A more comprehensive presentation of factors concerning alkyl benzene sulfonate and water is contained in the association's brochure "Synthetic Detergents in Perspective" which has been submitted to the committee for your records.

In summary, alkyl benzene sulfonate certainly has had no detrimental effect on water and waste treatment plant performance, or in the quality of their products. Alkyl benzene sulfonate in fact has been looked to as a useful tool for improving the quality of sewage treatment plant effluents. Certainly the levels of alkyl benzene sulfonate present in the potable waters of this country are well below the recommended maximum of 0.5 milligram per liter alkyl benzene sulfonate. This does not deny the fact that in a few special situations there are isolated instances of problems with alkyl benzene sulfonate. But closer examination has invariably revealed that these special situations were highly undesirable for reasons other than the presence of alkyl benzene sulfonate alone. The industry has voluntarily assumed the responsibility of removing the residues of their products even from these isolated situations.

BIBLIOGRAPHY

(1) "The Soap and Detergent Association; Organization, Service's Memberbership."

(2) "Detergents, Pollution, Biodegradability," Chemical & Engineering News March 18, 1963.

(3) "Public Health Service, Drinking Water Standards, 1962," U.S. Department of Health, Education, and Welfare Public Health Service. (4) "Taste and Odor of ABS in Water," by Jesse M. Cohen; Journal, AWWA, May 1963.

(5) "Detergents-Effects, Control, and Removal," F. M. Middleton, North Annual Wastes Engineering Conference, University of Minnesota, December 7-8, 1962.

(6) "River Suds Here Before Detergents," the Crete News, February 14, 1963. (7) "U.S. Census of Housing, 1960 State and Small Areas," U.S. Department of Commerce, Bureau of the Census, 1962.

(8) "Degradation of ABS in Unsaturated Soils," by Jesse M. Cohen, Robert A Taft Sanitary Engineering Center, December 1962.

(9) "The Effect of Detergents on the Water Resources of New York State" interim report of Temporary State Commission on Water Resources Planning, May 1963.

(10) Private communication.

(11) "Removal of ABS by Sewage Treatment," P. H. McGauhey, Sewage and Industrial Wastes, August 1959.

(12) "Study of Alkyl Benzene Sulfonate in Drinking Water," AASGP Committee Report, Journal, AWWA, 1961.

(13) "This is Ideal Water," Elwood L. Bean, Water Works Engineering, October 1962.

(14) "Effectiveness of Water Utility Quality Control Practices," by F. B. Taylor, Journal, AWWA, October 1962.

(15) "Market Newsletter," Chemical Week, May 18, 1963.

(16) "Monitoring the Ohio River for Synthetic Detergent Content," by P. J. Weaver and F. J. Coughlin, Journal, AWWA, 52, 607–612 (1900).

STATEMENT OF FRANK J. COUGHLIN

Associate Director of the Product Development Division, the Procter & Gamble Co., and past chairman of the Technical Advisory Council and Research Steering Committee, Soap and Detergent Association

Mr. Chairman and members of the committee, my name is Frank J. Coughlin. I am associate director of products development for the soap products division of Procter & Gamble. I was chairman of the Soap and Detergent Association's Research Steering Committee in 1956-57. This committee, one which is still active, has long been seeking answers to questions about the possible effects of synthetic detergents in waste waters and water supplies. Also I am currently chairman of the detergent subcommittee of the Chemical Industry Committee, advisory to the Ohio River Valley Water Sanitation Commission. I am a member of the American Public Health Association, the American Water Works Association, and the Water Pollution Control Federation.

My work as associate director of products development is concerned, broadly, with the environmental-health aspects of the products of our company's scap division. Specifically, for about 10 years, activities related to water pollution control and abatement, aside from industrial waste problems, have been one of my responsibilities.

I graduated from MIT as a chemical engineer in 1925, and have been with Procter & Gamble since that time, almost exclusively in product development work. My work has involved management responsibilities: First, for determining that new products coming on the market are thoroughly tested and carefully evaluated and meet the highest requirements of safety, and second, for reviewing from time to time, in the light of advancing knowledge and techniques, the findings that our established products are safe.

This statement discusses possible effect on the health of man from consumption of trace amounts of alkyl benezene sulfonate in drinking water supplies. This substance and I shall henceforth refer to it as ABS is the principal material of household synthetic detergents found in water supplies, and it is present in only very small traces.

I have only two points to make in this discussion:

First, that the preponderance of extensive scientific evidence from some of the Nation's most respected sources of such evidence clearly and incontrovertibly proves that the present levels of ABS in drinking water supplies are not harmful to humans and cannot, in any sense, be categorized as a public health hazard.

Second, that numerous research studies, each conducted with techniques that are approved and recommended by the main body of science, also fully support the conclusion that there is no long-term health hazard—no so-called cumulative ill effect from long-continued ingestion of the minute trace amounts of ABS normally found in the Nation's drinking water supplies.

Parenthetically, I should point out that these conclusions also apply to do mestic and wild animals. Statements have been made elsewhere of the similar lack of harmful effects on aquatic life.

As household synthetic detergents have come into widespread use, their possible effects on the health of man have been considered, evaluated, and kept under constant review by individual companies, by the Soap and Detergent Association, and by appropriate governmental agencies. Among official bodies, the U.S. Public Health Service has been particularly active in intensive study of the question of the physiological effects of water quality, including the biological effects of detergents.

In considering the possible health problems that might be related to detergents, individual companies and this association have consulted many outstanding scientists-doctors, toxicologists, pahtologists, and biochemists, for example. The companies and the association have been guided by the opinions of these independent and unbiased scientists.

Similarly, following normal practices of any responsible company making a product that poses any potential effect on health, the various detergent manufacturers have regularly conducted their own safety evaluations. Many of these studies have been published in scientific periodicals; other unpublished studies and data have been made available to and exposed to the scientific validation of interested scientists representing academic institutions and official bodies.

The association's booklet, "Synthetic Detergents in Perspective" has already been introduced as an exhibit. I would like to call to the particular attention of this committee two parts of this publication: Setcion 3, pages 14–17, entitled "Safety of Water Containing Detergent Residues," and the appendix of pages 37-39 which consists of an authorized reprint of an article entitled “ABS and the Safety of Water Supplies" from the official Journal of the American Water Works Association.

These references detail some of the voluminous scientific inquiry that ABS has undergone in recent years. The techniques used in making these studies are the well established methods used to evaluate the safety of food additives. The methods are recommended by such groups as the Food and Drug Adminis tration and the World Health Organization.

Similar listings of research studies may be found in the "Literature Citations" of the U.S. Public Health Service Drinking Water Standard of 1962 (p. 25).

Recurring in all the many studies is the basic conclusion that there is no scientifically valid evidence which suggests that ABS poses a public health problem.

It was in this broad framework of research evidence that the Public Health Service undertook a revision of its Drinking Water Standard. To study the toxicological aspects of substances found in water including the question of detergents, the Public Health Service established a task force on toxicology composed of six scientists of outstanding repute from academic and governmental circles. (These men are identified on p. 61 of the Standard.) Their recommendations were presented to the advisory committee which had been appointed by the Surgeon General to revise the Standard.

This advisory committee saw to it that the proposed standards were discussed widely before a final report was submitted. Further, the proposed standards appeared in the Federal Register before they were made effective so that any interested person could comment. In brief, the revised Standard, including the detergent limit specified in it, had wise consideration and wide scrutiny. What does the Drinking Water Standard say about ABS?

First, it sets a recommended limit for ABS in water supplies at 0.5 part per million. But the principal reason for setting this limit may properly be described as for esthetic rather than health reasons. The Public Health Service specifically pointed out that there is a clear differenec between toxic materials and "*** substances such as chlorides and detergents that are not directly injurious to health but might be objectionable and cause people to use other sources of supply that may not be properly protected."

Incidentally, the Standard also points out that "concentrations of ABS above 0.5 milligram per liter (part per million) are also indicative of questionably undesirable levels of other sewage pollution."

From the safety viewpoint, the Standard notes that the 0.5 part per million ABS limit has a factor of safety of the order of 15,000. This is a confirmation of the exhaustive research which has shown that ABS levels in normal drinking water supplies could be hundreds of times higher than they are without being harmful.

Before leaving the area of conclusions reached by official bodies, I will mention the findings of the British Government Committee on Synthetic Detergents. This group was appointed to study, among other matters, the question of detergents' effects on the safety of water supplies. This matter has been reviewed constantly since that time by the British Standing Committee on Synthetic Detergents and there has been no change in the 1956 conclusion.

I would like at this stage to describe in moderate detail one of the many research studies on the effects of ingestion of ABS. Not only will this show the experimental techniques used in such studies, but it also is germane to the question of the possible effects of the long-continued ingestion of trace amounts of ABS.

This study involved two separate 2-year tests of feeding rats on ABS. It is important to note that 2 years is almost the full life span of the rat.

In these tests, groups of 80 rats were fed at levels of 1,000 to 5,000 parts per million of ABS. Observations were made on such factors as growth, food consumption, blood chemistry, urine analysis, etc. The experiment was planned so there would be enough rats to allow some to be sacrificed and autopsied at intervals. Gross studies and microscopic studies were made on various organs after autopsy. Rats from each of the groups were bred in order to study the effects through two succeeding generations. The criteria evaluated were fertility, lactation, litter size, survival and growth of offspring, plus biochemical and pathological data on the individual organs of the sacrificed animals of the two succeeding generations. Throughout these studies, comparisons were made with a group of rats on a diet which contained no ABS.

Now this study-as did many others on rats, mice, guinea pigs, dogs, chickens and turkeys showed no objectionable effects from long-continued ingestion of ABS, even in a range of concentrations vastly higher than those found in drinking water supplies.

And it as were the many others-was carried out in the established and approved manner of assaying the toxicity of the substance to humans. The same basic research technics have been used time and time again on many substances to evaluate the countless discoveries that have eased human pain and improved the health and welfare of mankind,

I am, of course, aware of the argument that a given substance has not been proved safe until it is tested on succeeding generations of man himself—that long-range effects on man are not known because no man has been tested long range.

It seems to us that such arguments do not properly take into account the entire body of scientific procedures and knowledge. Had research studies in volving animals not been scientifically acceptable in the past as reasonably arcurate predictions of effects on humans, then many of us probably would not be around today to discuss this question of ABS, because we would not have had the protection and lifesaving benefits of countless medicinal miracles of this age.

Now, to summarize in two sentences:

Although this industry is voluntarily moving to a new form of surfactant which will be more degradable and will thus alleviate a nuisance situation. there is ample scientific evidence to show that the present form of ABS does not and has not constituted any kind of present or long-term health hazard. If there is any person or group having valid scientific proof to the contrary, this industry hopes he or they will bring it forth.

Mr. Chairman and members of the committee, thank you very much.

ADDITIONAL REFERENCES

1. Committee Report. ABS and the Safety of Water Supplies J. Am. Water Works Assoc. 52, 786-790 (1960)

2. Paynter and Weir. Chronic Toxicity of Santomerse No. 3 from Olefin (Dodecyl Benzene Sodium Sulfonate). Toxicol. & Apply. Pharmacol. 2 641648 (1960).

3. Snyder, Opdyke, Griffith, Rubenkoeniz, Tusing, and Paynter. Toxicologica Studies on Household Synthetic Detergents. I. Systemic Effects. Submitted for publication.

4. Saffiotti, Shubik, and Opdyke. Carcinogenesis Tests on Alkylbenzenes and Alkylbenzene Sulfonates. Toxicol. Appl. Pharmacol. 4, 763-769 (1962 5. Snyder, Opdyke, and Rubenkoenig. Toxicologic Studies on Brighteners Toxicol. & Appl. Pharmacol. 5, 176-183 (1963)

6. Tusing, Paynter, Opdyke, and Snyder. Toxicologic Studies on Sodium Laury Glyceryl Ether Sulfonate and Sodium Lauryl Trioxyethylene Sulfate. Toxicol. Appl. Pharmacol. 4, 402-409 (1962)

7. Dasher. Surface Activity of Naturally Occurring Emulsifiers. 660-663 (1952)

Science, 11,

8. Woodward, Stokinger, and Birmingham. Health Effects of Detergents in Weter. May 1963, for publication in the Archives of Environmental Health.

STATEMENT OF WARREN L. JENSEN

Assistant Manager, Research and Development Department Continental O Company; Member, Technical & Materials Division Research Committee: and Chairman, Biodegradation Test Methods Subcommittee of the Research Committee

DEVELOPMENT OF A BIODEGRADATION TEST METHOD

Honorable chairman and members of the committee, I am Dr. Warren L Jensen, assistant manager of the Research and Development Department, Cotinental Oil Co. My company is a member of the technical and materials division of the Soap and Detergent Association and I am a member of its research committee. Further, and more specifically to the subject at hand. I am chairman of the biodegradation test methods subcommittee of this re search committee. My doctor's degree in chemistry was obtained from Stanford University and my industrial research experience of 171⁄2 years has been eœrcerned with petroleum and petrochemical products and processes.

A fundamental requirement for the development of biodegradable detergents is a suitable laboratory test method for measuring the ease and extent to which bacteria can decompose the material in question. Numerous tests to determine the biodegradability of various organic materials have been in use. There are many variations in such tests, and, indeed, it appeared that almos every laboratory or bacteriologist had his own favorite procedure. In 1962. as evidence began to accumulate of probable future commericalization of such products in the United States, it followed that there was a need for a method which would be generally acceptable throughout the industry and available for its common use on appropriate occasions. A subcommittee, consequently. was established in the fall of that year and held its first meeting on January