl)-4-{{5-
6410-41-9 {(diethylamino)sulfonyl}-2-methoxyphenyl}azo}-3-hydroxy-
64114-42-7 Phosphoric acid, monobutyl ester, disodium salt
64116-22-9 Benzenesulfonic acid, 4-(1 -hexyldecyl)-, sodium salt
64130-91-2 Polyoxyethylene (tert-amyl)phenol-formaldehyde resin
1648615 1,3-Dioxolane-2-acetic acid, 2-methyl-, ethyl ester
64147-40-6 Dehydrated castor oil
2,7-Naphthalenedisulfonic acid,3-[(5-chloro-2-phenoxyphenyl)azo]-4-hydroxy-
6416-66-6 5-[[(4-methylphenyl)
Benzenesulfonic acid, 5-(2H-naphtho[1,2-d]triazol-2-yl)-2-(2-phenylethenyl)-,
64-17-5 Ethanol
64175-88-8 Polyoxyethylene polyoxypropylene monoisopropanolamide of capric acid
Polyoxyethylene* polyoxypropylene** monoisopropanolamide of mixed
64175-92-4 caprylic and capric acids *(5 moles) **(10 moles)
64175-94-6 Calcium chloride hydroxide hypochlorite, dihydrate
64-18-6 Formic acid
Page 53 of 93
6419-19-8 Phosphonic acid, {nitrilotris(methylene)}tris-
64-19-7 Acetic acid
Benzenesulfonic acid, 2-[(4-amino-3-bromo-9,10-dihydro-9,10-dioxo-
6424-75-5 anthracenyl)amino]-5-methyl-, monosodium salt
6424-85-7 C.I. Acid Blue 40
Isoparaffinic petroleum hydrocarbons, synthetic (conforming to 21 CFR
64365-06-6 561.365)
64365-11-3 Charcoal, activated
64365-17-9 Pentaerythritol ester of maleic anhydride - modified wood rosin
64365-23-7 Siloxanes and silicones, di-Me, hydroxy-terminated, ethoxylated propoxylated
1,3-Benzenedicarboxylic acid, polymer with 1,3-dihydro-1,3-dioxo-5-
isobenzofurancarboxylic acid and 2-ethyl-2-(hydroxymethyl)-1,3-propanediol,
64382-04-3 (Z,Z)-9,12-octadecadienoate
2-Propenoic acid, 2-methyl-, 2-(diethylamino)ethyl ester, polymer with
dodecyl 2-methyl-2-propenoate, ethenylbenzene, hexadecyl 2-methyl-2-
64399-38-8 propenoate and tetradecyl 2-methyl-2-propenoate
6440-58-0 Dimethylol-5,5-dimethylhydantoin
64427-33-4 Hi-Sol 10
D-Glucitol, 6-O-alpha-D-glucopyranosyl-, mixt. with 1-O-alpha-D-
64519-82-0 glucopyranosyl-D-mannitol
64665-10-7 Sodium tributylnaphthalenesulfonate
64665-57-2 Methyl-1H-benzotriazole, sodium salt
2-Naphthalenesulfonic acid, 7-amino-4-hydroxy-3-??4-?(4-
64683-40-5 sulfophenyl)azoUphenylUazoU-, compd. with 2,2',2''-nitrilotris?ethanolU (1:2)
6471-49-4 C.I. Pigment Red No. 23
64741-41-9 Naphtha (petroleum), heavy straight run
64741-50-0 Distillates (petroleum), light paraffinic
64741-51-1 Distillates (petroleum), heavy paraffinic
64741-52-2 Distillates (petroleum), light naphthenic
64741-53-3 Distillates (petroleum), heavy naphthenic
64741-59-9 Distillates (petroleum), light catalytic cracked
64741-65-7 Naphtha (petroleum), heavy alkylate
64741-66-8 Naphtha, petroleum, light alkylate
64741-67-9 Residues (petroleum), catalytic reformer fractionator
64741-88-4 Distillates, petroleum, solvent-refined heavy paraffinic
64741-89-5 Distillates, petroleum, solvent-refined light paraffinic
64742-14-9 Distillates (petroleum), acid treated light
64742-16-1 Petroleum resins
64742-42-3 Petroleum wax, clay-treated, microcryst.
64742-43-4 Paraffin waxes (petroleum), clay-treated
64742-46-7 Distillates (petroleum) hydrotreated middle
64742-47-8 Distillates (petroleum), hydrotreated light
64742-48-9 Aliphatic oil
64742-51-4 Petroleum wax
64742-54-7 Distillates (petroleum), hydrotreated heavy paraffinic
Page 54 of 93
64742-55-8 Distillates (petroleum), hydrotreated light paraffinic
64742-56-9 Distillate (petroleum), solvent dewaxed light paraffinic distillate
64742-65-0 Distillates (petroleum), solvent-dewaxed heavy paraffinic
64742-69-4 Petrolatum
64742-81-0 Kerosene (petroleum) hydrodesulfurized
64742-88-7 Solvent naphtha (petroleum), medium aliphatic
64742-89-8 Solvent naphtha (petroleum), light aliph.
64742-94-5 Heavy aromatic solvent naphtha (petroleum)
64742-95-6 Solvent naphtha (petroleum), light aromatic
64742-96-7 Solvent naphtha (petroleum), heavy aliphatic
64743-02-8 Alkenes, α-
64754-90-1 Chlorinated polyethylene
64754-97-8 Fatty acids, coco, calcium salts
64755-04-0 Hydroxylated aminoethylamide
Quaternary ammonium compounds, bis(hydroxyethyl)methyltallow alkyl,
64755-05-1 ethoxylated, chlorides
64771-72-8 Paraffins (petroleum), normal C5-20
6484-52-2 Ammonium nitrate
6485-40-1 2-Cyclohexen-1-one,2-methyl-5-(1-methylethenyl)-,(5R)-
64-86-8 Colchicine
6487-39-4 Lanthanum carbonate octahydrate (La2(CO3)3.8H2O)
65071-95-6 Polyoxyethylene tall-oil (Mol. Wt. 700-5000)
65072-00-6 Caseins, hydrolyzates
65087-00-5 1,3-Benzenediol, 2,4-bis[(4-dodecylphenyl)azo]-
65122-06-7 C.I. Basic Red 14 acetate
65138-84-3 1-Hexadecanol, dihydrogen phosphate, compd. with diethanolamine (1:2)
65143-89-7 Disodium hexadecyldiphenyloxide disulfonate
65-23-6 3,4-Pyridinedimethanol, 5-hydroxy-6-methyl-
6528-34-3 Butanamide, 2-[(4-methoxy-2-nitrophenyl)azo]-N-(2-methoxyphenyl}-3-oxo-
65330-59-8 1,2,3-propanetricarboxylic acid, 2-hydroxy-, copper(2+) sodium salt (1:1:2)
65381-09-1 Decanoic acid, ester with 1,2,3-propanetriol octanoate
Xanthylium, 9-(2,4-dicarboxyphenyl)-3,6-bis(diethylamino)-, hydroxide, inner
65392-81-6 salt, sodium salt
2-Propenoic acid, 2-methyl-, dodecyl ester, polymer with hexadecyl 2-methyl-
2-propenoate, octadecyl 2-methyl-2-propenoate and tetradecyl 2-methyl-2-
6542-37-6 1H,3H,5H-Oxazolo(3,4-c)oxazole-7a(7H)-methanol
Butanedioic acid, dimethyl ester, polymer with 4-hydroxy-2,2,6,6-tetramethyl-
65447-77-0 1-piperidineethanol (For colorant use only)
Poly(difluoromethylene), α-fluoro-ω-[2-[(2-methyl-1-oxo-2-
65530-66-7 propenyl)oxy]ethyl]-
65530-85-0 alpha-(Cyclohexylmethyl)-omega-hydropoly(difluoromethylene)
Poly(oxy-1,2-ethanediyl), alpha-hydro-omega-hydroxy-, ether with alpha-
65545-80-4 fluoro-omega-(2-hydroxyethyl)poly(difluoromethylene) (1:1)
Page 55 of 93
65573-03-7 9-Octadecenoic acid (9Z)- hexaester with decaglycerol
657-84-1 Benzenesulfonic acid, 4-methyl-, sodium salt
65-85-0 Benzoic acid
65996-61-4 Pulp, cellulose
65996-63-6 Starch, acid-hydrolyzed
65996-94-3 Phosphate rock and Phosphorite, calcined
65996-98-7 Terpenes and terpenoids, limonene fraction
65997-05-9 Rosin, partially dimerized
65997-06-0 Rosin, partially hydrogenated
65997-10-6 Rosin, fumarated, polymer with glycerol
65997-13-9 Resin acids and rosin acids, hydrogenated , esters with glycerol
65997-15-1 Cement, portland, chemicals
66068-84-6 Cyclohexanol, 4-(5,5,6-trimethylbicyclo{2.2.1}hept-2-yl)-
66070-58-4 Benzene, ethenyl-, polymer with 1,3-butadiene, hydrogenated
66070-60-8 Soybean oil,polymer with pentaerythritol and phthalic anhydride
66070-61-9 Soybean oil, polymer with glycerol and pentaerythritol
Fatty acids, tall-oil, polymers with glycerol, pentaerythritol and phthalic
66070-62-0 anhydride
66070-64-2 Linseed oil, polymer with pentaerythritol and phthalic anhydride
Soybean oil, polymer with glycerol, linseed oil, pentaerythritol and phthalic
66070-75-5 Fatty acids, tall-oil, polymers with bisphenol A and epichlorohydrin
66070-87-9 Polyglyceryl phthalate ester of coconut oil fatty acid (Mol. Wt. 1000-3000)
66070-93-7 Soybean oil, polymer with glycerol, pentaerythritol and phathalic anhydride
66071-03-2 Linseed oil, polymd.,oxidized
66071-16-7 Soybean oil, polymer with maleic anhydride
Fatty acids, tall-oil, polymers with glycerol, pentaerythritol, phthalic anhydride
66071-79-2 and rosin
66071-86-1 Soybean oil, polymer with isophthalic acid and pentaerythritol
66071-93-0 Fatty acids, cottonseed-oil, potassium salts
66071-94-1 Corn, steep liquor
66071-95-2 Fatty acids, cottonseed-oil, sodium salts
66071-96-3 Glutens, corn
661-19-8 1-Docosanol
3,6,9,12,15,18,21,24,-Octaoxahexacosan-1-ol, 26-(nonylphenoxy)-, dihydrogen
6623-40-1 Dimethylamine sulfonate
2,7-Naphthalenedisulfonic acid, 5-(acetylamino)-4-hydroxy-3-((2-
6625-46-3 methoxyphenyl)azo)-, disodium salt
66402-68-4 Metakaolin
66455-14-9 Alcohols, C12-13, ethoxylated
2,2',2"-Nitrilotrisethanol polymer with 1,4-dichloro-2-butene and N,N,N',N'-
66507-71-9 tetramethyl-2-butene-1,4-diamine
66-71-7 1,10-Phenanthroline
Page 56 of 93
66733-21-9 Erionite
Benzenepropanoic acid,3,5-bis(1,1-dimethylethyl)-4-hydroxy-,2,2-bis{{3-{3,5-
6683-19-8 bis(1,1-dimethylethyl
Isooctadecanoic acid, 2-(1-carboxyethoxy)-1-methyl-2-oxoethyl ester, sodium
66988-04-3 salt
66988-47-4 Polyoxyethylene polyoxypropylene mono(4-nonylphenyl) ether
Thiazolium, 3-[(4-amino-2-methyl-5-pyrimidinyl)methyl]-5-(2-hydroxyethyl)-
67-03-8 4-methyl-chlorode, monohydrochloride
6706-59-8 L-Gulitol
67254-73-3 Glycerides, mixed mono- and di-
67254-79-9 Fatty acids
67267-95-2 Benzenesulfonic acid, 4-(1 -heptylnonyl)-, sodium salt
6728-26-3 2-Hexenal, (2E)-
6737-68-4 1,4-Bis(2-methylanilino)anthraquinone
67401-50-7 Tetrasodium ethylenediaminetetraacetate trihydrate
67409-24-9 Sodium lauryl glyceryl ether sulfonate
67-43-6 Diethylene triamine pentaacetic acid
67-48-1 Choline chloride
67554-50-1 Phenol, octyl-
67-56-1 Methanol
67-63-0 Isopropyl alcohol
67633-86-7 Sulfuric acid, monooctyl ester, magnesium salt
67633-88-9 Sulfuric acid, monooctyl ester, ammonium salt
67-64-1 Acetone
67674-67-3 3-(Polyoxyethylene)propylheptamethyltrisiloxane
67-68-5 Dimethyl sulfoxide
67700-49-6 Rosin polymer with p-tert-butylphenol, formaldehyde and glycerol
Fatty acids, tall-oil, polymer with maleic anhydride, pentaerythritol and
67700-71-4 phthalic anhydride
67700-73-6 Soya alkyd resin
Soybean oil, polymer with ethylene glycol, pentaerythritol and phthalic
67700-81-6 Linseed oil, polymer with isophthalic acid and trimethylolpropane
67700-92-9 Fatty acids, tall-oil, polymers with pentaerythritol and phthalic anhydride
67701-05-7 Fatty acids, C8-18 and C18-unsatd.
67701-08-0 Fatty acids, C16-18 and C18-unsatd.
67701-09-1 Fatty acids, C8-18 and C18-unsatd., potassium salts
67701-10-4 Fatty acids, C8-18 and C18-unsatd., sodium salts
67701-31-9 Glycerides, C8-18 and C18-unsatd. mono- and di-
67701-33-1 Glycerides, C14-18 mono- and di-
67746-02-5 Fatty acids, coco, polymers with glycerol and phthalic anhydride
67746-05-8 Tall oil fatty acid isophthalic alkyd
67746-08-1 Linseed oil, polymd.
Fatty acids, tall-oil, polymer with ethylene glycol, pentaerythritol, and phthalic
Page 57 of 93
Soybean oil, polymer with ethylene glycol, glycerol, pentaerythritol and
67762-09-8 phthalic anhydride
67762-11-2 Soybean oil, polymer w. fumaric acid, pentaerythritol and phthalic anhydride
Soybean oil, polymer w. glycerol, maleic acid, pentaerythritol, and phthalic
Soybean oil, polymer with maleic anhydride, pentaerythritol and phthalic
Poly(oxy-1,2-ethanediyl),alpha-sulfo-omega-hydroxy-, C10-16-alkyl ethers,
67762-19-0 ammonium salts
67762-27-0 Alcohols, C16-18
67762-38-3 Fatty acids, C16-18 & C18-unsatd., Me esters
Silanes and siloxanes, 3-cyanopropyl Me, di-Me, 3-hydroxypropyl Me, ethers
67762-84-9 with polyethylene-polypropylene glycol mono-Me ether
Siloxanes and silicones, di-Me, 3-hydroxypropyl Me, ethers with polyethylene-
67762-85-0 polypropylene glycol mono-Me ether
67762-85-0 Silicone - glycol copolymer
Siloxanes and silicones, di-Me, 3-hydroxypropyl Me, ethers with polyethylene-
67762-87-2 polypropylene glyc
67762-90-7 Dimethyl siloxane polymer with silica
67762-94-1 Siloxanes and silicones, di-Me, Me vinyl
Siloxanes and silicones, di-Me,hydroxy-terminated, ethers with polypropylene
67762-96-3 glycol mono-Bu eth
67762-97-4 Siloxanes and silicones, ethoxy Me
67763-08-0 Alcohols, C-20-28, ethoxlated
67774-59-8 Soybean oil, polymer with glycerol, isophthalic acid and pentaerythritol
67784-88-7 Glycerides, palm-oil mono- and di-, hydrogenated, ethoxylated
67785-93-7 Potassium sulfatoricinoleate
9-Octadecenamide, N,N'-{iminobis(2,1-ethanediylimino-2,1-ethanediyl)}bis-,
67785-94-8 (Z,Z)-
2-Naphthalenesulfonic acid, 6-amino-4-hydroxy-5-{{2-
67786-14-5 (trifluoromethyl)phenyl}azo}-, monosodium s
67806-10-4 Tetradecanamide, N-[3-(dimethyoxidoamino)propyl]-
67874-52-6 Barium methyl benzoate
67890-05-5 Benzenesulfonic acid, isodecyl-, calcium salt
67891-79-6 Heavy aromatic distillate (petroleum)
67891-80-9 Light aromatic distillate (petroleum)
2-Propenoic acid, 2-methyl-, polymer with butyl 2-propenoate, ethene,
67892-91-5 ethenylbenzene, ethyl 2-propenoate and methyl 2-methyl-2-propenoate
1,2-Ethanediamine, N-(2-aminoethyl)-, polymer with 1,2-dichloroethane and
67905-86-6 (Z)-9-octadecen-1-amine
Polyethylene glycol ether with 2,2'-methylenebis(4,6-bis(tert-pentyl)phenol)
67906-06-3 (2:1)
67906-08-5 Polyethylene glycol monoeicosyl ether
a-(p-Nonylphenyl)-omega-hydroxypolyoxyethylene, mixture of monohydrogen
67922-57-0 and dihydrogen phosphate esters, magnesium salt
67922-98-9 Linseed oil, polymer with maleic anhydride and pentaerythritol
Page 58 of 93
Benzezesulfonic acid, 2,5-dichloro-4-{4,5-dihydro-3-methyl-4-{{4-{{(4-
67923-65-3 methylphenyl)sulfonyl}oxy
Benzenesulfonic acid, 4-dodecyl-, compd. with 2-[(2-
67924-20-3 aminoethyl)amino]ethanol (2:1)
67952-66-3 Ethylenediamine dodecylbenzenesulfonate
67952-68-5 Bicyclo{2.2.1}heptan-2-ol, ethyl-1,3,3-trimethyl-
Phenol, 4-dodecyl-, polymer with 1,2-ethanediamine and formaldehyde,
67953-82-6 compd. with (dibutylamino)methanol
67-97-0 Vitamin D3
6798-76-1 Zinc abietate
67989-28-0 Soybean oil, polymer with pentaerythritol, toluenediisocyanate and tung oil
67990-40-3 hydroxypropyl 2-propenoate and 2-propenoic acid
67993-50-4 Dodecyl diphenyl ether disulfonic acid
68002-20-0 1,3,5-Triazine-2,4,6-triamine, polymer with formaldehyde, methylated
68002-63-1 Quaternary ammonium compound, C14-18-alkyl trimethyl, chloride
68002-70-0 Glycerides, C16-22
68002-73-3 Fatty acids, vegetable-oil, calcium salts
68002-96-0 Alcohols, C16-18, ethoxylated propoxylated
68015-39-4 Fatty acids, tall-oil, polymers with glycerol, phthalic anhydride and rosin
Cuprate(2-), (29H,31H-phthalocyaninedisulfonato(4-)-
kappaN29,kappaN30,kappaN31,kappaN32)-, (SP-4-1)-, dihydrogen, compd.
68035-71-2 with 2,2',2''-nitrilotris(ethanol) (1:2)
68037-05-8 Ammonium C6-10-alkyl polyoxyethylene sulfate
68037-40-1 2,5-Furandione, polymer with ethylbenzene, sulfonated, sodium salt
Siloxanes and silicones, di-Me, Me hydrogen,reaction products with
68037-62-7 polyethylene glycol monoacet
Siloxanes and silicones, di-Me, Me hydrogen, reaction products with
68037-64-9 polyethylene-polypropylene glycol monoacetate allyl ether
Siloxanes and Silicones, di-Me, di-Ph, Me Ph, polymers with Me Ph
68037-65-0 silsesquioxanes
68037-66-1 Siloxanes and Silicones, di-Me, Me Ph, polymers with Me Ph silsesquioxanes
68037-81-0 Siloxanes and Silicones, di-Ph, Me Ph, polymers with Me Ph silsesquioxanes
68038-31-3 Fatty acids, tall-oil, polymers with pentaerythritol, phthalic anhydride and rosin
68038-60-8 Bacillus amyloliquefaciens
68038-66-4 Bacillus licheniformis
68038-70-0 Bacillus subtilis
68038-71-1 Bacillus thuringiensis
1H-Imidazolium, 1-ethyl-2-(8-heptadecenyl)-4,5-dihydro-3-(2-hydroxyethyl)-,
68039-12-3 ethyl sulfate (salt)
68-04-2 Citric acid, trisodium salt
68070-94-0 Dextrin, hydrogen 1-octenylbutanedioate
68071-17-0 Poly(oxy-1,2-ethanediyl), α-isodecyl-ω-hydroxy-,phosphate, potassium salt
Page 59 of 93
68071-29-4 Phenol, natural rubber resin
Castor oil polymer with p-tert-butylbenzoic acid, glycerol and phthalic
Fatty acids, C18-unsatd., dimers, polymers with tall-oil fatty acids,
68071-65-8 tetraethylenepentamine and triethylenetetramine
68081-81-2 Benzenesulfonic acid, C10-16-alkyl derivs., sodium salts
68081-96-9 Sulfuric acid, mono-C10-16-alkyl esters, ammonium salts
68081-97-0 Sulfuric acid, mono-C10-16-alkyl esters, magnesium salts
68082-28-0 Fatty acids, C18-unsatd., dimers, polymers with ethylene glycol
68082-64-4 Fatty acids, vegetable-oil, sodium salts
68083-14-7 Polydimethyldiphenyl siloxane copolymer
68083-64-7 Epichlorohydrin, polymer with hexamethylenetetramine
68084-55-9 2-((2-Aminoethyl)amino)ethanol dodecylbenzenesulfonate
68092-47-7 Benzoic acid, 3-methyl-, barium salt
68122-64-5 Soybean oil, polymerized
1-Methyl-1-alkyl* amidoethyl-2-alkyl*-imidazolinimethosulfate *(30% C16,
68122-86-1 70% C18)
68130-43-8 Sulfuric acid, mono-C8-18-alkyl esters, sodium salts
Poly(oxy-1-ethanediyl), alpha-hydro-omega-hydroxy-mono-C8-10-alkyl
68130-47-2 ethers, phosphates
68131-04-4 Humic acids, sodium salt
68131-12-4 Meat, meal
Soybean oil, polymer with phthalic anhydride, trimellitic anhydride and
68131-29-3 trimethylolpropane
68131-37-3 Corn syrup
68131-40-8 Alkyl* poly(ethyleneoxy)ethanol *(100% C11-15)
Caseins, potassium complexes (allergenic food commodity - use pattern is
68131-54-4 limited)
68131-65-7 Fatty acids, soya, calcium salts
68131-77-1 Distillates (petroleum), steam-cracked, polymd.
Distillates (petroleum), steam-cracked, polymers with ethylene-manuf.-by-
68131-89-5 product piperylene-cut
68132-78-5 Tallow amine hydrochloride, ethoxylated
Poly(oxy(methyl-1,2-ethanediyl)),α-(2-(diethylmethylammonio)ethyl)-ω-
68132-96-7 hydroxy-, chloride
68133-37-9 Diethanolamine ethylenediaminetetraacetate
1-Propanaminium, N-(3-aminopropyl)-2-hydroxy-N,N-dimethyl-3-sulfo-,N-
68139-30-0 coco acyl derivs., hydroxides, inner salts
Fatty acids, tall-oil, polymers with C18-unsatd fatty acid dimers and
68139-80-0 ethylenediamine
68139-89-9 Tall oil fatty acids-maleic anhydride resin
68139-91-3 Fatty acids, coco, diesters with polyethylene glycol
68140-00-1 Coco ethanolamides
68140-76-1 1,1'-(Methylimino)bis(3-chloro-2-propanol), polymer with N,N,N'N'-
Page 60 of 93
tetra,ethyl-1,2-ethanediamine
68152-55-6 Fumarated rosin ethylene glycol polymer
68152-57-8 Rosin, fumarated, polymer with ethylene glycol and pentaerythritol
68152-62-5 Rosin, maleated, polymer with pentaerythritol, formaldehyde and nonylphenol
68153-10-6 Oils, lard, sulfated, sodium salts,
68153-22-0 Carboxypolymethylene resin
Quaternary ammonium compounds, benzylbis (hydrogenated tallow
68153-30-0 alkyl)methyl, salts with bentonite
68153-76-4 Glycerides, C14-18 mono- and di-, ethoxylated
68153-88-8 Linseed oil bisphenol A p-tert-butylphenol formaldehyde tung oil polymer
68154-33-6 Fatty acids, coco, esters with sorbitan, ethoxylated-
68154-36-9 Sorbitan coconut oil ester
68155-01-1 Polyoxyethylene* cetyl and oleyl alcohols *(2.5 moles)
68155-09-9 Cocoamidopropyl dimethylamine oxide
68155-20-4 Amides, tall-oil fatty, N,N-bis(hydroxyethyl)
68155-33-9 Ethoxylated C14-18-alkylamine
68155-40-8 Amines, C16-18 and C18 unsatd. alkyl, ethoxylated
1,5-Naphthalenedisulfonic acid, 3,3'-[[6-[bis(2-hydroxyethyl)amino]-1,3,5-
68155-60-2 triazine-2,4-diyl]bis
Cuprate(2-), {29H,31H-phthalocyanine-C,C-disulfonato(4-)-
N29,N30,N31,N32}-, dihydrogen, compd. with 2-ethyl-N-(2-ethylhexyl)-1-
68155-92-0 hexanamine (1:2)
68171-29-9 Triethanolamine tris(dihydrogen phosphate) sodium salt
Poly(oxy-1,2-ethanediyl), alpha-tridecyl-omega-hydroxy-, phosphate,
68186-36-7 potassium salt
68186-90-3 C. I. Pigment Brown 24
Quaternary ammonium compounds, (hydrogenated tallow
68187-69-9 alkyl)bis(hydroxyethyl)methyl, ethoxylated, chlorides
68187-71-3 Calcium salts of tall-oil fatty acids
68187-76-8 Castor oil, sulfated, sodium salt
68187-84-8 Castor oil, epoxidized
68187-85-9 Fatty acids, tall-oil, esters with ethylene glycol
68188-27-2 Pentaerythritol ester of tall oil
68188-45-4 Sulfuric acid, mono-C>10-alkyl esters, sodium salts
68-19-9 Vitamin B12
68201-23-0 Lignin, alkali, oxidized, sodium salt
68201-46-7 Glycerides, coco mono- and di-, ethoxylated
68201-47-8 Glycerides, soya mono-
68201-51-4 Oils, menhaden, oxidized
682-01-9 Silicic acid (H4SiO4), tetrapropyl ester
68213-23-0 POE alkyl(C10-C18) alcohol
68213-57-0 Oils, menhaden, polymerized
Page 61 of 93
68227-33-8 6-Dodecyne-5,8-diol, 2,5,8,11-tetramethyl-
Poly(oxy-1,2-ethanediyl), α-hydro-ω-hydroxy-, ether with methyl β-D-
68239-42-9 glucopyranoside (4:1)
68-26-8 Vitamin A
68299-17-2 Sulfuric acid, monoisodecyl ester, sodium salt
68308-36-1 Soybean meal
68308-50-9 Fatty acids, corn-oil
68308-51-0 Fatty acids, cottonseed-oil
68308-53-2 Fatty acids, soya
68308-74-7 N,N-Dimethyl tall-oil fatty amides
68309-24-0 Fatty acids, tall-oil, polymers with maleic anhydride
68309-27-3 Fatty acids, tall-oil, sulfonated, sodium salts
68309-36-4 Ethoxylated vegetable oils and animal fats
68309-49-9 Soybean oil, polymer with isophthalic acid, linseed oil and trimethylolpropane
68309-52-4 Linseed oil, polymer with maleic anhydride and tung oil
68310-04-3 1,3-Benzenediol, 4-[(2,4-dimethylphenyl)azo]-2-[(4-dodecylphenyl)azo]-
Poly(oxy-1,2-ethanediyl), α-(carboxymethyl)-omega-(sec-pentadecyloxy)-,
α-(p-tert-Butylphenyl)-omega-hydroxypoly(oxyethylene) mixture of
dihydrogen phosphate and monohydrogen phosphate esters:the
68332-64-9 poly(oxyethylene) content is 4-12 moles
68333-69-7 Rosin, maleated, polymer with pentaerythritol
68333-79-9 Polyphosphoric acids, ammonium salts
68334-00-9 Hydrogenated cottonseed oil
68334-30-5 Diesel fuel
68334-35-0 Resin acids and rosin acids, calcium zinc salts
6834-92-0 Silicic acid (H2SiO3), disodium salt
68390-56-7 Fatty acids, tallow, hydrogenated, dimers, diketene derivs.
2-Cocyl-2-imidazolinium hydroxide-1-(2-hydroxyethyl)-1-carboxymethyl
68390-66-9 sodium salt, sodium alcoholate
68390-99-8 Amines, C14-18-alkyldimethyl, N-oxides
68391-01-5 Quaternary ammonium compounds, benzyl-C12-18-alkyldimethyl, chlorides
68409-75-6 Bone meal
68409-80-3 Fatty acids, C6-19-branched, calcium salts
68410-38-8 Fatty acids, tallow, hydrogenated, ethoxylated propoxylated
68410-46-8 Gelatins, reaction products with glutaraldehyde
Copper, {29H, 31H-phthalocyaninato(2-)-N29,N30,N31,N32}-, {{3-
68411-04-1 (dimethylamino)propyl}amino}sulfonyl derivs.
68411-27-8 Benzoic acid, C12-15-alkyl esters
68411-30-3 Sodium alkylbenzene sulfonate
68411-32-5 Benzenesulfonic acid, dodecyl-, branched
68411-97-2 Glycine, N-methyl-, N-coco acyl derivs.
68412-53-3 Poly(oxy-1,2-ethanediyl), α-(nonylphenyl)-ω-hydroxy-, branched, phosphates
68412-54-4 Poly(oxy-1,2-ethanediyl), [alpha]-(nonylphenyl)-omega-hydroxy-, branched
68413-17-2 Fatty acids, tall-oil, polymers with isophthalic acid, pentaerythritol and walnut
Page 62 of 93
oil
68422-69-5 Sulfated butyl oleate
68424-10-2 Cottonseed meal
68424-45-3 Fatty acids, linseed-oil
68424-50-0 Fatty acids, tall-oil, C12-15-alkyl esters, sulfated, sodium salts
68424-61-3 Glycerides, C16-18 and C18-unsatd. mono- and di-
68424-85-1 Alkyl* dimethyl benzyl ammonium chloride *(50% C14, 40% C12, 10% C16)
68424-94-2 Betaines, coco alkyldimethyl
68425-13-8 2-Methyl-1,3-butadiene, homopolymer (as latex)
68425-17-2 Syrups, hydrolyzed starch, hydrogenated
68425-57-0 Phosphoric acid, mixed decyl and octyl esters, compds. with diethanolamine
Benzene, ethenylmethyl-, polymer with ethenylbenzene and (1-
68425-58-1 methylethenyl)benzene
Residues (petroleum), catalytic reformer fractionator, sulfonated, polymers
68425-94-5 with formaldehyde, sodium salts
5-Benzoxazolesulfonamide, 2-(7-(diethylamino)-2-oxo-2H-1-benzopyran-3-
68427-35-0 yl)-
68439-30-5 Oxirane, methyl-, polymer with oxirane, 8-methylnonyl ether
68439-48-5 Alcohols, C-20/30, ethoxylated
68439-56-5 Alkenes, C13-18 alpha-, sulfonated, sodium salts
68439-57-6 Mixed alkyl sulfates
68439-70-3 Amines, C12-16-alkyldimethyl
68439-72-5 Amines, C8-18 and C18-unsatd. alkyl, ethoxylated
68440-19-7 Fatty acids, safflower-oil, sodium salts
Siloxanes and silicones, di-Me, 3-hydroxypropyl Me, ethers with
68440-66-4 polypropylene glycol mono-Bu et
68440-90-4 Siloxanes and silicones, Me octyl
68441-17-8 Oxidized polyethylene
68441-73-6 Ethene, homopolymer, oxidized, potassium salt
68441-84-9 Sodium salt of cresol sulfonic acid condensed with urea formaldehyde
68442-09-1 Naphthalenesulfonic acid, sodium salt, isopropylated
68442-82-0 Calcium carbonate dimethylhexanoate
68442-85-3 Cellulose, regenerated
68443-05-0 Sodium sulfonated oleate
2,7-Naphthalenedisulfonic acid, 4-hydroxy-5-(((4-
6844-74-2 methylphenyl)sulfonyl)amino)-3-(phenylazo)-, disodium salt
68457-75-0 Butylated, styreneated cresols
68458-48-0 Decyl alcohol, ethoxylated, phosphated
68458-49-1 Polyphosphoric acids, esters with polyethylene glycol nonylphenyl ether
68458-88-8 Lanolin, ethoxylated propoxylated
Page 63 of 93
68459-31-4 C9-19-fatty acid ester phthalic alkyd
Oxirane, methyl-, polymer with alpha-butyl-omega-hydroxypoly(oxy-1,2-
68459-87-0 ethanediyl) and oxirane
6846-50-0 2,2,4-Trimethyl-1,3-pentanediol diisobutyrate
68476-25-5 Feldspar
68476-30-2 Fuel oil, no. 2
68476-31-3 Fuel oil, no. 4
68476-33-5 Residual fuel oil
68476-37-9 Glue (as depolymd. animal collagen)
68476-40-4 Hydrocarbons, C3-4
68476-78-8 Cane syrup
68476-82-4 Peanut meal
68476-86-8 Petroleum gases, liquefied, sweetened
68477-30-5 Aromatic petroleum hydrocarbon solvent
68477-31-6 Aromatic petroleum derivative solvent
68477-33-8 Propane-isobutane mixture
68478-07-9 Naphtha
68478-54-6 Calcium, 2-ethylhexanoate isononanoate complexes
68478-65-9 N,N-Bis (2-hydroxyethyl) isodecyloxypropylamine oxide
Poly(oxy-1,2-ethanediyl),alpha,alpha'-[[[3-(decyloxy)propyl]methylimino]di-
68478-94-4 2,1-ethanediyl]bis[omega-
68479-09-4 2-Propenoic acid, telomer with sodium hydrogen sulfite, sodium salt
Butanedioic acid, sulfo-, mono{2-{(1-0xo-9-octadecenyl)amino}ethyl}ester,
68479-64-1 disodium salt,(Z)- (C
Hexanedioic acid, polymer with 1,4-butanediol and 1,2-propanediol,
68511-11-5 didodecanoate
68511-39-7 Poly(oxy-1,2-ethanediyl), α-sulfo-ω-hydroxy-, C12-15-alkyl ethers
68511-70-6 Formaldehyde, polymer with 4-nonylphenol, propoxylated
68512-34-5 Lignosulfonic acid, sodium salt, sulfomethylated
68512-35-6 Lignin, alkali, reaction products with formaldehyde and sodium bisulfite
68512-79-8 Soybean oil, polymer with dicyclopentadiene
68513-95-1 Soybean, flour
68514-08-9 Sulfite liquors and cooking liquors, spent, alkali-treated, metal salts
68514-09-0 Sulfite liquors and cooking liquors, spent, oxidized
68514-28-3 Humic acids, potassium salts
68514-43-2 Linseed oil, maleated, ammonium salt
68514-61-4 Milk, skim, hydrolyzed
68514-74-9 Palm oil, hydrogenated
68514-75-0 Oils, orange-juice
68514-76-1 Citrus pulp
68515-42-4 1,2-Benzenedicarboxylic acid, di-C7-11-branched and linear alkyl esters
68515-49-1 Phthalic acid, di-C9-11-branched alkyl esters, C10-rich
68515-65-1 Disodium 1(or 4)-cocoamidoisopropyl sulfosuccinate
68515-73-1 D-Glucopyranose, oligomeric, decyl octyl glycosides
68516-16-5 Sulfuric acid, C6-10-alkyl esters
Page 64 of 93
68525-86-0 Corn, flour
68525-90-6 Sorbitan, poly(oxy-1,2-ethanediyl) derivs., hepta-9-octadecenoate, all-(Z)-
68526-82-9 Octyl alcohol bottoms
68526-86-3 Alcohols, C11-14-iso-, C13- rich
68527-08-2 Alkenes, C>10 α-, polymd.
68527-23-1 Naphtha (petroleum), light steam-cracked aromatic
Carboxymethylated 2-undecyl-1-hydroxyethyl-4,5-dihydroimidazoline,
68551-07-5 Fatty alcohols (100% C4-C10)
68551-18-8 Alkanes, C10-14-iso-
68551-41-7 Calcium salts of fatty acids (see 21 CFR 175.300 xxii)
68551-42-8 Fatty acids, C6-C19 branched, manganese salts
68551-90-6 Fatty acids, cottonseed-oil, calcium salts
68553-00-4 Fuel oil, no. 6
68553-02-6 Fatty acids, coco, esters with polyethylene glycol ether with glycerol (3:1)
68553-04-8 Glycerides, soya di-
68553-11-7 Glycerides, tallow mono- and di-, hydrogenated, ethoxylated
68553-81-1 Rice bran oil
68554-37-0 Pentaerythritol, phthalic anhydride and tall oil polymer with rosin
Siloxanes and silicones, di-Me, polymers with Me silsesquioxanes and
68554-64-3 polypropylene glycol mono-
Siloxanes and silicones, di-Me, polymers with Me silsesquioxanes and
68554-65-4 polyethylene-polypropylene glycol mono-Bu ether
68554-70-1 Silsesquioxanes, Me
N,N'-Bis{3-(dimethylamino)propyl}urea, polymer with 1,1'-oxybis(2-
68555-36-2 chloroethane)
68583-49-3 Cyclotetrasiloxane, octamethyl-, reaction products with silica
68583-84-6 1,3-Butanediol adipate-laurate polyester
1,3-Benzenedicarboxylic acid, polymer with 5-amino-1,3,3-
68584-15-6 trimethylcyclohexylamine and nonanedioic acid, cyclohexylamine modified
68584-22-5 Benzenesulfonic acid, C10-16-alkyl derivs
68584-23-6 Calcium alkyl(C8-C24)benzenesulfonate
68584-24-7 Benzenesulfonic acid, C10-16-alkyl derivs., compds. with 2-propanamine
68584-25-8 Benzenesulfonic acid, C10-16-alkyl derivs., compds. with triethanolamine
68584-26-9 Benzenesulfonic acid, C10-16-alkyl derivs., magnesium salts
68584-27-0 Benzenesulfonic acid, C10-16-alkyl derivs., potassium salts
6858-44-2 Citric acid, trisodium salt, pentahydrate
Poly(oxy-1,2-ethanediyl), α-(nonylphenyl)-ω-hydroxy-, branched, phosphates,
68584-47-4 potassium salts
68585-15-9 Oxirane, methyl, polymer with oxirane, mono C6-C10 alkyl ethers, phosphates
Poly(oxy-1,2-ethanediyl), alpha-sulfo-omega-hydroxy-, C10-16-alkyl ethers,
68585-34-2 sodium salts
Page 65 of 93
68585-36-4 Alkyl(C10-14)oxypoly(ethyleneoxy)ethyl phosphate
2-Propenoic acid, 2-methyl-, 2-((2,3,3a,4,7,7a(or 3a,4,5,6,7,7a)-hexahydro-4,7-
68586-19-6 methano-1H-indenyl)oxy)ethyl ester
68602-80-2 Distillates (petroleum), C12-30 aromatic
68603-15-6 Alcohols, C6-12
68603-16-7 Alcohols, C12-18, distn. residues
68603-17-8 Alcohols, C16-18, distn. residues
68603-18-9 C10-16 Alcohols distn. Residues
Poly(oxy-1,2-ethanediyl),.alpha.-(carboxymethyl)-.omega.-hydroxy-, C11-15-
68603-23-6 sec-alkyl ethers, sodium salts
68603-42-9 Amides, coco, N,N-bis(2-hydroxyethyl)
Imidazolium compounds, 1-{2-(2-carboxyethoxy)ethyl}-1(or 3)-(2-
68604-71-7 carboxyethyl)-4,5-dihydro-2-norc
68605-55-0 Fatty acids, tall-oil,polymers with bisphenol A,epichlorohydrin and tall oil
Fatty acids, tall-oil, polymers with bisphenol A, epichlorohydrin, rosin and
68605-57-2 tung oil. (CA INDE
68606-06-4 Fatty acids, vegetable-oil, potassium sodium salts
68606-94-0 Oils, orange, sweet, terpene-free
68607-27-2 Dihydrogenated tallow hydroxyethyl methyl ammonium chloride
Quaternary ammonium compounds, pentamethyltallow alkyltrimethylenedi-,
68607-29-4 dichlorides
68608-26-4 Sodium petroleum sulfonate
Acetic acid, chloro-, sodium salt, reaction products with 4,5-dihydro-2-
68608-66-2 undecyl-1H-imidazole-1-ethanol and sodium hydroxide
68609-68-7 1-Hexanol, 2-ethyl-, manuf. of by-products from, distn. residues
68609-86-9 Manganese naphthanate 2-ethylhexanoate complex
68609-93-8 9-Octadecenoic acid (Z)-, sulfonated, Potassium salts
Poly(oxy-1,2-ethanediyl), α,α'-[[methyl[3-(tridecyloxy)propyl]imino]di-2,1-
68610-19-5 ethanediyl
Reaction products of methyl acrylate with 2-ethylhexylamine and sodium
68610-44-6 hydroxide
Cellulose, omega-ether with alpha-?2-hydroxy-3-(trimethylammonio) pro-
68610-92-4 pyl|-omega-hydroxypoly(oxy-1,2-ethanediyl) chloride
68611-14-3 Lignosulfonic acid, ethoxylated, sodium salts
68611-44-9 Silane, dichlorodimethyl-, reaction products with silica
68611-55-2 Sulfated mixed oxo alcohols (100% C10 and up)
68628-60-4 Benzenesulfonic acid, 4-sec-dodecyl-, sodium salt
2-Propenoic acid, 2-methyl-, polymer with ethenylbenzene and alpha-hydro-
68630-83-1 omega-hydroxypoly(oxy-1,2-ethanediyl)-(Z)-2-butenedioate
Disodium 3-(2-(2-carboxyethoxy)ethyl)-2-heptyl-2,3-dihydro-1H-imidazole-1-
68630-92-2 propanoate
1H-Imidazolium, 1-(2-carboxyethyl)-4,5-dihydro-3-(2-hydroxyethyl)-2-
68630-96-6 isoheptadecyl-, hydroxide, inner salt
68647-71-2 Tall oil, potassium salt
Page 66 of 93
68647-72-3 Terpenes, orange oil
68647-73-4 Oils, tea-tree
68647-95-0 Fatty acids, C18-unsatd., dimers, compds. with coco alkylamines
68648-12-4 Fatty acids, tall-oil, diesters with polypropylene glycol
68648-20-4 Fatty acids, tall-oil, sesquiesters with sorbitol, ethoxylated
68648-20-4 Sorbitol tall oil fatty acid sesquiester, ethoxylated
68648-35-1 Sulfonated cod oil
68648-38-4 Polyoxyethylene lanolin alcohol
68648-44-2 Pyrethrum marc
68648-50-0 Resin acids and Rosin acids, dimers, calcium salts
68648-72-6 Sodium alpha-olefin (C12-C16) sulfonate
Benzene, ethenyl-, polymer with 2-methyl-1,3-butadiene, hydrogenated (CA
68648-89-5 INDEX NSME)
68648-98-6 Benzenesulfonic acid, mono-C7-17-branched alkyl derivs.
Benzenesulfonic acid, mono-C9-17-branched alkyl derivs., compds. with 2-
68649-00-3 propanamine
68649-29-6 Polyethylene-polypropylene glycol, mono-C10-16-alkyl ethers, phosphates
Poly(oxy-1,2-ethanediyl), [alpha]-sulfo-[omega]-(nonylphenoxy)-, branched,
68649-55-8 ammonium salt
68649-89-8 Resin acids and rosin acids, ammonium salts
68650-09-9 Polyoxyethylene* glycerol tall oil ester *(25 moles) (Mol. wt. 1490)
Fatty acids, tall-oil, polymers with pentaerythritol, polyethylene glycol and
68650-28-2 trimellitic anhydride
Imidazolium compounds, 1-(2-(carboxymethoxy)ethyl)-1-(carboxymethyl)-
68650-39-5 4,5-dihydro-2-norcoco alkyl, hydroxides, inner salts, disodium salts
68650-50-0 Fatty acids, C18-unsatd., dimers, polymers with ethylenediamine
687-47-8 Propanoic acid, 2-hydroxy-, ethyl ester (S)
68783-43-7 Fatty acids, linseed-oil, calcium salts
68783-78-8 Ditallow dimethyl ammonium chloride
68813-94-5 Sulfuric acid, zinc salt, basic
68813-94-5 Zinc sulfate, basic
68814-56-2 Rhizobium japonicum
68814-57-3 Rhizobium leguminosarum
68814-58-4 Rhizobium lupini
68814-59-5 Rhizobium meliloti
68814-60-8 Rhizobium phaseoli
68814-61-9 Rhizobium trifolii
688-37-9 9-Octadecenoic acid, (Z)-, aluminum salt
68855-41-4 Lignosulfonic acid, sodium salt, oxidized
68855-54-9 Kieselguhr, soda ash flux-calcined
68855-99-2 Litsea cubeba oil
68876-77-7 Yeast
Page 67 of 93
Benzene, ethenyl-, polymer with 2,5-furandione, 2-butoxyethyl ester,
68891-11-2 Oxirane, methyl-, polymer with oxirane, mono(nonylphenyl) ether, branched
Oxirane, methyl-, polymer with oxirane, mono-C10-16-alkyl ethers,
68891-13-4 phosphates, potassium salts
68891-21-4 Poly(oxy-1,2-ethanediyl),α-(dinonylphenyl)-ω-hydroxy-branched
68891-29-2 alpha-Alkyl(C8-C10)-omega-hydroxypoly(oxyethylene) ammonium sulfate
68891-33-8 Nonylphenol polyoxyethylene sulfate
68891-38-3 Alcohols, (C12-14), ethoxylated, monoethers with sulfuric acid, sodium salts
68908-46-3 Sulfuric acid, mono-C10-16-alkyl esters, potassium salts
68908-63-4 Ethoxylated C12-15 alcohols
Poly(oxy-1,2-ethanediyl), α-hydro-. omega.-hydroxy-, mono-C10-12-alkyl
68908-64-5 ethers, phosphates
68909-20-6 Silanamine, 1,1,1-trimethyl-N-(trimethylsilyl)-, hydrolysis products with silica
68909-59-1 Phosphoric acid, mono-C8-10-alkyl esters, monosodium salts
68909-82-0 Naphthalenesulfonic acid, bis(1-methylethyl)-, Me derivs, sodium salts
68909-83-1 Naphthalenesulfonic acid, butyl-, Me derivs, sodium salts
68909-84-2 Naphthalenesulfonic acid, dibutyl-, Me derivs, sodium salts
68911-49-9 Dried blood
68911-87-5 Bis(hydrogenated tallow alkyl) dimethyl ammonium salts with montmorillonite
68915-31-1 Sodium hexametaphosphate ((NaPO3)6)
68915-32-2 Quassia extract
68916-18-7 Coffee grounds
68916-91-6 Licorice extract
68917-18-0 Cornmint oil
68917-19-1 Magnolia flower
68917-32-8 Terpenes and terpenoids, grapefruit-oil
68917-60-2 Terpenes and terpenoids, pennyroyal-oil
68917-71-5 Terpenes and terpenoids, lime-oil
68917-73-7 Oils, wheat
68917-75-9 Wintergreen oil
Quaternary ammonium compounds, bis(C8-18 and C18-unsatd. alkyl)dimethyl,
68918-78-5 chlorides
68919-53-9 Fatty acids, soya, Me esters
68919-54-0 Sunflower-oil fatty acids, Me ester
68919-76-6 Fatty acids, tall-oil, reaction products with 2-{(2-aminoethyl)amino}ethanol
68920-66-1 Alcohols, C16-18 and C18-unsatd., ethoxylated
68920-69-4 Alcohols, C9-11, propoxylated
Benzenemethanaminium, N-ethyl-N-(4-((4-(ethyl((3-
sulfophenyl)methyl)amino)phenyl)(2-sulfophenyl)methylene)-2,5-
68921-42-6 cyclohexadien-1-ylidene)-3-sulfo-, hydroxide, inner salt, aluminum salt (3:2)
Vinyl acetate, crotonic acid, vinyl neodecanoate, glycidyl methacrylate
68928-85-8 polymer
68937-10-0 Hydrogenated polyisobutene
68937-41-7 Phenol, isopropylated, phosphate (3:1)
Page 68 of 93
68937-54-2 Siloxanes and silicones, di-Me, 3-hydroxypropyl Me, ethoxylated
68937-55-3 Siloxanes and silicones, di-Me, 3-hydroxypropyl Me, ethoxylated propoxylated
Siloxanes and silicones, di-Me,[(methylsilylidyne)tris(oxy)tris-, hydroxy
68937-56-4 terminated, ethers with polyethylene-polypropylene glycol monobutyl ether
68937-83-7 Fatty acids, C6-10, methyl esters
68937-84-8 Fatty acids, C12-18, methyl esters
68937-99-5 Sunflower seeds
68938-15-8 Fatty acids, coco, hydrogenated
Siloxanes and silicones, di-Me, 3-hydroxypropyl Me, ethers with polyethylene
68938-54-5 glycol mono-Me eth
68952-63-6 Linseed oil, tung oil, di-tert-butylphenol, bisphenol A, formaldehyde polymer
68953-01-5 Fatty acids, tall-oil, esters with ethoxylated sorbitol
68953-36-6 Tall oil fatty acids, reaction products with tetraethylene pentamine
68953-91-3 Benzenesulfonic acid, mono-C7-17-alkyl derivs., calcium salts
68953-96-8 Benzenesulfonic acid, mono-C11-13-branched alkyl derivs., calcium salts
6895-43-8 Ethyl bixin
Poly(oxy-1,2-ethanediyl), alpha-(nonylphenyl)-omega-hydroxy-, branched,
68954-84-7 phosphates, sodium salts
68955-55-5 Amines, C12-14-alkyldimethyl, N-oxides
68955-64-6 Hexanedinitrile, hydrogenated, high-boiling fraction, phosphonomethylated
68956-56-9 Hydrocarbons, terpene processing by-products
Siloxanes and Silicones, di-Me, Me hydrogen, reaction products with
68957-00-6 polypropylene glycol monoallyl ether
68959-25-1 3-Pentanol, 1-(2-hydroxyethoxy)-2,2,4-trimethyl-
68964-56-7 Octadecanoic acid, 9(or 10)-(sulfooxy)-, monosodium salt
689-82-7 2-Butenedioic acid (Z)-, monopotassium salt
68987-29-1 1-Octadecanol, phosphate, potassium salt
68987-63-3 Copper, [29H,31H-phthalocyaninato(2-)-N29,N30,N31,N32]-, chlorinated
68987-81-5 Ethoxylated propoxylated C6-10 alcohols-
2-Butenedioic acid (2E)-,mixed esters with polyethylene glycol and
polyethylene glycol mono(nonylphenyl) ether, polymer with methacrylic acid
68988-56-7 Polytrimethylhydrosilylsilicone
68988-76-1 9-Octadecenoic acid (Z)-, sulfonated
Quaternary ammonium compounds, benzyl-C12-18-alkyldimethyl, salts with
68989-01-5 1,2-benzisothiazol-3(2H)
68989-22-0 Zeolites, NaA
68990-15-8 Oils, fenugreek
68990-20-5 Penta cosolvent
68990-53-4 Glycerides, C14-22 mono-
68990-54-5 Glycerides, C14-22 mono-,acetates
68991-42-4 Oils, red pepper, paprika
69009-90-1 1,1'-Biphenyl, bis(1-methylethyl)-
Page 69 of 93
69011-04-7 n-Butyl acid phosphate, manganese salt
Benzene, diethenyl-, polymer with ethenylbenzene and ethenylethylbenzene,
69011-15-0 chloromethylated, 2-(dimethylamino)ethanol-quaternized
Benzene, diethenyl-, polymer with etenylbenzene and ethenylethylbenzene,
69011-22-9 sulfonated, sodium salts
69011-36-5 Polyoxyethylene tridecyl (branched) alcohol
Poly(oxy-1,2-ethanediyl), alpha-sulfo-omega-hydroxy-, C8-14-alkyl ethers,
69011-37-6 ammonium salts
Poly(oxy-1,2-ethanediyl),α-sulfo-ω-(octylphenoxy)-,branched,sodium salt (CA
69011-84-3 INDEX NA
69012-32-4 Calcium silicate slag
α-Alkyl(C8-C14)-omega-hydroxypoly(oxypropylene) block copolymer
withpolyoxethylene; polyoxpropylene content averages 2 moles;
69013-18-9 polyoxyethylene content averages 7 moles
69029-39-6 Polyoxyethylene polyoxypropylene mono(di-sec-butylphenyl) ether
6915-15-7 Malic acid
alpha-Alkyl*-omega-hydroxy-polyoxyethylene** polyoxypropylene***
69227-22-1 polyoxyethylene** *(100% C10-C16) **(4 moles) ***(1.5 moles)
69278-92-8 Tall oil, calcium zinc salt
692-86-4 10-Undecenoic acid, ethyl ester
693-33-4 1-Hexadecanaminium, N-(carboxymethyl)-N.N-dimethyl-, inner salt
69364-63-2 Poly(oxy-1,2-ethanediyl), alpha-isohexadecyl-omega-hydroxy-
6938-94-9 Diisopropyl adipate
69430-24-6 Cyclosiloxanes, di-Me
69430-36-0 Hydrolyzed keratins
695-06-7 4-Hexanolide
69-65-8 Mannitol
69669-25-6 Fatty acids, C12-20, potassium salts
Siloxanes and silicones, di-Me, 3-hydroxypropyl Me, Me 2-(7-
oxabicyclo[4.1.0]hept-3-yl )ethyl, ethers with polyethylene-polypropylene
69669-36-9 glycol mono-Me ether
69671-09-6 Propylene-ethylene thioether
6969-49-9 Octyl salicylate
69-72-7 Salicylic acid
69-79-4 D-Glucose, 4-O-alpha-D-glucopyranosyl-
3-Pyridinecarbonitrile, 1-butyl-5-[(4-chlorophenyl)azo]-1,2-dihydro-6-
69808-32-8 hydroxy-4-methyl-2-oxo-
69867-71-6 Phosphoric acid, monopentyl monophenyl ester
69898-00-6 alpha-Olefins
69-93-2 Uric acid
70084-87-6 Glutens, enzyme-modified
7011-83-8 Decanoic acid, 4-hydroxy-4-methyl-,.gamma.-lactone
70131-50-9 Acid-leached bentonite
70131-67-8 Dimethyl siloxane, hydroxy-terminated
Page 70 of 93
Soybean oil, polymer w. benzoic acid, pentaerythritol, phthalic anhydride, TDI
70131-70-3 and trimethylolpropane
70142-34-6 12-Hydroxystearic acid-polyethylene glycol copolymer
70146-13-3 Benzenesulfonic acid, oxybis(decyl-, disodium salt
70161-44-3 Glycine, N-(hydroxymethyl)-, monosodium salt
70191-76-3 Disodium dihexadecyldiphenyloxide disulfonate
70206-24-5 Alkyl imidazolinium methyl sulfate (derived from oleic acid)
2 Naphthalenecarboxylic acid, 4-((5-chloro-4-methyl-2-sulfophenyl)azo)-3-
7023-61-2 hydroxy-, calcium salt (1:1)
1H-Benzimidazolesulfonic acid, 2-(7-(diethylamino)-2-oxo-2H-1-benzopyran-
70267-73-1 3-yl)-, monosodium salt
2-Propenoic acid, 2-methyl-, octadecyl ester, polymer with isooctyl 2-
70425-89-7 propenoate and 2-propenoic acid
70495-37-3 Sulfuric acid, mono(2-ethylhexyl) ester, ammonium salt (1:1)
70528-83-5 Benzenesulfonic acid, dodecyl-, branched, calcium salts
Butyl acrylate-2-ethylhexyl acrylate-2-hydroxyethyl acrylate-styrene
70559-25-0 Poly(oxy-1,2-ethanediyl), α-[2,4,6-tris(1-phenylethyl)phenyl]-ω-hydroxy-
2-Anthracenesulfonic acid, 4-[[3-(acetylamino)phenyl]amino]-1-amino-9,10-
70571-81-2 dihydro-9,10-dioxo-, m
70592-80-2 Alkyl(C10-16) dimethylamine oxide
706-14-9 2(3H-Furanone, 5-hexyldihydro-
Poly(oxy-1,2-ethanediyl), α-(carboxymethyl)-ω-hydroxy, C12- 15-alkyl ethers,
7065-13-6 1-Hexadecanol, hydrogen sulfate, potassium salt
70657-70-4 Propylene glycol monomethyl ether acetate
70693-62-8 Potassium peroxymonosulfate sulfate (K5(HSO5)2(HSO4)(SO4))
707-19-7 Propargyl alcohol
70750-46-8 Betaines,bis(hydroxyethyl)tallow alkyl
70750-47-9 Quternary ammonium compounds, coco alkylbis(hydroxyethyl)methyl chloride
70750-53-7 Terpenes and terpenoids, limonene fraction, polymd.
70750-57-1 Terpenes and Terpoids, turpentine oil, alpha-pinen fraction, polymd.
70788-30-6 Cyclohexanepropanol, 2,2,6-trimethyl-,α-propyl-
Oils, walnut, polymers with maleic anhydride, pentaerythritol, phthalic
70879-75-3 anhydride, sunflower oil and trimethylolethane
70892-46-5 Benzenesulfonic acid, C12-18-alkyl derivs. sodium salts
70903-62-7 o,p-Dinonylphenol, ethoxylated, phosphated, sodium salt
Siloxanes and silicones, di-Me,3-hydroxypropyl Me,ethers with polyethylene
70914-12-4 glycol acetate
70955-37-2 Dodecyl and higher aliphatic ketones
71010-52-1 Gellan gum
Quaternary ammonium compounds, benzyl(hydrogenated tallow
71011-24-0 alkyl)dimethyl, salts with bentonite
Quaternary ammonium compounds, bis(hydrogenated tallow alkyl)dimethyl,
71011-27-3 chorides, compds. with hectorite
Page 71 of 93
71012-10-7 9-Octadecenoic acid (9Z)-, monoester with tetraglycerol
71-23-8 1-Propanol
71243-46-4 Polyoxyethylene linear primary alcohols
71243-86-2 Nonene, hydroformylation products, high-boiling, sulfated, sodium salts
7128-64-5 2,2'-(2,5-Thiophenediyl)bis(5-tert-butylbenzoxazole)
7128-91-8 1-Hexadecanamine, N,N-dimethyl-, N-oxide
71317-43-6 1-Tridecanol, hydrogen sulfate, potassium salt
71317-56-1 1-Tridecanol, hydrogen sulfate, magnesium salt
71-36-3 1-Butanol
2-Propenoic acid, 2-methyl-, polymer with butyl 2-methyl-2-propenoate,
71394-17-7 ethenylbenzene, 2-ethylh
71-41-0 1-Pentanol
71526-07-3 1-Oxa-4-azaspiro{4.5}decane, 4-(dichloroacetyl)-
71-55-6 1,1,1-Trichloroethane
Benzenesulfonic acid, 4-hydroxy-, polymer with formaldehyde and urea,
71662-60-7 Stearamine oxide
7173-51-5 1-Decanaminium, N-decyl-N,N-dimethyl-, chloride
7173-62-8 N-Oleyl-1,3-propylenediamine
71750-79-3 Siloxanes and silicones, 3-[(2-aminoethyl)amino]propyl Me, di-Me
717-74-8 Benzene, 1,3,5-tris(1-methylethyl)-
71786-60-2 N,N-Bis(2-hydroxyethyl)-C12-18-alkylamine
71819-51-7 C.I. Solvent Red 164
Copolymer of castor oil, maleic anhydride, and polyethylene glycol 600 (Mol.
71820-36-5 Wt. 3150)
Cobaltate(1-),bis{2,4-dihydro-4-{(2-hydroxy-5-nitrophenyl)azo}-5-methyl-2-
71839-88-8 phenyl-3H-pyrazol-3-o
71872-84-9 9,10-Anthracenedione, 1,4-bis((2,4,6-trimethylphenyl)amino)-
Benzenesulfonic acid, 2,5-dichloro-4-(4-((5-(((dodecyloxy)carbonyl)amino)-2-
71873-51-3 sulfophenyl)azo)-4,5-dihydro-3-methyl-5-oxo-1H-pyrazol-1-yl)-, disodium salt
Benzenesulfonic acid, 2(or 5)-butyl-5(or 2)-{{4-{{4-butylsulfophenyl)amino}-
71927-89-4 9,10-dihydro-5,8-dihydroxy-9,10-dioxo-1-anthracenyl}amino}, disodium salt
alpha-(o,p-Dinonylphenyl)-omega-hydroxypoly(oxyethylene) mixture of di-
hydrogen phosphate and monohydrogen phosphate esters and the
corresponding ammonium, calcium, monomethanolamine, potassium, sodium
72067-21-1 and zinc salts of the phosphate ester.
Methylium, [4-(dimethylamino)phenyl]bis[4-(ethylamino)-3-methylphenyl]-
72102-55-7 ,acetate (CA INDE
2,7-Naphthalenedisulfonic acid, 4-hydroxy-5-((4-(methylamino)-6-((3-((2,5,6-
trichloro-4-pyrimidinyl)amino)phenyl)amino)-1,3,5-triazin-2-yl)amino)-3-((2-
72139-15-2 sulfophenyl)azo)-, trisodium salt
72152-45-5 C.I. Reactive Green 12
2-Anthracenesulfonic acid, 4-((4-(acetylmethylamino)-2-sulfophenyl)amino)-
72152-54-6 1-amino-9,10-dihydro-9,10-dioxo-, disodium salt
72162-23-3 (C10-C12) Dibasic acid, diethanolamine salts
Page 72 of 93
Phosphoric acid, C12-15-alkyl esters, compds. with polyethylene glycol
72207-82-0 mono[2-(diethylamino)ethyl] ether
72208-21-0 C.I. Basic Red 14 (phosphate)
72214-01-8 2-Ethylhexyl sulfate
Coconut oil, polymer with isophthalic acid, trimellitic anhydride and
72245-05-7 trimethylolpropane
7230-93-5 Dodecanoic acid, aluminum salt
Imidazolium compounds, 2-(C17 and C17-unsatd. alkyl)-1-[2-(C18 and C18-
72749-55-4 unsatd. amido)ethyl]-4,5-d
72749-59-8 Tri-C6-12-alkylmethyl ammonium chlorides
72827-81-7 C.I. Acid Red 388
2,7,-Naphthalenedisulfonic acid, 5-(benzoylamino)-3-{{2-(2-
72828-83-2 cyclohexylphenoxy)phenyl}azo}-4-hydr
72854-21-8 Zirconium naphthenate
72869-69-3 Oils, apricot
73018-51-6 1,6-Octadien-3-ol, 3,7-dimethyl-, acid-isomerized
73038-25-2 Poly(oxy-1,2-ethanediyl), alpha-isotridecyl-omega-hydroxy-, phosphate
73049-73-7 Peptone type IV from soybean
Poly(oxy-1,2-ethanediyl),α-(butoxyhydroxyphosphinyl)-ω-hydroxy-,C13-15-
73050-07-4 alkyl ethers,s
Poly(oxy-1,2-ethanediyl),α,α-phosphinicobis{ω-hydroxy-,di-C13-15-alkyl
73050-08-5 ethers,
Poly(oxy-1,2-ethanediyl),α-phosphono-ω-hydroxy-,C13-15-alkyl ethers,
73050-09-6 disodium salts
73138-28-0 Dimethyl dioctadecyl ammonium bentonite
7320-34-5 Diphosphoric acid, tetrapotassium salt
73-22-3 L-Tryptophan
73227-23-3 Neodymium tris(2-ethylhexanoate)
73246-96-5 Ethanol, 2.2'-iminobis-, N-soya alkyl derivs.
73248-92-7 Sulfuric acid, iron(2+) salt (1:1), nonahydrate ()
73296-90-9 Sulfuric acid, mono-C12-16-alkyl esters, potassium salts
Cobaltate(1-),bis{1-{(2-hydroxy-5-nitrophenyl)azo}-2-naphthalenolato(2-)}-,
73297-09-3 sodium
73398-61-5 Glycerides, mixed decanoyl and octanoyl
Dialkyl* dimethyl ammonium chloride (47%C12, 18%C14, 10%C18, 9%C10,
73398-64-8 8%C16, 8%C8)
Xanthylium, 3,6-bis(diethylamino)-9-(2-(methoxycarbonyl)phenyl)-, (T-4)-
73398-89-7 tetrachlorozincate(2-) (2:1)
73455-30-8 Dimethylamine ethylenediaminetetraacetate
7346-80-7 Sodium N-cis-9-octadecenyl-N-methyltaurine
7347-29-7 Oleoyl imidazoline
Cobaltate(1-),{2,4-dihydro -4-{(2-hydroxy-5-nitrophenyl)azo}-5-methyl-2-
73507-66-1 phenyl-3H-pyrazol-3-onato(2-)}{1-{(2-hydroxy-5-nitrophenyl)azo}-2-
Page 73 of 93
naphthalenolato(2-)}-, sodium
73513-47-0 Disodium zinc ethylenediaminetetraacetate

73637-19-1 Disodium cupric ethylenediaminegtetraacetate trihydrate
73637-20-4 Disodium manganese ethylenediaminetetraacetate
73728-37-7 Rubber, cyclized
7373-11-7 2-Hydroxypropylamine nitrite
1-Propanesulfonic acid, 3-{{-
73772-32-4 (dimethylamino)propyl}{(tridecafluorohexyl)sulfonyl}amino}-2-hydro
7378-99-6 1-Octanamine, N,N-dimethyl-
7379-27-3 Potassium ethylenediaminetetraacetate
7379-28-4 Glycine, N,N'-1,2-ethanediylbis(N-(carboxymethyl)-, sodium salt
Fatty acids, tall-oil, polymers with bisphenol A, diethylenetriamine,
73807-20-2 epichlorohydrin and triethylenetetramine
73891-88-0 Tannic acid
73891-99-3 Rape oil, Me ester
Benzoic acid, 2-{{2-hydroxy-5-sulfo-3-{(2,5,6-trichloro-4-pyrimidinyl)
74204-30-1 amino}phenyl}imino}-1-phenylethyl}azo}-5-sulfo-, copper complex
7429-90-5 Aluminum (metal)
7439-89-6 Iron (Fe)
7440-37-1 Argon
7440-44-0 Carbon
7440-50-8 Copper
7440-59-7 Helium
7440-66-6 Zinc (metallic)
7443-25-6 Propanedioic acid, {(4-methoxyphenyl)methylene}-, dimethyl ester
7446-19-7 Zinc sulfate monohydrate
7446-20-0 Sulfuric acid, zinc salt (1:1) , heptahydrate
7446-26-6 Zinc pyrophosphate
7446-70-0 Aluminum chloride
7447-40-7 Potassium chloride (KCl)
7447-41-8 Lithium chloride
74499-22-2 Methyl tallate
74504-64-6 1,2,3-Propanetriol, homopolymer, dodecanoate
74775-06-7 Poly{oxy(methyl-1,2-ethanediyl)},α-(1-oxopropyl)-ω-(tetradecyloxy)-
74811-65-7 Croscarmellose sodium
74-84-0 Ethane
74-86-2 Acetylene
7487-79-8 Diethanolamine laurate
7487-88-9 Magnesium sulfate
7492-30-0 9-Octadecenoic acid, 12-hydroxy-, monopotassium salt, (9Z, 12R)-
74-98-6 Propane
75-01-4 Ethene, chloro-
75-05-8 Acetonitrile
75-28-5 Isobutane
Page 74 of 93
75-31-0 2-Propanamine
75319-63-0 beta-D-Glucopyranoside, hexadecyl (approval pending & tolerance pending)
75-37-6 1,1-Difluoroethane
7540-51-4 6-Octen-1-ol, 3,7-dimethyl-, (3S)-
75-43-4 Dichloromonofluoromethane
7543-51-3 Phosphoric acid, zinc salt (2:3), tetrahydrate
75-45-6 Chlorodifluoromethane
75499-50-2 Hypophosphoric acid, calcium salt
75-52-5 Nitromethane B2779
7553-56-2 Iodine
7558-79-4 Disodium phosphate
7558-80-7 Phosphoric acid, monosodium salt
75-65-0 2-Methyl-2-propanol
75673-43-7 Oxazolidine, 3,4,4-trimethyl-
75-68-3 1-Chloro-1,1-difluoroethane
7575-62-4 Disodium 4-dodecyl-2,4'-oxydibenzenesulfonate
75768-93-3 sulfophenyl)azo)phenyl)azo)-, compd. with 2,2',2"-nitrilotris(ethanol) (1:2)
7580-31-6 Nickel 2-ethylcaproate
2-Propenoic acid, 2-methyl-, polymer with ethyl 2-propenoate and alpha-(2-
75832-50-7 methyl-1-oxo-2-propenyl)-omega-(hexadecyloxy) poly (oxy-1,2-ethanediyl)
7585-39-9 beta-Cyclodextrin
7601-54-9 Trisodium phosphate
76-06-2 Chloropicrin
76-13-1 1,1,2-Trichloro-1,2,2-trifluoroethane
Diethyl Phosphite (Limited to use as a stabilizer in a non-food use formulation
762-04-9 at quantities less than or equal to .1%)
76-22-2 Camphor
7631-86-9 Silica (crystalline free)
7631-90-5 Sodium bisulfite (NaHSO3)
7631-95-0 Sodium molybdate
7631-99-4 Sodium nitrate
7632-00-0 Sodium nitrite
7632-04-4 Sodium perborate
7732-05-5 Sodium phosphate
763-69-9 Propanoic acid, 3-ethoxy-, ethyl ester
7646-85-7 Zinc chloride (ZnCl2)
7646-93-7 Sulfuric acid, monopotassium salt
7647-01-0 Hydrochloric acid
7647-14-5 Sodium chloride
764-71-6 Octanoic acid, potassium salt
76-49-3 endo-Bornyl acetate
76-59-5 Bromothymol blue
7664-38-2 Metaphosphoric acid
7664-93-9 Sulfuric acid
Page 75 of 93
7673-09-8 1,3,5-Triazine-2,4,6-triamine, N,N',N''-trichloro-
7681-11-0 Potassium iodide (KI)
7681-38-1 Sodium hydrogen sulfate
7681-49-4 Sodium fluoride
7681-52-9 Sodium hypochlorite
7681-53-0 Sodium hypophosphite
7681-57-4 Disulfurous acid, disodium salt
7681-82-5 Sodium iodide
7693-13-2 Calcium citrate
7695-91-2 DL-Vitamine E acetate
7697-37-2 Nitric acid
7699-41-4 Silicic acid (H2SiO3)
770-35-4 2-Propanol, 1-phenoxy-
7704-34-9 Sulfur
7705-08-0 Ferric chloride
77-06-5 Gibberellic acid
7720-78-7 Ferrous sulfate
7722-64-7 Potassium permanganate
7722-71-6 Oleyl dihydrogen phosphate
7722-76-1 Ammonium phosphate
7722-84-1 Hydrogen peroxide
7722-88-5 Diphosphoric acid, tetrasodium salt
7727-37-9 Nitrogen
7727-43-7 Barium sulfate
7727-54-0 Ammonium persulfate
7727-73-3 Disodium sulfate decahydrate
7732-18-5 Water
7733-02-0 Sulfuric acid, zinc salt (1:1)
1,6-Hexamethylene diamine, polymer with poly-methylene
77348-43-7 polyphenylisocyanate
7739-63-1 Sulfuric acid, monodecyl ester, potassium salt
7747-35-5 7a- Ethyldihydro-1H,3H,5H-oxazolo(3,4-c) oxazole
1H-3a,7-Methanoazulen-6-ol, octahydro-3,6,8,8-tetramethyl-,[3R-
77-53-2 (3α,3a.beta.,6α,7.beta,8aalpha)]
7757-79-1 Potassium nitrate
7757-82-6 Sodium sulfate
7757-83-7 Sodium sulfite
7757-86-0 Magnesium phosphate, dibasic
7757-87-1 Magnesium phosphate anhydrous
7757-93-9 Calcium phosphate, dibasic [JAN]
7758-02-3 Potassium bromide
7758-05-6 Iodic acid (HIO3), potassium salt
7758-09-0 Potassium nitrite
7758-11-4 Phosphoric acid, dipotassium salt
7758-16-9 Sodium acid pyrophosphate
Page 76 of 93
7758-23-8 Calcium phosphate, monobasic
7758-29-4 Sodium tripolyphosphate
77-58-7 Stannane, dibutylbis[(1-oxododecyl) oxy]-
7758-87-4 Tricalcium phosphate (Ca3(PO4)2)
7758-98-7 Copper(II) sulfate anhydrous (CuSO4)
7758-99-8 Copper sulfate perntahydrate
77-71-4 5,5-Dimethylhydantoin
7772-98-7 Thiosulfuric acid (H2S2O3), disodium salt
7774-34-7 Calcium chloride (CaCl2), hexahydrate
7775-09-9 Sodium chlorate
7775-11-3 Sodium chromate
7775-19-1 Sodium metaborate
7775-27-1 Peroxydisulfuric acid ([(HO)S(O)2]2O2), disodium salt
7778-18-9 Calcium sulfate
7778-49-6 Citric acid, potassium salt
7778-53-2 Tripotassium phosphate
7778-54-3 Calcium hypochlorite
7778-66-7 Hypochlorous acid, potassium salt
7778-77-0 Potassium phosphate monobasic (KH2PO4)
7778-80-5 Potassium sulfate
7779-88-6 Zinc nitrate
7779-90-0 Phosphoriccid, zinc salt (2:3)
7782-42-5 Graphite
7782-44-7 Oxygen
7782-50-5 Chlorine
7782-63-0 Ferrous sulfate heptahydrate
7782-99-2 Sulfurous acid
7783-18-8 Thiosulfuric acid (H2S2O3), diammonium salt
7783-20-2 Ammonium sulfate {(NH4)2SO4}
7783-28-0 Diammonium phosphate
7784-25-0 Ammonium alum
2-Anthracenesulfonic acid, 1-amino-9,10-dihydro-4-{(4-methyl-3-
77847-18-8 sulfophenyl)amino}-9,10-dioxo-,
7785-26-4 2-Pinene, (1S,5S)-(-)-
7785-87-7 Manganese sulfate
7785-88-8 Sodium aluminum phosphate
77-86-1 1,3-Propanediol, 2-amino-2-hydroxymethyl-
7789-80-2 Calcium iodate
77-90-7 1,2,3-Propanetricarboxylic acid, 2-(acetyloxy)-, tributyl ester
7790-76-3 Calcium pyrophosphate
7790-86-5 Cerous chloride
7790-92-3 Hypochlorous acid
7791-13-1 Cobalt chloride (CoCl2), hexahydrate
Page 77 of 93
7791-20-0 Nickel chloride (NiCl2), hexahydrate
77-92-9 Citric acid
77-93-0 Triethyl citrate
77-99-6 Trimethylolpropane
7803-63-6 Ammonium bisulfate
78-07-9 Ethyl triethoxysilane
78-23-9 Octadecanoic acid, 3-hydroxy-2,2-bis(hydroxymethyl)propyl ester
1-Propanesulfonic acid, 2-hydroxy-3-(2-propenyloxy)-,monosodium salt,
78266-09-8 polymer with 2-propenoic
Poly(oxy-1,2-ethanediyl),α-hydro-ω-hydroxy-, mono-C11-14-isoalkyl ethers,
78330-24-2 C13-rich, p
Sodium alpha-sulfo-omega-hydroxy-poly(oxy-1,2-ethanediyl) C11-14-isoalkyl
78330-30-0 ethers, C13 rich
78-40-0 Tri-ethyl phosphate
78-42-2 Tris(2-ethylhexyl) phosphate
78491-02-8 Diazolidinyl urea
78-51-3 Tributoxyethyl phosphate
78-59-1 Isophorone
78-66-0 3,6-Dimethyl-4-octyne-3,6-diol
78-69-3 3-Octanol, 3,7-dimethyl-
78-70-6 3,7-Dimethyl-1,6-octadien-3-ol
78-78-4 Isopentane
78-83-1 Isobutyl alcohol
78-92-2 sec-Butanol
78-93-3 Methyl ethyl ketone
78-96-6 Monoisopropanolamine
79070-11-4 Poly(difluoromethylene), α-chloro-ω-(2,2-dichloro-1,1,2-trifluoroethyl)-
79-09-4 Propanoic acid
79-11-8 Monochloroacetic acid
79-14-1 Hydroxyacetic acid
79-21-0 Peracetic acid
2,7-Naphthalenedisulfinic acid, 5-(benzoylamino)-3-{{2-(4-
79234-36-9 cyclohexylphenoxylphenoxy)phenyl}azo}
79-24-3 Nitroethane
1,3-Naphthalenedisulfonic acid, 7-[[4-[(6-amino-hydroxy-3-sulfo-2-
79255-97-3 naphthalenyl)azo]-5-methoxy-2-m
1,5-Naphthalenedisulfonic acid, 3-[[4-[(6-amino-hydroxy-3-sulfo-2-
79255-98-4 naphthalenyl)azo]-5-methoxy-2-m
79-33-4 L-Lactic acid
79-34-5 1,1,2,2-Tetrachloroethane
79-41-4 Methacrylic acid
79620-91-0 Diacetyl tartaric acid esters of mono and diglycerides of edible fats
79-83-4 D-Pantothenic acid
79-92-5 Camphene
8000-25-7 Oils, rosemary
Page 78 of 93
8000-27-9 Oils, cedarwood
8000-28-0 Oils, lavender
8000-29-1 Oil of citronella
8000-34-8 Oils, clove
8000-41-7 Terpineol
8000-46-2 Oils, geranium
8000-48-4 Eucalyptus oil
8001-20-5 Tung oil
8001-22-7 Soybean oil
8001-23-8 Safflower oil
8001-25-0 Olive oil
8001-26-1 Linseed oil
8001-29-4 Cottonseed oil
8001-30-7 Corn oil
8001-31-8 Coconut oil
8001-54-5 Benzalkonium chloride [BAN:INN:JAN]
8001-69-2 Cod-liver oil
8001-75-0 Ceresin wax
8001-78-3 Hydrogenated castor oil
8001-79-4 Castor oil
8001-97-6 Aloe vera gel
8002-03-7 Peanut oil
8002-09-3 Pine oil
8002-13-9 Rapeseeds
8002-26-4 Tall oil
8002-31-1 Cocoa
8002-33-3 Sulfonated castor oil
8002-43-5 Lecithins
8002-48-0 Malt extract
8002-50-4 Menhaden oil
8002-72-0 Onion oil
8002-74-2 Paraffin wax
8002-75-3 Palm oil
8004-87-3 C.I. Basic Violet 1
8004-92-0 C.I. Acid Yellow 3
8005-03-6 C.I. Acid Black 2
8005-44-5 Fatty alcohols
8005-72-9 C.I. Direct Yellow 28
8006-54-0 Lanolin
8006-64-2 Turpentine, oil
8006-90-4 Oils, peppermint
8006-95-9 Wheat germ oil
8007-02-1 Oil of lemongrass
8007-08-7 Oils, ginger
Page 79 of 93
8007-11-2 Origanum oil
8007-20-3 Oils, cedar leaf
8007-24-7 Cashew, nutshell liq.
8007-43-0 Sorbitan sesquioleate
8007-44-1 Oils, pennyroyal, hedeoma pulegioides
8007-46-3 Oils, thyme
8007-69-0 Oils, almond
8007-70-3 Oil of anise
8007-75-8 Oil of Bergamot
8007-93-0 Belladonna leaf
8008-20-6 Kerosene (deodorized)
8008-26-2 Oils, lime
8008-51-3 Oil of camphor
8008-56-8 Oil of lemon
8008-57-9 Oil of orange
8008-74-0 Fats and glyceridic oils, sesame
8008-79-5 Spearmint oil
8008-80-8 Oils, spruce
8009-03-8 Petrolatum
8011-48-1 Pine tar
8011-63-0 Bordeaux mixture
8012-89-3 Beeswax
8012-95-1 Paraffin oils
8013-01-2 Yeast, ext.
8013-07-8 Epoxidized soybean oil
8013-10-3 Juniper tar oil
8013-17-0 Invert sugar
8013-76-1 Oil of bitter almond
8014-09-3 Oils, patchouli
8014-19-5 Oils, palmarosa
8015-73-4 Oils, basil
8015-80-3 Candlenut oil
8015-80-3 Kukui nut oil
8015-86-9 Carnauba wax
8016-11-3 Epoxidized linseed oil
8016-13-5 Fish oil
8016-20-4 Oils, grapefruit
8016-35-1 Oiticica oil
8016-70-4 Hydrogenated soybean oil
8016-85-1 Oils, tangerine
8016-96-4 Oils, vetiver
8020-83-5 Hydrocarbon oils
8021-29-2 Oils, Fir
8021-99-6 Charcoal,bone
8022-15-9 Oils, lavandin
Page 80 of 93
8022-37-5 Armoise Oil
8022-56-8 Oils, sage
8023-74-3 Mink oil
8023-77-6 Resins, oleo-, capsicum
8024-32-6 Fats and glyceridic oils, avocado
80-26-2 3-Cyclohexene-1-methanol, α,α,4-trimethyl-, acetate
80-27-3 α-Terpinyl propionate
8027-33-6 Alcohols, lanolin
8028-48-6 Sweet orange peel tincture
8028-52-2 Vinegar (maximum 8% acetic acid in solution)
8028-66-8 Honey
8028-89-5 Caramel
8029-31-0 Beer
8029-76-3 Hydroxylated lecithin
8030-12-4 Tallow hydrogenated
8030-30-6 Petroleum Naphtha
8030-76-0 Lecithins, soya
8030-78-2 Tallow trimethyl ammonium chloride
8031-18-3 Fuller's earth
8039-09-6 Ethoxylated lanolin
80-39-7 N-Ethyl-p-tolylsulfonamide
8042-47-5 Mineral Oil U.S.P.
8042-47-5 White mineral oil (petroleum)
80-46-6 p-tert-Amylphenol
8046-71-7 Soaps
8046-74-0 Soaps, potassium
8047-99-2 Ethyl toluene sulfonamide
8049-98-7 Milk
8049-99-8 Milorganite
8050-07-5 Olibanum
8050-09-7 Rosin ( wood )
8050-13-3 Methyl hydrogenated rosinate
8050-15-5 Methyl ester of rosin, partially hydrogenated
8050-26-8 Resin acids and Rosin acids, esters with pentaerythritol
8050-31-5 Resin acids and rosin acids, esters with glycerol
8050-33-7 Polyoxyethylene* ester of rosin *(10-15 moles)
8050-81-5 Simethicone
8052-10-6 Tall oil rosin
8052-35-5 Molasses
8052-41-3 Stoddard solvent
8052-42-4 Asphalt
8052-48-0 Fatty acids, tallow, sodium salts
8052-50-4 Tallow, sulfated, sodium salt
80-54-6 Benzenepropanal, 4-(1,1-dimethylethyl)-α-methyl-
80-56-8 alpha-Pinene
Page 81 of 93
2-Propenoic acid, polymer with ethyl 2-methyl-2-propenoate and 2-
80570-62-3 methylpropyl 2-methyl-2-propenoate
80584-98-1 Ethoxylated adduct of dehydroabietylamine
Linseed oil acids, formaldehyde and 2-amino-2-(hydroxymethyl)-1,3-
80584-99-2 propanediol reaction product
8061-51-6 Lignosulfonic acid, sodium salt
8061-52-7 Lignosulfonic acid, calcium salt
8061-53-8 Lignosulfonic acid, ammonium salt
8061-54-9 Lignosulfonic acid, magnesium salt
8062-15-5 Lignosulfonic acid
80-62-6 Methyl methacrylate
1,2,3-Propanetricarboxylic acid, 2-hydroxy-, mixt. with(1,1-dimethylethyl)-4-
8064-49-1 methoxyphenol and pr
8066-83-9 Lauric diethanolamide
8068-05-1 Lignin, alkali
80762-96-5 Propylene glycol di-tert-butyl ether
81-07-2 Saccharin
81-13-0 D-Panthenol
1-Propanaminium, N-(2-hydroxyethyl)-3-{(2-hydroxy-3-
81190-38-7 sulfopropyl){(tridecafluorohexyl)sulfonyl}a
811-97-2 1,1,1,2-Tetrafluoroethane
813-94-5 Calcium citrate
Copper, (29H,31H-phthalocyaninato(2-)-N29,N30,N31,N32)-, ((3-
81457-65-0 (methylethoxy)propyl)amino)sulfonyl derivs.
81-48-1 1-Hydroxy-4-(p-toluidino)anthraquinone
81-77-6 C.I. Pigment Blue 60
818-08-6 Dibutylin oxide
81-88-9 Xanthylium, 9-(2-carboxyphenyl)-3,6-bis(diethylamino)-, chloride
822-16-2 Octadecanoic acid, sodium salt
822-16-2 Octadecanoic acid, sodium salt
822-17-3 9,12-Octadecadienoic acid (9Z, 12Z)-, sodium salt
82385-42-0 Saccharin, sodium salt hydrate
827-19-0 Benzenesulfonic acid, 2,5-dimethyl-, sodium salt
827-21-4 Benzenesulfonic acid, 2,4-dimethyl-, sodium salt
828-00-2 Dimethoxane
Benzenesulfonic acid, 2,2'-(1,2-ethenediyl)bis[5-[[4-[(2-hydroxypropyl)
82833-23-6 amino]-6-(phenylamino)-1,
82919-37-7 Decanedioic acid, methyl 1,2,2,6,6-pentamethyl-4-piperidinyl ester
82980-39-0 Glycerides, wheat germ-oil
83137-86-4 Acrysol RM 5
83-66-9 2,6-Dinitro-3-methoxy-4-tert-butyltoluene
83-88-5 Riboflavin
842-07-9 2-Naphthalenol, 1-(phenylazo)-
Benzenepropanoic acid, 3-(2H-benzotriazol-2-yl)-5-(1,1-dimethylethyl)-4-
84268-33-7 hydroxy-, methyl ester (
Page 82 of 93
84501-72-4 Sodium isononanoate
84540-57-8 Propylene glycol monomethyl ether acetate
84604-14-8 Extract of rosemary
84-66-2 Diethyl phthalate
846-70-8 2-Naphthalenesulfonic acid, 8-hydroxy-5,7-dinitro-, disodium salt
84681-71-0 Hydrogenated rapeseed oil
84696-51-5 Spearmint, ext.
84-74-2 Dibutyl phthalate
84775-78-0 Kelp
84-88-8 5-Quinolinesulfonic acid, 8-hydroxy-
84929-31-7 Lemon extract
84961-66-0 Tobacco dust
85049-30-5 Bentonite, sodian
85116-93-4 Fatty acids, C16-18, esters with pentaerythritol
85-40-5 4-Cyclohexene-1,2-dicarboximide
85-41-6 Phthalimide
85-44-9 Phthalic anhydride
85536-14-7 Benzenesulfonic acid, 4-C10-13-sec-alkyl derivs.
85585-93-9 Carbonic acid, aluminum magnesium salt, basic
85637-75-8 Oxirane, methyl-, polymer with oxirane, mono[2-(2-butoxyethoxy)ethyl] ether
7-Benzothiazolesulfonic acid, 2-{4-{{4-{{3-{{5-(aminocarbonyl)-1- ethyl-
85665-95-8 1,6-dihydro-2-hydroxy-4-m
85-68-7 Butyl benzyl phthalate
85711-55-3 Fatty acids, tall-oil, compds. with oleylamines
85763-69-5 Iron, C3-13-carboxylate naphthenate complexes
Chromium, 2-[(4,5-dihydro-3-methyl-5-oxo-1-phenyl-1H-pyrazol-4-
85828-89-3 yl)azo]benzoate 2-[4,5-dihydro-3
85-83-6 C.I. Solvent Red 24
85-86-9 2-Naphthalenol, 1-((4-(phenylazo)phenyl)azo)-
860-22-0 FD&C Blue No. 2
86352-09-2 Naphthalenesulfonic acids, polymers with formaldehyde, sodium salts
1-(2',5'-Dichloro-4'-sulfophenyl)-3-methyl-4-((4"-(N-polyoxyalkylene
86356-61-8 sulfonamide)phenyl)azo)pyrazol-5-one, sodium salt
864277-75-8 Lignoflex
866-83-1 Potassium citrate, monobasic
866-84-2 Potassium citrate
868-18-8 Sodium tartrate
2-Propenoic acid, polymer with 2-hydroxypropyl 2-propenoate and sodium 2-
Poly(oxy-1,2-ethanediyl), alpha-methyl-omega-[2-methyl-3-[1,3,3,3-
868662-38-8 tetramethyl-1-[(trimethylsilyl) oxy] disiloxanyl]) propoxy]
86893-19-8 Ethoxylated methyl glucoside dioleate
87-01-4 7-(Dimethylamino)-4-methylcoumarin
Page 83 of 93
87-20-7 Isoamyl salicylate
87244-72-2 Siloxanes and Silicones, polyoxyalkylene-
872-50-4 N-Methyl-2-pyrrolidone
87-25-2 Ethyl anthranilate
Polyoxyethylene* amylphenol - formaldehyde resin *(10 moles) (Mol. Wt.
87315-51-3 1500-3000)
87-69-4 Tartaric acid
877-24-7 1,2-Benzenedicarboxylic acid, monopotassium salt
2H-1,3,5-Oxadiazine-2,4,6(3H,5H)-trione, 3,5-bis(6-isocyanatohexyl)-,
87823-33-4 polymer with N-(2-aminoethyl)-1,2-ethanediamine
87-90-1 Symclosene
88-04-0 p-Chloro-m-xylenol
88-12-0 N-Vinyl-2-pyrrolidone
Poly(oxy-1,2-ethanediyl), alpha-[3-[dimethyl[2-(trimethylsilyl) ethyl] silyl]
881689-05-0 propyl]-omega-methoxy-
88230-35-7 Hexanol, acetate, branched and linear
88-24-4 2,2'-Methylenebis(4-ethyl-6-tert-butylphenol)
88349-88-6 Acetic acid, [(5-chloro-8-quinolinyl)oxy]- (metabolite of inert safener)
88-41-5 Cyclohexanol, 2-(1,1-dimethylethyl)-, acetate
88-61-9 Benzenesulfonic acid, 2,4-dimethyl-
2-Propenoic acid, methyl ester, polymer with ethenyl acetate, hydrolyzed,
1-Butanol, 4-(ethenyloxy)-, polymer with chlorotrifluoroethene,
88795-12-4 (ethenyloxy)cyclohexane and ethoxyethene
88-89-1 2,4,6-Trinitrophenol
2-Propenoic acid, 2-methyl-, polymers with Et acrylate and polyethylene glycol
888969-14-0 methacrylate C18-22-alkyl ethers
Isocyanic acid, polymethylenepolyphenylene ester, polymer with N-(2-
88923-95-9 aminoethyl)-N'-[2-[(2-aminoethyl)amino]ethyl]-1,2-ethanediamine
89-04-3 Trioctyl trimellitate
Oxirane, hexadecyl-, reaction products with polyethylene-polypropylene glycol
893427-80-0 ether with trimethylolpropane (3:1)
2-Propenoic acid, 2-methyl-.polymer with ethyl 2-propenoate and methyl 2-
89511-79-5 methyl-2-propenoate, s
89595-41-5 Phosphate, dihydrogen, monopotassium salt
89-65-6 D-Isoascorbic acid
2-Propenoic acid, polymer with ethenylbenzene and (1-methylethenyl)benzene,
89-78-1 Menthol
89-83-8 Thymol
89960-16-7 Butanedioic acid, sulfo-, 1,4-di-sec-octyl ester, sodium salt
9000-01-5 Gum arabic
9000-07-1 Carrageenan
9000-11-7 Cellulose, carboxymethyl ether
Page 84 of 93
9000-21-9 Furcellaran
9000-28-6 Gum ghatti
9000-30-0 Guar gum
9000-40-2 Locust bean gum
9000-50-4 Oils, oakmoss-resinoid
9000-59-3 Shellac
9000-65-1 Gum tragacanth
9000-69-5 Pectin
9000-70-8 Gelatins
9000-71-9 Caseins
9000-90-2 Amylase, alpha-
9001-45-0 beta-D-glucuronidase
9001-45-0 beta-Glucuronidase
9001-73-4 Papain
9002-18-0 Agar
9002-81-7 Poly(oxymethylene)
90028-20-9 Echinacea purpurea, ext.
9002-84-0 Ethene, 1,1,2,2-tetrafluoro-, homopolymer
9002-86-2 Polyvinyl chloride resin
9002-88-4 Polyethylene
9002-89-5 Polyvinyl alcohol
9002-92-0 Poly(oxy-1,2-ethanediyl), alpha-dodecyl-omega-hydroxy-
Poly(oxy-1,2-ethanediyl), alpha-[4-(1,1,3,3-tetramethylbutyl}phenyl]- omega-
9002-93-1 hydroxy-
9003-01-4 Carboxy vinyl polymer
9003-04-7 Sodium polyacrylate
9003-05-8 Polyacrylamide
9003-06-9 Acrylamide acrylic acid polymer
9003-07-0 Polypropylene
9003-08-1 2,4,6-Triamino-s-triazine-formaldehyde polymer
9003-09-2 2-Ethene, methoxy-, homopolymer
9003-11-6 Oxirane, methyl-, polymer with oxirane
9003-13-8 Butoxypolypropylene glycol
9003-17-2 Butadiene resin
9003-18-3 2-Propenenitrile, polymer with 1,3-butadiene
9003-20-7 Acetic acid ethenyl ester, homopolymer
9003-22-9 Vinyl chloride vinyl acetate copolymer
9003-27-4 Polyisobutylene
9003-28-5 Butene, homopolymer
9003-29-6 Polybutene
9003-32-1 Ethyl acrylate polymer
9003-35-4 Phenol, polymer with formaldehyde
9003-39-8 2-Pyrrolidinone, 1-ethenyl-, homopolymer
9003-49-0 Polymerized butyl acrylate
9003-53-6 Polystyrene resin
Page 85 of 93
9003-55-8 Butadiene-styrene copolymer
9003-56-9 2-Propenenitrile, polymer with 1,3-butadiene and ethenylbenzene
9003-63-8 n-Butyl methacrylate, polymerized
9003-68-3 Pegoterate
9004-32-4 Cellulose, carboxymethyl ether, sodium salt
9004-34-6 Cellulose
9004-35-7 Cellulose, acetate
9004-36-8 Cellulose acetate butyrate
9004-53-9 Dextrin
9004-57-3 Cellulose, ethyl ether
9004-58-4 Cellulose, ethyl 2-hydroxyethyl ether
9004-62-0 Cellulose, 2-hydroxyethyl ether
9004-64-2 Cellulose, 2-hydroxypropyl ether
9004-65-3 Cellulose, 2-hydroxypropyl methyl ester
9004-67-5 Cellulose, methyl ether
9004-74-4 Poly(oxy-1,2-ethanediyl),.alpha.-methyl-.omega.-hydroxy-
9004-77-7 Butoxypoly(ethyleneoxy) ethanol
9004-81-3 Polyoxyethylene monolaurate (Mol. Wt. 780)
9004-82-4 Poly(oxy-1,2-ethanediyl), alpha-sulfo-omega-(dodecyloxy)-, sodium salt
9004-83-5 Poly(oxy-1,2-ethanediyl), [alpha]-[2(tert-dodecylthio)ethyl]-[omega] hydroxy-
9004-87-9 Ethoxylated isooctylphenol
9004-94-8 Polyethyleneglycol palmitate
9004-95-9 Polyoxyethylene* cetyl alcohol *(2.5 moles)
9004-96-0 Poly(oxy-1,2-ethanediyl), alpha-(1-oxo-9-octadecenyl)-omega-hydroxy-(Z)-
Poly(oxy-1,2-ethanediyl), alpha-[(9Z,12R)-12-hydroxy-1-oxo-9-octadecenyl]-
9004-97-1 omega-hydroxy-
9004-98-2 Poly(oxy-1,2-ethanediyl), alapha-(9Z)-9-octadecenyl-omega-hydroxy-
9004-99-3 Polyoxyethylene stearate (Mol. Wt. 600-2000)
9005-00-9 Poly(oxy-1,2-ethanediyl), alpha-octadecyl-omega-hydroxy-
Poly(oxy-1,2-ethanediyl), α-(1-oxododecyl)-ω-[(1-
9005-02-1 oxododecyl)oxy]-
9005-07-6 Polyoxyethylene dioleate
9005-08-7 Poly(oxy-1,2-ethanediyl), α-(1-oxooctadecyl)-ω-((1-oxooctadecyl)oxy)-
9005-25-8 Starch
9005-27-0 Starch , 2-hydroxyethyl ether
9005-32-7 Alginic acid
9005-35-0 Calcium alginate
9005-37-2 Propylene glycol alginate
9005-38-3 Sodium alginate
Caseins, ammonium complexes (food commodity allergen - use pattern is
9005-42-9 limited)
9005-46-3 Caseins, sodium complexes
9005-53-2 Lignin
9005-64-5 Sorbitan, monododecanoate, poly(oxy-1,2-ethanediyl) derivs.
9005-65-6 Sorbitan, mono-9-octadecenoate, poly(oxy-1,2-ethanediyl) derivs., (Z)-
Page 86 of 93
9005-66-7 Polyoxyethylene* sorbitan monopalmitate *(20 moles)
9005-67-8 Polyoxyethylene sorbitan monostearate
9005-70-3 Polyoxyethylene* sorbitan trioleate *(20 moles)
9005-71-4 Polyoxyethylene* sorbitan tristearate *(20 moles)
9005-90-7 Turpentine
9006-03-5 Chlorinated rubber
9006-26-2 2,5-Furanedione, polymer with ethene
9006-27-3 Poly(oxy-1,2-ethanediyl), alpha-(1-oxododecyl)-omega-methoxy-
90063-37-9 Lavender, Lavandula angustifolia, ext.
9006-50-2 Egg white
9006-65-9 Dimethicone
9007-13-0 Resin acids and rosin acids, calcium salts
9007-48-1 Polyglyceryl oleate
9008-34-8 Resin acids and rosin acids, manganese salts
9008-63-3 Naphthalenesulfonic acid, sodium salt, polymer with formaldehyde
9009-32-9 Polyglyceryl stearate
Ethanol, 2,2',2''-nitrilotris-, compd. with α-(2,4,6-tris(1-phenylethyl)phenyl)-ω-
90093-37-1 hydroxypoly(oxy-1,2-ethanediyl)phosphate
9010-66-6 Zein
9010-77-9 Ethylene acrylic acid
9010-79-1 Ethylene-propylene copolymer
9010-88-2 2-Propenoic acid, 2-methyl-, methyl ester, polymer with ethyl 2-propanoate
9010-89-3 Poly(diethylene glycol adipate)
9011-05-6 Cross linked protein urea-formaldehyde copolymer
9011-06-2 Ethene, 1,1-dichloro-, polymer with chloroethene
9011-09-0 2-Propenoic acid, butyl ester, polymer with 1,1-dichloroethene
9011-11-4 Styrene, alpha-methyl-, polymer with styrene
9011-13-6 Styrene - maleic anhydride resin
9011-14-7 Poly(methyl methacrylate)
9011-16-9 Methoxyethylene-maleic anhydride copolymer
9011-29-4 Sorbitol sesquioleate ethoxylated(30 moles)
9012-54-8 Cellulase
9012-76-4 Chitosan
9014-01-1 Subtilisin
90147-57-2 Yucca extractives (from Yucca, Agavaceae)
90147-58-3 Yucca, extract
9014-85-1 Polyoxyethylene* 2,4,7,9-tetramethyl-5-decyne-4,7-diol *(3.5-30 moles)
9014-90-8 Sodium nonylphenyl polyoxyethylene* sulfate *(4-5 moles)
9014-92-0 alpha-(Dodecylphenyl)-omega-hydroxypoly(oxy-1,2-ethanediyl)
9014-93-1 Polyoxyethylene* dinonylphenol *(2-50 moles)
9015-54-7 Protein hydrolyzates
9016-00-6 Poly(oxy(dimethylsilylene))
9016-45-9 Poly(oxy-1,2-ethanediyl), α-(nonylphenyl)-ω-hydroxy-
9016-87-9 Polymethylenepolyphenylene isocyanate
Page 87 of 93
1,4-Benzenedicarboxylic acid, polymer with 1,2-ethanediol and alpha-hydro-
9016-88-0 omega-hydroxypoly(oxy-1,2-ethanediyl)
9017-33-8 Naphthalenesulfonic acid-formaldehyde condensate
9017-68-9 Acrylic acid, polymer with isooctyl acrylate
Benzenemethanaminium, ar-ethenyl-N,N,N-trimethyl-, hydroxide, polymer
9017-79-2 with diethenylbenzene
9017-80-5 Benzenemethanaminium, ar-ethenyl-N,N,N-trimethyl-, chloride, homopolymer
Poly(oxy-1,4-butanediyl), α-hydro-ω-hydroxy-, polymer with 1,4-butanediol
9018-04-6 and 1,1'-methylenebis(4-isocyanatobenzene)
9019-29-8 Butene, polymer with ethene
90194-45-9 Benzenesulfonic acid, mono-C10-13-alkyl derivs., sodium salts
2-Propenoic acid, 2-methyl-, polymer with diethenylbenzene and
9020-13-7 ethenylbenzene
9032-42-2 Methyl hydroxyethyl cellulose
9033-79-8 2-Propenoic acid, polymer with sodium 2-propenoate
9036-19-5 Poly(oxy-1,2-ethanediyl), α-((1,1,3,3-tetramethylbutyl)phenyl)-ω-hydroxy-
9036-66-2 D-Galacto-L-arabinan
2-Propenoic acid, monoester with 1,2-propanediol, polymer with chloroethene
and ethenyl acetate, ester with ethenylbenzene polymer with 2,5-furandione 2-
90371-20-3 butoxyethyl ester
9038-29-3 Propylene oxide ethylene oxide polymer decyl ether
Oxirane, decyl-, reaction products with polyethylene-polypropylene glycol
903890-89-1 ether with trimethylopropane (3:1).
Oxirane, methyl-, polymer with oxirane ether with 2-ethyl-2-(hydroxymethyl)-
903890-90-4 1,3-propanediol (3:1), reaction products with tetradecyloxirane.
9038-95-3 Oxirane, methyl-, polymer with oxirane, monobutyl ether
9041-04-7 Benzenesulfonic acid, hydroxy-, polymer with formaldehyde and urea
9041-33-2 Oxirane, methyl-, polymer with oxirane, mono-2-propenyl ether
9042-19-7 Poly[oxy(methyl-1,2-ethanediyl)], alpha-2-propenyl-omega-hydroxy-
9043-30-5 Polyoxyethylene isotridecyl ether
90438-79-2 Acetic acid, C6-8-branched alkyl esters
9044-17-1 Butene, polymer with 2-methyl-1-propene
9046-01-9 Poly(oxy-1,2-ethanediyl), alpha-tridecyl-omega-hydroxy-, phosphate
9046-09-7 Poly(oxy-1,2-ethanediyl), α-(tributylphenyl)-ω-hydroxy-
Poly(oxy(methyl-1,2-ethanediyl)), α-(2-aminomethylethyl)-ω-(2-
9046-10-0 aminomethylethoxy)-
9049-05-2 Carrageenan calcium salt
9050-36-6 Maltodextrin
90506-18-6 Phosphoric acid, C8-16-alkyl esters, compds. with diethanolamine
9051-57-4 Ammonium nonylphenyl polyoxyethylene sulfate *(4-5 moles)
9063-38-1 Starch, carboxymethyl ether, sodium salt
9063-89-2 Poly(oxy-1,2-ethanediyl), alpha-(octylphenyl)-omega-hydroxy-
9064-13-5 Poly{oxy(methyl-1,2-ethanediyl)}, alpha-(methylphenyl)-omega-hydroxy-
9069-79-8 Potassium salt of naphthalenesulfonic acid - formaldehyde condensate
9069-80-1 Formaldehyde-naphthalenesulfonic acid polymer, ammonium salt
Page 88 of 93
Dimethyl 5-sodiosulfoisophthalate-dimethyl terephthalate-ethylene glycol-
9069-94-7 polyethylene glycol copolymer
9071-85-6 Poly(oxy-1,2-ethanediyl), α,α'-phosphinicobis(ω-(nonylphenoxy)-
90-72-2 Phenol, 2,4,6-tris{(dimethylamino)methyl}-
Poly(oxy-1,2-ethanediyl), .alpha.,.alpha.',.alpha.'',.alpha.'''-[[(2-
sulfophenyl)methyliumylidene]bis(4,1-phenylenenitrilodi-2,1-
9079-33-8 ethanediyl)]tetrakis[.omega.-hydroxy-, chloride, monosodium salt
Poly(oxy-1,2-ethanediyl), .alpha.,.alpha.',.alpha.'',.alpha.'''-[[(2-
sulfophenyl)methyliumylidene]bis[(3-methyl-4,1-phenylene)nitrilodi-2,1-
9079-34-9 ethanediyl]]tetrakis[.omega.-hydroxy-, chloride, monosodium salt
90-80-2 Glucono-delta-lactone
9081-17-8 Nonylphenol, ethoxylated, monoether with sulfuric acid
9082-00-2 Oxirane, methyl-, polymer with oxirane, ether with 1,2,3-propanetriol (3:1)
9084-06-4 Naphthalenesulfonic acid, polymer with formaldehyde, sodium salt
Poly(oxy-1,2-ethanediyl), alpha-(phenylmethyl)-omega-((1,1,3,3-
9086-75-3 tetramethylbutyl)phenoxy)-
9087-53-0 Polyethylene-polypropylend glycol hexadecyl ether
91031-95-7 Mannitan coconut oil ester
91051-70-6 Propylene glycol tall oil ester
91078-64-7 Naphthalenesulfonic acids, branched and linear Bu derivs., sodium salts
91-20-3 Naphthalene
91-53-2 Ethoxyquin
2,7-Naphthalenedisulfonic acid, 3-hyroxy-4-((4-sulfo-1-naphthyl)azo)-,
915-67-3 trisodium salt
91697-98-2 Glycerides, C8-18 and C18-unsatd. mono-
91994-94-4 Acetylated lanolin alcohol
92129-90-3 Whey
92257-31-3 2-Naphthalenol ((phenylazo) phenyl) azo alkyl derivatives.
928-72-3 Glycine, N-(carboxymethyl)-, disodium salt
928-96-1 3-Hexen-1-ol, (3Z)-
93-08-3 2'-Acetonaphthone
93385-02-5 1-Propanol, 2-(tetradecyloxy)-,acetate
93385-03-6 3,6,9,12-Tetraoxaoctacosan-1-ol, 11-methyl, acetate
93-56-1 Phenyl glycol
93763-70-3 Perlite, expanded
93-83-4 9-Octadecenamide, N,N-bis(2-hydroxyethyl)-, (Z)-
93858-51-6 Benzenesulfonic acid, dodecyl-, compd. with 3-methoxy-1-propanamine (1:1)
93-89-0 Benzoic acid, ethyl ester
93918-16-2 Manganese neononoate
93-92-5 Benzenemethanol,α-methyl-,acetate
94-09-7 Ethyl p-aminobenzoate
94-13-3 Propyl p-hydroxybenzoate
1-Propanesulfonic acid, 3-{{3-
94133-90-1 (dimethylamino)propyl}{(heptadecafluorooctyl)sulfonyl}amino}-2-hy
94133-91-2 1-Propanaminium, 3-{{(heptadecafluorooctyl)sulfonyl}(2-hydroxy-3-
Page 89 of 93
sulfopropyl)amino}-N-(2-hydrox
94248-66-5 Isohexadecanoic acid, monoester with glycerol
94266-47-4 Citrus, ext.
94-26-8 Butyl p-hydroxybenzoate
94313-89-0 Ammonium diisodecyl sulfosuccinate
94349-62-9 Aloe barbadensis, ext.
94-36-0 Benzoyl peroxide
94-91-7 N,N'-Disalicylidene-1,2-propanediamine
95-14-7 1,2,3-Benzotriazole
95-19-2 1-(2-Hydroxyethyl)-2-(heptadecyl)imidazoline
95-38-5 1-(2-Hydroxyethyl)-2-(heptadecenyl)imidazoline
95-47-6 2-Xylene
95-48-7 o-Cresol
95-49-8 o-Chlorotoluene
95-63-6 Trimethylbenzene
1H-Imidazoledipropanoic acid, 4,5-dihydro-1-(2-hydroxyethyl)-2-norcoco
95913-20-5 alkyl derivs., di-me esters, phosphates (esters), sodium salts
959-55-7 Benzenemethanaminium, N,N-dimethyl-N-octyl-, chloride
96-29-7 Methyl ethyl ketoxime
96-48-0 gamma-Butyrolactone
96949-21-2 Rhamsan gum
97-23-4 Dichlorophene
97298-48-1 Bis(1-methylheptyl) 2-butenedioate
97-53-0 Phenol, 2-methoxy-4-(2-propenyl)-
97-56-3 Benzenamine, 2-methyl-4-{(2-methylphenyl)azo}-
97-59-6 Allantoin
97-63-2 2-Propenoic acid, 2-methyl-, ethyl ester
97-64-3 Lactic acid, ethyl ester
97675-81-5 Fish, meal
97676-23-8 Oils, licorice
97766-30-8 Orange, sweet, valencia, ext.
97-78-9 Glycine, N-methyl-N-(1-oxododecyl)-
97-85-8 Isobutyl isobutyrate
97-88-1 Butyl methacrylate
Acrylic acid-sodium acrylate-sodium-2-methylpropanesulfonate
97953-25-8 copolymer(minimum average molecular
97-99-4 Tetrahydrofurfuryl alcohol
98-52-2 Cyclohexanol, 4-(1,1-dimethylethyl)-
98-54-4 p-tert-Butylphenol
98-55-5 alpha-Terpineol
98730-04-2 Benoxacor
98824-28-3 Casamid 362
98-82-8 Benzene, (1-methylethyl)-
Page 90 of 93
98-86-2 Acetophenone
98-92-0 Nicotinamide
Xanthylium, 9-(2-(ethoxycarbonyl)phenyl)-3,6-bis(ethylamino)-2,7-dimethyl-,
989-38-8 chloride
98-94-2 N,N-Dimethylcyclohexylamine
99-07-0 DMP (dimethylaminomethylphenols) - epoxy curing agents (hardeners)
994-36-5 Citric acid, sodium salt
99607-70-2 Acetic acid, {(5-chloro-8-quinolinyl)oxy}-, 1-methylhexyl ester
99734-09-5 Poly(oxy-1,2-ethanediyl), α-{tris(1-phenylethyl)phenyl}-ω-hydroxy-
99-76-3 Benzoic acid, 4-hydroxy-, methyl ester
99-85-4 .gamma.-Terpinene
99-86-5 α-Terpinene
99-87-6 p-Cymene
999-97-3 Silanamine, 1,1,1-trimethyl-N-(trimethylsilyl)-
N/A 1-Benzyl-2-stearylbenzimidazol-6,3'-disulfonic acid, sodium salt
5-Enolpyruvylshikimate-3-phosphate synthase as produced in potato by the
CTP2-CP4syn gene and its controlling sequences and found in the following
N/A construct: PV-STMT01
a-Alkyl*-omega-hydroxypoly(oxyethylene) poly(oxypropylene) condensate
N/A with monostearyl acid phosphate *(30% C14, 30% C13, 20% C12, 20% C10)
N/A Alfalfa meal
N/A Almond hulls
N/A Almond shells
N/A Aluminum - magnesium stearate
N/A Apple pomace
N/A Bacillus megaterium NRRL #B-3254,ATCC #11561
N/A Bacillus megaterium, BM 458
N/A Bacillus subtilis, CH201
N/A Beef fat
N/A Beet powder
N/A Bran
N/A Bread crumbs
N/A Calcareous shale
N/A Canary seed
N/A Cardboard
N/A Cat food
N/A Cheese
N/A Cinnamon
N/A Citrus pectin
N/A Clam shells
N/A Cloves
N/A Cocoa shell flour
N/A Cocoa shells
N/A Cookies
N/A Cornstarch
Page 91 of 93
N/A Cotton
N/A Diethanolamide of methyl laurate
N/A Dog or cat collar
N/A Douglas fir bark
N/A Egg Shells
Fatty acids, sunflower-oil, conjugated, polymers with maleic anhydride, and
N/A tall-oil fatty acids
N/A Feldspathoid (alkali aluminosilicate mimeral)
N/A Flavoring
Fumaric acid-isophthalic acid-styrene-ethylene/propylene glycol copolymer
N/A (minimum average mole
N/A Granite
Imidazolium compds, 2-heptadecyl-4,5-dihydro-1-methyl-1-(2-tallow
N/A amidoethyl), Me sulfates
N/A Iron humate
N/A Malt flavor
N/A Meat meal
N/A Meat scraps
N/A Medicated feed
N/A Millet seed
N/A Mineral wool (tile)
N/A Mixed Phytosterols (consisting of campesterol, sitosterol)
N/A N-(Soya alkyl)-N-methylmorpholinium sulfate
N/A N,N'-1,3-xylyl bis(12-hydroxystearamide)
N/A N,N-Dimethyl oleyl-linoleylamine salt of benzoic acid
N/A Naphthalenesulfonic acid, isopropylisohexyl-, sodium salt
N/A Nutria meat
N/A Nylon
N/A Oyster shells
N/A Paper
N/A Paprika
N/A Paraffin wax
N/A Peanut butter
N/A Peanut shells
N/A Peat moss
N/A Propylene glycol isobutyl ether and higher homologs
N/A Pumice
Red cabbage color, expressed from edible red cabbage heads via a pressing
N/A process using only acidified water
N/A Red cedar chips
N/A Rubber
N/A Sawdust
N/A Seaweed, edible
N/A Soy protein
N/A Soybean hulls
Page 92 of 93
N/A Sulfur coated urea
N/A Walnut flour
N/A Walnut shells
N/A Wheat
N/A Wool
Page 93 of 93
Inert (other) Ingredients in Pesticide Products
Pesticide products contain both "active" and "inert" ingredients. The terms "active ingredient"
and "inert ingredient" have been defined by Federal law, the Federal Insecticide, Fungicide,
and Rodenticide Act (FIFRA), since 1947.
An active ingredient is one that prevents, destroys, repels or mitigates a pest, or is a

plant regulator, defoliant, desiccant or nitrogen stabilizer. By law, the active
ingredient must be identified by name on the label together with its percentage by
weight.
An inert ingredient means any substance (or group of structurally similar substances if
designated by the Agency), other than an active ingredient, which is intentionally
included in a pesticide product. Inert ingredients play a key role in the effectiveness
of a pesticidal product. For example, inert ingredients may serve as a solvent,
allowing the pesticide's active ingredient to penetrate a plant's outer surface. In
some instances, inert ingredients are added to extend the pesticide product's shelf-
life or to protect the pesticide from degradation due to exposure to sunlight.
Pesticide products can contain more than one inert ingredient, but federal law does
not require that these ingredients be identified by name or percentage on the label.
Only the total percentage of inert ingredients is required to be on the pesticide
product label.
Name Change: From Inert to Other Ingredients
In September 1997, the Environmental Protection Agency (EPA) issued Pesticide Regulation
Notice 97-6 which encourages manufacturers, formulators, producers, and registrants of
pesticide products to voluntarily substitute the term "other ingredients" as a heading for the
"inert" ingredients in the ingredient statement on the label of the pesticide product. EPA made
this change after learning the results of a consumer survey on the use of household pesticides.
Many comments from the public and the consumer interviews prompted EPA to discontinue
the use of the term "inert." Many consumers are mislead by the term "inert ingredient",
believing it to mean "harmless." Since neither federal law nor the regulations define the term
"inert" on the basis of toxicity, hazard or risk to humans, non-target species, or the
environment, it should not be assumed that all inert ingredients are non-toxic.
Last updated on Thursday, August 28th, 2008.

http://www.epa.gov/opprd001/inerts/

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Fluoride: The Ultimate Cluster-Flux

And the Players Involved

A Compilation of Documents and Articles

If you are sickened and appalled by the approved use of fluoride in

I would like to thank (or curse) Christopher Bryson whose excellent

For more information on fluoride, I would recommend the Fluoride Action

How much phosphogypsum is being produced?

Why is so much phosphogypsum produced?

Phosphate rock, which is processed to make phosphoric acid, contains concentrations of

Processing Phosphate Rock

Where does the phosphate rock come from?

How many facilities are producing phosphoric acid and

How much radioactivity is in the phosphogypsum?

The concentrations of uranium and radium-226 in phosphogypsum samples taken in central

The radium-226 concentration in phosphogypsum varies significantly at different sampling

How are people exposed to the radiation from phosphogypsum

Other Phosphogypsum Constituents of Concern

In addition to the radiation health hazards covered by Subpart R, phosphogypsum contains

The major use is as a fluoridation agent for drinking

• Some common synonymns:

• "Sodium fluosilicate (sodium silico fluoride) has been used to control

• The major use of sodium hexafluorosilicate and fluorosilicic acid is as

NOTE FROM FAN:

This chemical is unique in that it has received some public

Oborova norma ON 653130, Ministry of Industry, Prague,

Commercial Sodium Silicofluoride

Sodium-silicofluoride (Na2SiF6), used mainly in the glass industry, in

Anemia (click on for all fluorinated pesticides)

Apoptosis (click on for all fluorinated pesticides)

Ataxia (click on for all fluorinated pesticides)

Bladder (click on for all fluorinated pesticides)

Blood (click on for all fluorinated pesticides)

Body Weight Decrease (click on for all fluorinated pesticides)

Bone (click on for all fluorinated pesticides)

Dermal (click on for all fluorinated pesticides)

Heart (click on for all fluorinated pesticides)

Kidney (click on for all fluorinated pesticides)

Liver (click on for all fluorinated pesticides)

Lung (click on for all fluorinated pesticides)

Spleen (click on for all fluorinated pesticides)

American Journal of Public Health

MAZYCK P. RAVENEL, M.D., Editor AUGUSTA JAY, Editorial Associate

THE NEW FEDERAL LAWS RELATING TO FOODS,

be appealed to a federal circuit court of appeals, and finally to the Supreme

THE AIRPLANE AND YELLOW FEVER

In 1943, the aluminum industry was the largest single electricity

Alcoa subsidiary receives long term contract from Lockheed

City of Industry, CA - Defense industry news provided by Financial News...

EPA Cites Alcoa Subsidiary for Hazardous Waste Violations

"The shipment of hazardous wastes requires proper management to ensure protections,"

PROBLEM/OPPORTUNITY program, including the PEIS, supporting technical

Typical depleted UF6 storage cylinder (Cylinders are constructed of

The Portsmouth remediation contractor is LATA-Parallax Portsmouth LLC. LATA-Parallax

1. Isn't bottled water safer than tap water?

2. Is bottled water actually unsafe?

3. Could the plastic in water bottles pose a health risk?

4. How can I find out where my bottled water comes from?

5. How can I determine if bottled water is really just tap water?

• require bottlers to display information on their labels about the levels of

7. How does drinking bottled water affect the environment?

9. How can I obtain test results on my tap water?

Summary Findings of NRDC's 1999 Bottled Water Report

Bottled No No 1/week No No 1/year

last revised 4.29.99