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ENVIRONMENT-RELATED
NON-HAZARDOUS WASTE/"TCLP-SAFE"
(Toxic Characteristics Leaching Procedure)
PennzSuppress® D passes the Toxicity
Characteristics Leaching Procedure (TCLP) test, which is EPA’s method for
determining if a waste is hazardous based on the characteristic of toxicity.
The phrase "TCLP-safe" is sometimes used in the industry to refer to
the absence of regulated chemicals in a waste material, when tested according
to the TCLP method.
PennzSuppress® D was tested
in its concentrated form, and does not contain any TCLP regulated chemicals,
therefore it is not subject to this test procedure at the time of disposal,
and need not be handled as a hazardous waste. Furthermore, PennzSuppress®
D does not meet any of the other EPA criteria for classification as
"hazardous."
DOES NOT INHIBIT PLANT GROWTH
When a substance is applied to roadways, there are often concerns about
harming plants that grow in the area. To evaluate the effect on plant growth
in soil exposed to PennzSuppress® D, an
acute toxicity test for root elongation was performed on lettuce seeds (Lactuca
sativa). This EPA test method is used to screen soil at hazardous waste sites
to determine if plant life is being adversely affected by materials dumped in
the area. An 80/20 dilution of water/PennzSuppress®
D, which is the concentration of product most commonly applied, was used
in water to determine the "EC50." EC50 , which
stands for effective concentration 50%, represents the inhibit root elongation
in 50% of the test seeds. Again, the higher the EC50, the lower the
toxicity of the product.
The EC50 for the diluted PennzSuppress®
D was determined to be 128,000 mg/kg. Based on the EPA’s assessment of a
“low concern” for EC50 values >mg/kg, PennzSuppress®
D is not considered harmful to plant growth. PennzSuppress®
D can be used to effectively control dust on roads near vegetation, without
leaching of damaging chemicals into surrounding soil. Also, by holding fine
dirt particles on seeded banks, PennzSuppress®
D can actually promote seed germination.
EXHIBITS LOW TOXICITY TOWARD FISH
When areas near waterways are treated for dust control and silt run-off,
there is a concern that the material applied may be washed into waterways by
rain that follows application. Pollution of water, and its effects on aquatic
life, are of increasing concern to the public and to regulatory agencies.
Chronic aquatic toxicity tests were conducted to assess the lethal affect on
fish in streams, lakes or rivers, into which storm water runoff from roads
treated with PennzSuppress® D may flow.
These tests were run under static conditions on both fathead minnow larvae (Pemephales
promelas) and rainbow trout (Oncorhynchus mykiss). The endpoints studied
included hatchability, survival, growth and reproduction. An 80/20 dilution of
water/PennzSuppress® D was used for the
tests, which is the concentration of the product most commonly applied. The
actual amount of PennzSuppress® D, which
would be washed off a road and into waterways by rain immediately following
application, would be far less concentrated than the test dilution. Once
PennzSuppress® D has had adequate time to
firmly set-up, it is resistant to deterioration, and does not re-emulsify in
rain.
The chronic values for the 96 hour test of the diluted PennzSuppress®
D were 130 mg/l for fathead minnow and 194 mg/l for rainbow trout. EPA assigns
a rating of “low concern for ChV’s >10 mg/l. From the results of these
chronic tests, acute aquatic toxicity LC50 values were also calculated and
found to be 510 mg/l for fathead minnow and 913 for rainbow trout. EPA rates
LC50 values of >100 mg/l as a “low concern.” A U.S. Fish and
Wildlife Research Information Bulletin #84-78 classifies LC50
values of 100-1000 mg/l as “practically non-toxic.” Based on these
results, PennzSuppress® D
exhibits a low level of toxicity toward the fish tested.
The word "hazardous" is a broad term which can be applied to
many different properties of a product or its handling, and may be regulated
by many different agencies. Materials can present “hazards” due to
concerns over health, fire, environment, disposal, shipping, packaging, and
numerous others. In support of the claims made above, the following are
details, interpretation and discussion about the health, safety and
environmental testing performed on PennzSuppress®
D.
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