In other words, we have a nuisance problem here an esthetic problem-with a high visibility factor that is creating a public reaction against our products. Thus, our first job has been to find product improvements that will get us out and away from the overall water pollution complex.

Our commitments toward this goal do not grow out of any cummulative evidence of damaging effects, but out of a consciousness that this industry should seek to solve that part of the problem that is, in fact, due to detergents. So let us move on to the second question of what we are doing about it-and the adequacy of this changeover, in the absence of a regulatory law to assure compliance.

I have already mentioned the target date for having biodegradable products ready. We understand that the Assistant Secretary of Health, Education, and Welfare, upon inquiry, has received many individual assurances backing up this date, and the Department has taken a position for a period of grace to test the sincerity of our intent. (13) It would appear from statements by proponents of this legislation (16) that it is not the target date itself, as much as the possibility that it may be unrealized or disregarded, that worries them. It was suggested at the House subcommittee hearings that the "bad guys" or the producers of shoddy goods, might find it to their economic advantages to persist in the use of the nuisance-causing type of ABS, even after new, more biodegradable types were available.

This line of reasoning, I suggest, stems from a lack of familiarity with the basic procedures necessary to produce mass quantities of the surface active agent. In a statement which Mr. Moss has submitted for the record (14) the facts are spelled out in more detail. Specifically, there are in the United States a relatively few-five or sixproducers of the basic materials for current tetrapropylene type of ABS-the ingredient whose use is here in question. Without the mass household markets offered through sales to a similarly small number of large finished product producers, this type of material will be technically obsolescent. As such, it will be no bargain for anybody.

The possible importation of the current material seems equally unrealistic, since a tariff of 25 percent ad valorem, plus 3.5 cents per pound, on top of transportation costs, is far more than any differential between the older and the improved product which is likely to exist, even temporarily.

We come then to the fact that the new materials of improved biodegradability will be used for economic reasons if no other-law or no law-within a reasonable time interval, once commercial quantities are available and freely offered for sale.

Furthermore, it is important to realize that any objectionable foaming or other detergent residue effects have largely grown out of high volume of total use. An individual holdover package, here and there, has in itself no potential nuisance value. We have been asked, from time to time, why the biodegradability problem was not anticipated when detergents were first developed. As you know, all detergent residues degrade to some extent. The fact is that detergents, in the early days when they were a small part of the soap business, were not a predictable nuisance, since tests did not identify them in sewage. It was mass use that led to recognizable effects such as foaming. Now mass use of a more degradable material will surely abate it.

The third point which has been posed to those of us who claim these bills are unnecessary concerns the adequacy of our new products to meet fair and reasonable standards of biodegradability. As students of water pollution generally, you will recognize that laboratory test methods foretelling what will happen in sewage treatment, or in streams or ground water are not simple. For some 10 years, our association has been working on test methods-both to measure ABS in laboratories and streams and other surfactants in water, and to determine the relative rate of breakdown of various experiemental composition. In this work, our research men have been in contact with, and we hope in agreement with, research men in the Division. of Water Supply and Pollution Control of the U.S. Public Health Service. (15) Mr. Leon W. Weinberger, Chief, Basic and Applied Sciences Branch, Division of Water Supply and Pollution Control, has been nominated and will serve as an exofficio member of the industry's biodegradation test subcommittee.

As a matter of fact, this operation is already in the works and a special meeting has been called for July.

He will have full opportunity to evaluate and to contribute to its work. True, the Germans have announced an official standard for biodegradability. I am told that products proposed for use in the United States will more than meet this standard when the German test method is used. However, as discussed in the statement submitted by Dr. Warren Jensen (16) U.S. conditions are more thoroughly reflected in improved test methods under development here and with which this cooperation with HEW has been made.

I come now to the final question, one which merits a frank and serious reply. Why do we advise against this legislation, against certain detergents, if it is made effective at a future date in line with our voluntary action for a changeover?

First, we do so because any effort to impose at some future date a specific legal standard of biodegradability seems likely to slow down improvement until the standard is fully defined. The main objective then would be simply to comply, rather than to apply flexibility and creativeness to ending the problems as they actually exist in water sources. This is why we say legislation may actually delay, rather than to advance, scheduled action.

Second, we oppose this legislation because, as citizens and taxpayers, we are concerned about the diversion of competent water pollution specialists, and biologists or other trained men, into a highly complex area of enforcement. There is so much needed work to be done on water pollution generally. Yet, here would be a legal requirement that every product of every producer or converter, national or local, be subjected to a complicated test routine. We doubt that the agency involved looks favorably on this prospect.

Frankly, we believe those who know the complexities of the problem will recognize that we began taking a technically preventive course as quickly and as intensively as any good citizen would have done certainly with far greater intensity than many other steps needed to abate gross pollution. For us to be singled out as a "villain" at this particular time seems unjustified. The timing of the correction of many pollution problems must be evaluated against the risks of makeshift solutions.

We heard a little bit about that this morning when we were talking about 1967, I believe, for the correction of some of these Mississippi problems.

In the overall battle against water pollution, our 2-year target date is on the nearby side.

In conclusion, some of you may still question this claimed intensity of effort. Setting a target date over 2 years away, I have been told, suggests lagging interest and a desire to stall. We have no apologies to make for this time schedule, but I think that a factual explanation is due those of you not familiar with production procedures in this field in which billions of pounds of materials are involved. For this reason, I should like to introduce to you at this time Mr. John P. Moser, vice president of Lever Brothers Co. Mr. Moser will explain, on the basis of actual industrial experience in this field extending over 37 years, why we have been realistic, rather than wishfully optimistic, in citing a date by which our individual members-working on their own and voluntarily can comply with the objectives of these bills and make them unnecessary.

(The attachments and references to Mr. Pattison's statement follow :)

APPENDIX 1

THE BOARD OF DIRECTORS

THE SOAP & DETERGENT ASSOCIATION

Howard M. Abbott, vice president, Harchem Division, Wallace & Tiernan, Inc. J. A. Barnett, vice president, Purex Corp., Ltd.

Edward J. Bock, vice president, Monsanto Chemical Co.

W. Rowell Chase, executive vice president, the Procter & Gamble Co.

A. K. Forthmann, president, the Los Angeles Soap Co.

J. B. Henderson, marketing manager, Shell Chemical Co.

G. M. Keller, vice president and general manager, Armour & Co.

G. H. Lesch, president, Colgate-Palmolive Co.

F. G. Meeker, president, the Andrew Jergens Co.

D. C. Melnicoff, president, Fels & Co.

M. C. Mumford, president, Lever Brothers Co.

G. H. Packwood, Jr., president, G. H. Packwood Manufacturing Co.

A. W. Schubert, president, Emery Industries, Inc.

Harry Theobald, president, the Theobald Industries.

T. M. Welton, president, Oronite Division, California Chemical Co.

APPENDIX 2

T. & M. DIVISION MEMBERSHIP-THE SOAP & DETERGENT ASSOCIATION

Armour & Co., 1355 West 31st Street, Chicago, Ill.

Atlantic Refining Co., 260 South Broad Street, Philadelphia, Pa.

B. T. Babbitt, Inc., 20 Broadway, Albany, N.Y.

California Chemical Co., 200 Bush Street, San Francisco, Calif.
Colgate-Palmolive Co., 105 Hudson Street, Jersey City, N.J.
Continental Oil Co., Post Office Box 2197, Houston, Tex.

The Dow Chemical Co., Abbott Road Buildings, Midland, Mich.
Enjay Chemical Co., 60 West 49th Street, New York, N.Y.
Fels & Co., 73d and Woodland Avenue, Philadelphia, Pa.

FMC Corp., 633 Third Avenue, New York, N.Y.

General Aniline & Film Corp., 435 Hudson Street, New York, N.Y.
Petrochemical Department, Gulf Oil Corp., Pittsburgh, Pa.

Hooker Chemical Corp., Post Office Box 326, Jeffersonville, Ind.

Jefferson Chemical Co., Ltd., 7114 North Lamar Boulevard, Austin, Tex.
Lever Bros. Co., 390 Park Avenue, New York, N.Y.

Monsanto Chemical Co., 800 North Lindbergh Boulevard, St. Louis, Mo.
Olin Mathieson Chemical Corp., 460 Park Avenue, New York, N.Y.

Phillips Petroleum Co., Adams Building, Bartlesville, Okla.
Procter & Gamble Co., Post Office Box 599, Cincinnati, Ohio

Purex Corp., Inc., Lakewood, Calif.

Shell Chemical Co., 110 West 51st Street, New York, N.Y.

Ultra Chemical Works, Inc., Division of Witco Chemical Co., Inc., 2 Wood Street, Paterson, N.J.

Union Carbide Chemical Corp., 270 Park Avenue, New York, N.Y.

Victor Chemical Division, Stauffer Chemical Co., 100 South Wacker Drive, Chicago, Ill.

Wyandotte Chemical Corp., Wyandotte, Mich.

REFERENCES

(1) "Organic Contaminants Affecting the Quality of Water," F. M. Middleton and A. A. Rosen, Public Health reports, 71, 1125-1133 (1956). (2) "A Lurking Danger-Environmental Sanitation-Problem of the Suburbs," Florida Health Notes, January 1963, 3–14.

(3) Perry F. Prather, M.D., commissioner, department of health, Maryland, memorandum to news and editorial writers, planning, zoning, and sanitary commissions, and other public officials.

(4) "Sterilization of Water," Abel Wolman, Journal AMA, 176, 167 (1960). (5) Statement by R. B. Wearn, Colgate-Palmolive Co., before Special Subcommittee on Air and Water Pollution of the Senate Public Works Committee, June 25, 1963.

(6) Proceedings, hearing on problems of the Nation's Water, Natural Resources, and Power Subcommittee, House Committee on Government Operations, Representative H. Reuss' statements, 12, 1524, June 10, 1963.

(7) Statement by F. J. Coughlin, Procter & Gamble Co., before Special Subcommittee on Air and Water Pollution of the Senate Public Works Committee, June 25, 1963.

(8) "Drinking Water Standards-1962," Public Health Service, U.S. Government, Department of Health, Education, and Welfare, 22-24.

(9) Statement by C. G. Bueltman, the Soap & Detergent Association, before Special Subcommittee on Air and Water Pollution of the Senate Public Works Committee, June 25, 1963.

(10) "Synthetic Detergents as a Criterion of Wisconsin Ground Water Pollution," M. S. Nichols and E. Koepp, Journal AWWA, 53, 303-306, 1961. (11) "Taste and Odor of ABS in Water," Jesse M. Cohen, Journal AWWA, 587-591, May 1963.

(12) "Effectiveness of Water Utility Quality Control Practices," Floyd B. Taylor, Journal AWWA, 1257–1264, October 1962.

(13) Anthony J. Celebrezze, Secretary of Health, Education, and Welfare, letter of May 21, 1963, to Charles A. Buckley, chairman, Committee on Public Works, House of Representatives. (14) Statement by H. V. Moss, Monsanto Chemical Co., before Special Subcommittee on Air and Water Pollution of the Senate Public Works Committee, June 25, 1963.

(15) Proceedings, hearing on Problems of Nation's Water, Natural Resources and Power Committee on Government Operations, statement by Dr. Leon W. Weinberger, Chief, Basic and Applied Sciences Branch, Division of Water Supply and Pollution Control, USPHS, June 10, 1963.

(16) Statement by W. L. Jensen, Continental Oil Co., before Special Subcommittee on Air and Water Pollution of the Senate Public Works Committee, June 25, 1963.

Senator MUSKIE. Mr. Moser, you may proceed, and we will limit our questions during this statement to such as may be needed to clarify the point for our better understanding.

Senator MILLER. Mr. Chairman, before we go to the next speaker, the first witness did refer to this very excellent paper by Dr. Wise of the Library of Congress, Legislative Reference Service.

I believe he actually quoted from one of the conclusions of Dr. Wise. I found this to be quite an interesting paper, and it is not particularly long.

I would like to suggest that it might be included in the record. I think it would serve as a useful supplement to the witness' speech. It is comparatively recent.

Senator MUSKIE. Without objection, it will be included in the record at this point.

(The statement referred to follows:)

DETERGENTS-A SOURCE OF POLLUTION AND WHAT IS BEING DONE

(By Edward Wise, senior specialist in science and technology, Legislative Reference Service, the Library of Congress)

(The author wishes to acknowledge the assistance of Drs. J. Burlin Johnson and Quentin Hartwig, of the Library's Science and Technology Division, for suggestions and review of certain phases of the literature, and John Feulner, also of the Science and Technology Division, for certain translations.)

INTRODUCTION

In the spring of this year, 2-year-old Gerald Colpas toddled into the kitchen of his new Lindenhurst, Long Island, home and asked for a drink of water. His mother drew it from a 2-gallon camping jug that had been filled in another community. Beside the jug a covered fish tank held the reserve supply. Gerald's thirst quenched, Mrs. Colpas started filling a cooking pot from the tap in the sink. Thick suds foamed up over the edges before it was half full. The clean, crisplooking suds were caused by synthetic detergents that had contaminated the ground water table after having seeped from cesspools and septic tanks in the neighborhood.

In the history of soap products over the past 100 years, there has been a tradition of constant improvement-from bulk soap to soap bars, from bars to chips and flakes, to powdered and liquid forms, suited to specific cleaning tasks. Before World War II, a major breakthrough was achieved with the development of new surface-active ingredients which made it possible for cleaning products to maintain their efficiency in hard water-something that "soap" in its chemical sense cannot do. Thus was born the synthetic detergent, which was able to overcome an obstacle present to some degree in virtually all water supplies-the hard water salts-and to provide the homemaker with unexcelled cleaning performance in spite of the hardness of her water supply.

Because of their improved cleaning efficiency, the synthetic detergent's achieved rapid public acceptance and today constitute about 75 percent of the volume of the entire soap and detergent industry in the United States. If industrial products are eliminated and only household products are considered, synthetic detergents would constitute about 90 percent of the annual volume. The synthetic detergent volume amounts to about 3.5 billion pounds of ingredients, of which some 9 million pounds consist of the organic surface-active ingredient (surfactants), responsible for removing grease and soil. About 800 million pounds of this volume represents surfactant consumption in household products.

As in all product improvement, certain difficulties may come hand in hand with the gains. Such is the case with synthetic detergents or "syndets," as they are commonly called. Syndets do not respond to today's conventional wastetreatment processes or even to the more refined treatment given to public water supplies, and herein lies the problem.

It should be pointed out that while this paper is devoted exclusively to the detergent pollution problem, this is only one of the factors contributing to water pollution. Many other things contribute to the pollution of our water and disposal systems these days. Ultimately these must be taken into consideration and acceptable means found to cope with the total pollution problem.