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Action Requested by:
February 18, 2011

NACWA and Food & Water Watch¹  (FWW) are co-sponsoring a short, anonymous survey of wastewater utilities about triclosan, a popular antimicrobial pesticide used in consumer products including soaps, detergents, cleaning products, and toothpaste.  Triclosan may have adverse human health and environmental impacts, and it is often found in biosolids.  While triclosan does inhibit bacterial growth, studies indicate that it provides little or no practical benefit for household use.  For example, soaps containing triclosan have not been proven more effective in preventing illness than ordinary soaps. 

NACWA’s Board of Director’s approved NACWA’s co-sponsorship of this survey with FWW, and NACWA requests that member utilities complete the voluntary survey by Friday, February 18.  We ask that each utility only submit one response to the survey.  The survey consists of 16 yes/no type questions, with an opportunity to explain some answers and provide additional comments.  Members with questions about the survey should contact Cynthia Finley at 202/296-9836 or This e-mail address is being protected from spambots. You need JavaScript enabled to view it . 

Triclosan Survey Results To Be Used in Triclosan Advocacy

FWW plans to use the results of this survey to highlight the need for a precautionary approach to chemical regulation.  The survey results may reveal the burdens and issues that triclosan may create and whether preventing introduction of triclosan into the sewer system could relieve any burdens/issues.  FWW plans to use the results of this survey to highlight the need for a precautionary approach to chemical regulation, and will include the results in a report that it will use to advocate for a ban on the non-medical uses of triclosan.  FWW is planning a congressional briefing on triclosan in February, and introduction of a triclosan ban bill is expected later this year.  FWW is also petitioning EPA to reconsider the non-medical uses of triclosan and other methods of keeping it out of the environment (see below) – an effort NACWA can consider getting involved in depending on the results of the survey.

The survey results will also be useful in the Association’s advocacy work on emerging contaminants and in advancing the goals of the National Dialogue on Safe and Sustainable Consumer Products.  NACWA began this Dialogue with EPA, NACWA members, and other organizations, including FWW, to discuss additives to consumer products that may have adverse impacts on the aquatic environment and human health, and to develop solutions that will keep pollutants out of the sewer system rather than requiring wastewater treatment utilities to remove them.  Dialogue participants communicate by email, regular conference calls, and occasional meetings.  The next conference call is scheduled for Thursday, February 10, at 3:00 pm EST, and will focus on triclosan.  Please contact Cynthia Finley at 202/296-9836 or This e-mail address is being protected from spambots. You need JavaScript enabled to view it if you are interested in joining the call or the Dialogue group.

NACWA Drafting Comments on Petition Asking EPA to Ban Triclosan

FWW, Beyond Pesticides, and other groups have petitioned EPA and the Food and Drug Administration (FDA) for a ban on non-medical uses of triclosan.  EPA asked for public comments on this petition in a December 8 Federal Register notice .  NACWA and its Emerging Contaminants Workgroup are reviewing the petition and discussed it with Beyond Pesticides during a conference call on January 27.  NACWA will submit comments by the February 7 deadline.  The comments will likely support removing triclosan from non-medical products, but will disagree with other aspects of the petition, including requests that EPA address the environmental impacts of triclosan by developing effluent guidelines, pretreatment requirements, and biosolids regulations using its authority under the Clean Water Act.  While NACWA has a shared concern regarding the presence of triclosan in biosolids and in the nation’s waters, the Association has historically focused on addressing it at its source through more effective regulation under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), not the Clean Water Act. 

Again, please complete the triclosan survey by Friday, February 18.  Contact Cynthia Finley at 202/296-9836 or This e-mail address is being protected from spambots. You need JavaScript enabled to view it with any questions about the survey, NACWA’s comments on the triclosan petition, or the National Dialogue on Safe and Sustainable Consumer Products.

¹ FWW is a non-profit organization that advocates for policies that will result in access to healthy and safe food and drinking water.  FWW has participated in the NACWA-initiated National Dialogue on Safe and Sustainable Consumer Products, and has organized projects to educate consumers about avoiding products containing triclosan.