What is the definition of phosphate free cleaners and detergents for purposes of the VGP?
Phosphate free soaps, cleaners, and detergents, are defined in Part 7 of the Permit. Phosphate free is defined as materials which contain, by weight, 0.5% or less of phosphates or derivatives of phosphates. Discussion “Phosphate free” refers to any cleaning product that is not formulated with phosphorous containing compounds, which would readily be converted to phosphate in the aquatic environment, as an intentional part of the product formulation. EPA considers “readily be converted to phosphate” to be products that break down through simple hydrolysis or oxidation reactions. EPA considers the term “phosphate” to encompass phosphoric acid, phosphonates, organophosphates, any salt of a hydrogen phosphate, and any salt of phosphate. “Derivatives of phosphate” include polyphosphates, such as sodium tripolyphosphate (Na5P3O10),pyrophosphate and phosphorus oxoacids. For purposes of this permit, cleaning products that contain such phosphorous containing compounds as an unintentional consequ
