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University of Denver Water Law Review




In recent years, new information has arisen to challenge this assumption. Chemicals from a wide variety of pharmaceutical and personal care products ("PPCPs"), their byproducts and endocrine disrupting compounds ("EDCs") have received growing attention from the water treatment and wastewater treatment community because of the ability of PPCPs to persist, or only partially degrade, in water and during wastewater treatment.

Several federal agencies, including the EnvironmentAl Protection Agency ("EPA"), the Food and Drug Administration ("FDA"), the U.S. Department of Agriculture ("USDA"), the U.S. Geological Survey ("USGS"), and the Centers for Disease Control and Prevention ("CDC"), have the potential to be involved in various aspects of the management of PPCPs. In addition to these federal agencies, numerous units of state, tribal, and local governments are (or could be) involved in implementing federal, state, and tribal environmental programs that are relevant to the management of PPCPs. Industry stakeholders also play significant roles, both directly and indirectly, in PPCP management.

PPCPs are an extremely diverse group of chemicals used in human health care, cosmetic care, veterinary medicine, and agriculture. In 2004, it was estimated that "there may be as many as six million PPCP substances commercially available worldwide . . . ." PPCPs are also ubiquitous pollutants, entering the environment worldwide due to widely dispersed usage by individuals and in both industry and agriculture. Recent reports in popular media regarding pharmaceuticals in drinking water have contributed to increasing public awareness of and concern about this issue.

In 2006, the Center for Water Law & Policy at Texas Tech University (the "Center") was awarded funding by the Environmental Protection Agency to conduct a study related to micropollutants (including PPCPs) in the natural environment. This study was divided into three specific projects.

Project 1 focused on the development of a PPCP database containing documents, reports, publications, and other material related to PPCPs. While information in the database was designed for use in Project 3 (discussed below), the information was also intended to be made available to those interested in understanding water law and policy issues, including researchers, decision-makers in the public and private sectors, stakeholders, interest groups, and the general public. The creation of the Micropollutants Clearinghouse ("Clearinghouse") achieved this latter objective.

Project 2 focused on primary research to improve the understanding of the presence and fate of mixtures of micropollutants in the environment. This research, which was based on field studies conducted on discharges from a wastewater treatment facility in West Texas, forms the basis for the case study noted below

Project 3 focused on an analysis of alternative strategies for addressing the presence and effects of PPCPs in fresh water resources. It identified and evaluated statutory and regulatory approaches that are (or could be) utilized to prevent PPCPs from entering the aquatic environment in concentrations that would exceed concentrations determined appropriate for protection of human health and the environment. Potential alternative strategies were also identified and evaluated. Project 3 addressed three basic questions: 1) can existing statutory and regulatory authorities be utilized to collect information about and/or effectively manage PPCPs entering the environment?; 2) are there other alternative strategies that should be considered?; 3) what are the relative strengths and weaknesses of the existing authorities and alternative strategies? The results of Project 3, as well as answers to these three questions, are contained herein

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University of Denver College of Law


This article is a revision and update of a 2011 report produced through a USEPA grant awarded to the Texas Tech University Center for Water Law & Policy, available at

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