| Abstract: | There is growing awareness and concern regarding the presence of chemical constituents of pharmaceuticals and personal care products (“PPCPs”) in the environment. A recent USGS study indicated that PPCPs are present at low levels in surface water throughout the U.S. Concern is based in part on the fact that certain PPCPs: (1) are designed to have biological effects (particularly pharmaceuticals), (2) are persistent in or continually added to the environment, (3) have negative environmental effects (specifically on aquatic life) even at low levels, and (4) potentially have cumulative and synergistic effects when combined with other PPCPs. The primary route of PPCPs into the environment is sewage discharges, septic systems, and large stock yards and feedlots where the unmetabolized PPCPs are excreted by humans and animals and end up in surface water and ground-water. Given these circumstances, manufacturers of PPCPs may face a risk of increased regulation and possibly litigation similar to that faced by oxygenate manufacturers and petroleum refiners over the use of Methyl Tertiary Butyl Ether (“MTBE”). Companies can take steps now and in the future that may minimize the impact of these risks. |
