April 8, 2011
Office of Pesticide Programs (OPP) Regulatory Public Docket (7502P)
Environmental Protection Agency
1200 Pennsylvania Ave., NW.
Washington, DC 20460-0001
Re: Petition for a Ban on Triclosan [EPA–HQ–OPP–2010–0548; FRL–8852–8]
To Whom It May Concern:
Environmental Working Group (EWG) is a non-profit public health and environmental research and advocacy organization based in Washington, DC. We work to combat the health risks from chemical contamination of food, water, consumer products and the environment. As a co-signer to the 2010 Citizen Petition for a Ban on Triclosan, EWG strongly supports a suspension of non-medical uses of triclosan while EPA reexamines the safety of currently registered uses. We are particularly concerned that EPA has not comprehensively assessed the safety of cumulative exposures of triclosan for the developing fetus, infant and child.
Triclosan has been used for 40 years as an antimicrobial ingredient in consumer and commercial products. Despite widespread concerns about the chemical’s toxicity—the fact that the chemical is detected in the majority of Americans, and its potential to harm aquatic life and form toxic byproducts in water or the environment—there are few restrictions on its use. The American Medical Association does not recommend use of antimicrobial products in the home (Tan 2002), stating: “No data support the efficacy or necessity of antimicrobial agents in such products, and a growing number of studies suggest increasing acquired bacterial resistance to them.” According to a Food and Drug Administration Nonprescription Drugs Advisory Committee, triclosan soaps are no better than plain soap and water for preventing the spread of infections or reducing bacteria on the skin (FDA 2005).
EWG research finds that:
- A wide range of home products contain triclosan and contribute to exposures. EWG research shows that with no assessment of health risks to infants, regulators have approved triclosan for use in 140 different types of consumer products including liquid hand soap, toothpaste, undergarments and children’s toys (EWG 2008). This exposure has been allowed despite the fact that the chemical ends up in mothers’ breast milk and poses potential toxicity to fetal and childhood development.
- Triclosan commonly contaminates the human body. EWG biomonitoring research has found triclosan in 42 of the 49 participants tested, including all 20 adolescent girls (EWG 2008).