The Sodium Bromide Ban - Rudy talks with Scott Hamilton, CEO, United Chemical

This episode features Scott Hamilton, CEO of United Chemical, discussing the EPA's recent restrictions on sodium bromide, its implications for pool professionals, and the science behind bromate formation and safety. Gain insights into regulatory processes, chemical safety, and effective pool management strategies.

keywords

sodium bromide, EPA regulations, bromate, pool chemistry, pool safety, algae control, chemical risk assessment, United Chemical, Yellow Treat, bromine pools

key topics

• EPA's restrictions on sodium bromide
• Bromate formation and health risks
• Science and risk assessment of pool chemicals

guest name

Scott Hamilton

Sound Bites

• "Don't let your mentor go, that's mentoreward.com."
• "Bromamines are effective and don't have a nasty smell."
• "Pool pros should voice their concerns to regulators."

Chapters

00:00
Introduction to the EPA's Controversy on Sodium Bromide

03:52
The History and Impact of Bromate Regulations

06:53
Understanding Bromate Formation in Pools

09:30
The Chemistry of Bromine and Chlorine in Pools

12:18
The Misconceptions of Bromine Pools

15:16
Toxicology of Bromate and Cancer Risks

18:12
Bromate in Food Products and Regulatory Delays

22:25
Understanding EPA's Role and Challenges

25:10
The Impact of Lobbying on Chemical Regulations

29:45
Efficacy of Sodium Bromide in Algae Control

30:50
Trends in Mustard Algae Growth

34:22
Research Findings on Bromate Formation

42:48
Engaging with Regulatory Bodies

45:40
Legacy and Safety of Sodium Bromide

Resources

• United Chemical
• Yellow Treat
• EPA Regulations on Bromide Products (2005)
• Bromate Risk Assessment Study

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Transcript

SPEAKER_05 0:00

We used a chemical called cimizine for black algae. That went away in 1993. The EPA said no more for pool use. The consensus was they took it away because it worked. Do you think that applies? Welcome to Friday. I'm Rudy Stankwitz. This is the Talking Pools Podcast. Boy, do we have an episode for you. I know many of you, more than many of you, many hundreds, many thousands of you have been upset as of late because the EPA attempted to take away your favorite mustard algae treatment. That's a fact. If you look at the label of any sodium bromide product right now, the EPA has required that the tagline be added not for use in outdoor pools. Why is that? Bromate. It's a disinfection byproduct. They're afraid people are going to get cancer if you use this in a pool. But like I said in a few episodes ago, is the proof really there? They're looking at it as lack of evidence, is not evidence of non-existence, where we have United Chemical, probably the sodium bromide product you're most familiar with, out there busting their tails, putting together information, collecting data to present to the EPA to say, this just ain't so. So today I have with me Scott Hamilton, CEO of United Chemical. Scott, what's going on with this? I've been getting Service Industry News since I first stepped into this business, and every time it landed, I did the same thing. Flip straight to the horror file. The weird installs, the absurd finds, the stuff only pool pros ever see. Then I'd go back and read the articles. Service Industry News is a twice-monthly trade publication for pool and spa service text, 24 issues a year, emailed free to over 10,000 texts and available on their app. Every issue covers nationwide industry news and real technical content you actually will use. Get your free subscription at serviceindustry newscd.net. Today I have with me Scott Hamilton, CEO of United Chemical. Scott, what's going on with this?

SPEAKER_04 2:17

A lot and also not a lot. So as you pointed out, the the EPA in their interim decision removed the outdoor pool use of sodium bromide. There's a long history about that, about leading up to this, and also what we're doing to try to combat maybe some of the assumptions and misinformation out there. So back in 2001, Arch Chemical, uh a competitor of ours, they sent a letter to the EPA that they said is a required disclosure, saying that we have information that is pertinent because of regulations. So they in that said they conducted a study, and I'll say I have not read the study, it's just been submitted to the EPA back then, and I haven't been able to find a copy of it. But basically stating that they did a study with uh a sodium bromide product they didn't name. Interestingly enough, it was 88.8%. And if you're familiar with the sodium bromide allergics out there, that was the old formula for yellow treat. So they used yellow treat and did a 60 times dose roughly treatment. Uh and I'm and also with shocking 60 times, and said they reverse calculated up to 50% of bromine can convert to bromate. Back in 2001, the EPA kind of scoffed at that.

SPEAKER_05 3:40

You said 60 times roughly a 60 times dose. 60 times the normal dose of sodium bromide, then 60 times the normal dose of calhypo or liquid, whichever.

SPEAKER_04 3:52

Not sure what chlorine they use, but yeah, basically superchlorination. And they said with regression analysis, which is basically you kind of walk backwards based on calculations, said, well, up to 50% could be converted to bromate. And bromate is classified as a probable human carcinogen, I think is the latest. Um and that's based on studies going back to around that time, maybe a little bit before, on potassium bromate. Potassium bromate's something that was used worldwide as a leavening agent for and stuff. So it was a dietary thing. So in those studies, they fed large amounts of potassium bromate to mice and then studied the mice, and over time the mice developed renal tumors. So that made it a concern that okay, if it does it in mice, it could potentially do that in rats. And so that's when bromate first kind of itself became a concern. And then Arch Chemical in 2000, around 2001, it might have been 2005, did a letter to the EPA and said, Hey, we did this internal study and you should know about it using not our product, not their product, but and then sent that to the EPA. And it was, I think, 60 times dose. Wow. Okay. So they suck. So EPA then looked at that back then and uh said, Well, no one's using it that way, so let's not let's not look at those numbers. Let's instead, like the total amount of bromate, let's instead look at an assumption of 50% conversion. And so that's kind of where the 50% conversion that gets talked about started to come up. And it's based on the assumption, based on what Arch said. And there's some environmental data where it said it could up to back in like 1971, about a water estuary or something where it's like, oh, maybe we can see upwards potentially at 50%. So that's where that number comes from. It kind of goes, we don't quite take Arch at face value. Let's look at a 50% conversion based on current doses, and did a risk assessment based on that. And it kind of just went, yeah, we'll look at into it in the future. EPA is a big organization, they look at a lot of stuff. Fast forward to the interim decision. So they the EPA approached all the manufacturers, said, hey, we want data on this, despite being kind of well known in the industry. We're, you know, we're not a huge corporation, so we didn't really have a lot of data to give. And a couple other companies did provide data LANSA, ICL, which is a manufacturer of sodium bromide, and Enviotech, which I also think is a manufacturer or distributor of sodium bromide, the raw chemical. And they formed what's called the bromate work group, and they submitted a protocol to EPA and then did laboratory testing with it, submitted the results as well as with the American Chemistry Council, submitted some samples they had taken out in the field, and it refuted the 50% conversion. I don't remember exactly what that conversion amount was, but it was substantially less. So there was some, just not near as much. Correct. Yeah. So there was some. And so, and I believe they said that it was one ppm or less in residential pools and or maybe one ppm in commercial and then like 0.5%.

SPEAKER_05 7:10

That's based off of the actual recommended dose.

SPEAKER_04 7:13

Yeah. So that for those that they supplied to the EPA, they actually took samples and sent them to a lab. I'm not sure if they used the same lab as us, but they did send it to a lab. They gave it to the EPA and they also gave the laboratory testing. An EPA said, I took some issues with, I guess, the results and how the protocol was done, which funny enough, bromate workgroup says this is the protocol you approve. But they found the data was not satisfactory, so they threw it out. As you alluded to, in the absence of data, we're going to say, okay, we're just going to assume 100% converts to bromate, and therefore the risk level is too high, we're going to remove the outdoor pool use on any uh bromine-containing product. That's also true for tablets and bromine tabs and things like that. It was all halogenated.

SPEAKER_05 8:01

Can you walk everybody through this process, how sodium bromide forms bromate?

SPEAKER_04 8:08

So when you add sodium bromide to the water and then you uh shock it with chlorine, as is typical with an algacyte treatment, or if it's just in the presence of chlorine, it uh basically uh goes from bromide to bromine. And then bromine, like chlorine, forms hyperbromous acid and hypobromide, just like chlorine forms hypochlorous acid, hypochlorite. They're very similar. Um, the advantage of hyperbromous acid is that at a given pH, there's a lot more of it. Whereas like a pH of 7.5, which we all know is about 50-50 hypochlorous acid, hypochlorite, it's much more like 80 plus percent. And it goes up even more. So that's the main advantage of it. And that's an oxidation reaction. You can continue to oxidize it, so it goes from hyperbromas to hypobromite to bromite. You can get all the way to bromate. And that's about five levels of oxidation, state changes, and so it's a oxidation process, and the further you go along oxidizing, the more chemical energy you need to do it. So it becomes increasingly harder. But that's the that's the pathway, and that's the generally assumed pathway, is that uh you basically go in stages. You convert it to one, then convert it to the next, then convert it to the next until you arrive at bromate. Bromate is um also somewhat stable, predominantly leaves the water through splash out and backwashing and things like that, more so than it would like evaporation or anything else. So that's that's how it forms in the water. And so their the assumption is of the EPA is that any of that bromine gets converted 100% into bromate through those steps. It's not really chemically feasible. It's kind of a assumption they're making for the sake of safety, not in terms of it necessarily being realistic. Because even realistically, even if we go by what Arch was saying, you could only expect 50%.

SPEAKER_05 10:07

The other advantage is, of course, meaning for bromus acid has no attraction to cyanuric acid like hypochlorous acid does. So at that point in time where it's boundary bromine doesn't go through that at all. So there's nothing regulating the effectiveness of hypobromous acid as we see in the cyanuric acid, hypochlorous acid relationship.

SPEAKER_04 10:26

Yeah, so it it kind of works very quickly. It can't be stabilized, like you said, so it does deactivate a little bit more quickly, and that's why you don't see it used regularly in outdoor pools except as like a as an algeci. So there's other benefits like bromamines are also very effective and uh are are not as much of a problem as like chloramines are, so there's also an advantage. There's no nasty smell. There's no nasty smell, and it's actually pretty good algebra. It's pretty good at high temps, no problem. Yeah, so it's more stable in that regard. There's also other reactions that happen kind of momentarily, like between chlorine and bromine at the moment of reaction, it forms a molecule that's very high oxidizer, which is basically just a chlorine and bromine connected momentarily by themselves. And so that has some effect, but at the same time, the the primary driver of what's killing the algae is the hyperbromas.

SPEAKER_05 11:24

True or false? If you add sodium bromide to a chlorine pool, you now have a bromine pool. That's very common.

SPEAKER_04 11:30

And it's like most things, it's sort of true, but not really. So there's uh competitors will often say once a bromine pool, always a bromine pool. And that would be very nice if it was true. It means you could buy yellow treat once and then just use chlorine and it would forever work, but it doesn't quite work that way. So, yes, you're using some of the chlorine to create the hyperbromous acid. So, in that regard, yes, you are converting chlorine to bromine in that instance. But as it continues to get used up, the chlorine is still active in the water. So, someone way to think about it that's maybe a little bit more accurate is that it exists as kind of like a hybrid pool where you have two sanitizers working at once. But of course, over time, the bromine gets deactivated rather quickly from UV light, and also as it splashes out and some degree gassing off, although not nearly as quickly as chlorine gas off, it slowly dissipates in the water. And also just the sheer fact that you're adding so much more chlorine than you are bromine, you're gonna have chlorine present in the under normal chemical operations.

SPEAKER_05 12:39

How much time is that? Hours, days, weeks? You mean as far as before it's just chlorine again?

SPEAKER_04 12:44

It depends. It depends on the pool and it depends on the different conditions. So bromine itself as a pure element is not nearly as gaseous as chlorine. So it exists kind of in a transition state where it's slightly liquid and slightly gaseous. So when you shock the pool with bromine present, you're creating some bromine. There's some element of that gassing off. It's just not as predominant as, like, let's say, chlorine gasol. So there's some degree of that. And the rest is really splash out. So if um typically two to three weeks is probably what you could expect from a yellow treat dose to, or sodium bromide dose in general, to it being negligibly present. So that's usually the norm. It can maybe be longer, it can be shorter. It just depends. How much are you backwashing, how much are you swimming during that time? And so that all has factors that affect it. But it's it's a little bit of an exaggeration to say you use yellow treat, you forever have a bromine pool now, or you have to drain the pool and refill it. You don't, because the amount that you're adding is a very small amount and it becomes negligible rather quickly.

SPEAKER_05 13:50

So with the EPA is a big concern, we must absorb this stuff through our skin like a sponge, right?

SPEAKER_04 13:56

No. So the the toxicology of bromate is that uh the only pathway that's a concern is ingestion. So it's actually when you're drinking the water, ingesting water as you swim. Obviously, no one's you know taking a straw into their pool and and drinking it unless that's the only water source. To each their own. But no, it's it's the incidental swallowing and ingestion during swimming. PA has what they call swim model, which is they worked out with the American Chemistry Council that uh works out a rough approximation of what, depending on your age group, depending on if you're a competitive competitor in the water or not, et cetera, all these fact assumptions, how much are you ingesting? It's basically like I think the equivalent of a shot of water per maybe half hour to hour that you swim. Okay is how much you're actually drinking, like a shot glass equivalent. Maybe a little bit more. I'd have to work out the exact math again. That's a British. Yeah, but it's not it's not a lot.

SPEAKER_05 14:59

It's not like drinking water. Right. So how much do you and so they're basing it off of a shot glass? How many of these shot glasses do we have to like if I was just going to go out there and drink bromate out of the pool under normal circumstances, under the normal levels that we operate with after we add a dose of of sodium bromide anybody's product? Um, I'm out there, I got my shot glass, I'm 200 pounds. How much of this do I have to drink before I get cancer?

SPEAKER_04 15:25

Well, that's really according to their model, what they they make an assumption is that, and it's important to bring this up because back when all the balls are gun got rolling on all this, they've done additional studies, the like the original scientists who looked at bromade itself and how how really toxic or how harmful or carcinogenic is to people. And it's probably less than they were originally assuming. So it's important to keep that in into account. There's probably a threshold that once you drink more than that, then you start to get the toxological effects. That's the latest sign. So that's not what EPA is. EPA is looking at as linear. So if you get an atom, one single atom of bromate in you, there's some measurable increase in cancer risk. And that gets multiplied across your lifetime. So going back to your original question, okay, how much do I have to ingest? So at the level of, and I'm going to paraphrase, we we have a better breakdown in our actual study using their model. It's over 30 years. If you if all the assumptions are true, then it's something like maybe the threshold they concern about is one in 10,000. 10,000 people over 30 years, one of those people developing renal cancer from ingesting the amounts that are assumed. And that's and that's basically how they calculate it. And you say the same for Cheerios or like any major breakfast cereal, probably. Depends on what it depends on what you're putting on your Cheerios, I think. But yeah, so there's the way that, you know, with science and with this, and especially things as complex. And I am not a, you know, I'm not an epidemiologist. I understand chemistry as it applies to a pool, and I'm working off assumptions that other people much more inform those subjects do to me. So take this with a grain of salt. But the the assumption is that every additional exposure you get compounds. So yes, smoking is much more carcinogenic. 50-50 shot of everybody who's smoked cigarettes versus one in 10,000. That's very, that's very, you know, significant. It's not necessarily an either-or, at least is the way they assume it. So that's kind of how when they're making these risk assessments, to my understanding, it applies. So it's like one additional person in 10,000. I don't know what the carcinogenic rate is. Cheerios is, I hope it's low because I I love Cheerios. I'm gonna get sued by General Mills tomorrow. If you use a linear model like we're talking about, then technically everything has the potential effect of increasing cancer risks, and it's all about risk mitigation. What's probably more realistic that I was talking about, there's probably a threshold. So there's some studies, some proposed, I believe, by the original Japanese team that first did the studies with bromate, and that's kind of their specialty on dietary bromate. And some other scientists have looked at it that said the odds are when you ingest bromate, let's say you you ingest a significant amount of bromate, your stomach acid also has a chemical reaction with it, acts as a reducing agent, reduces it back to uh bromite, bromine, etc. So it kind of rids, puts it in a state where your body can handle it. There's also other other biological processes that basically stop it from becoming carcinogenic at that point when it hits your kidneys. And that's just probably realistic. And you also have to look at the study. When they're doing studies, you try to do an extreme amount because you want a result. It's not very noteworthy if you fed bromate to rats and it didn't do anything. So you're trying to push the limits to find a measurable result. Well, I think it's the ex by time. It's the ex by time, cost, and also funding, you know. So you you you know, there's all those factors. And also just wanting to know what happens. So is it it's not necessarily always realistic. That's why you do back calculations. So, but that those are the assumptions that are built on and built on. So and that's what the EPA looks at. They look at the assumptions, build more assumptions on it, because that's basically all they have to work with. And so, yeah, so over a 30-year lifetime, if you have, I'll have to look at the math, I don't know, two ppm maybe of bromine. Maybe it might be like one and a half ppm is kind of the limit based on their models. Um, a one in 10,000 increased chance of developing cancer, assuming it works linear linearly. Uh, what I was reading on toxicology is it might mean anything less than 15 ppm has a zero fact. It's negligible. It's actually one of the things we're going to present to the EPA with toxicologists to present that information and data because when is that that you'll be presenting that to them? Whenever they can whenever they'll talk about it.

SPEAKER_05 20:20

Whenever they'll let you.

SPEAKER_04 20:21

Yeah, so with so with the study, and just to give you an idea of timelines, we proposed a study that we actually completed uh about two years ago, and they're just starting to review the protocol now.

SPEAKER_05 20:32

So that's gonna rip breakfast cereals out from under the bus for a second, but bread, pizza dough, baked goods, all of these things contain potassium bromate.

SPEAKER_04 20:43

Yeah, and that's actually what they first studied. That was the vehicle of bromate. They assume that since potassium is pretty common and bromate is not, that that's actually the carcinogen is bromate. That's how they work that out.

SPEAKER_05 20:56

It's also an ingredient in cookies.

SPEAKER_04 20:58

Yes. And a lot of it's banned in some, I think, EU countries. It's still used widely in other countries. In the US, it's not banned. It's just discouraged because of the way the laws work. You shouldn't do that, but you're not going to get in trouble for it if you do. It's not illegal, but you shouldn't use that in baking style. I think most of the food industry has moved out of it, but I don't I don't have a list of like manufacturers that do or don't.

SPEAKER_05 21:26

But that's the report I saw going back the furthest presented to the EPA on bromate was dated 2005. Why did it take them so long before this happened in 23, right? 22, 23?

SPEAKER_04 21:39

I I'm think the letter that you're referencing is the arch chemical. So that might be the 2005 letter. Carcinogenic studies on potassium bromate maybe go back as far as 2001. So I'd have to double check.

SPEAKER_05 21:53

But as far as the actual label requirement that they made you put on your product?

SPEAKER_04 21:59

What year was that? Came into effect uh two thousand before I believe manufacturers first started receiving it, and I think we were found at the tail end of that, and then they give you a year to basically sell through your your inventory of labels before you have to put new labeling in. So that way.

SPEAKER_05 22:27

From Tim Layton, an environmental scientist, Nam Shum I'm gonna butcher this one, Shameem, Cassie Walls. And uh yeah, I I can't tell you who they were with. There's just the name of ran rando scientists. But why did it take so long?

SPEAKER_04 22:42

It's a good question. I don't know if they're I don't know. It's interesting. I we could be, and this this is just my own ignorance of what goes on with the the EPA behind the closed doors or outside, because we're based out in California, I'm not in DC. We have contacts with the EPA, we've you know, we've interacted with them, we have uh a firm that we've gone through to talk to them. But I think it's several fold. I think first, there's a lot of pesticides out there, and the EPA is is perpetually understaffed. Like I said, it's taking them two years to review a protocol for a study. That's a really long time. By law, they're actually supposed to get back to anybody in 90 days, but I mean that's that's almost impossible, especially at this point. And they can't be an expert on everything. So I think that's the first factor. So then not being an expert means they lean on manufacturers. And I think depending on who you talk to is what you get. We we've had an experience, and I don't want to go down a conspiracy theory rabbit hole, but there were come some competitors that were using that 2005 letter from Arch as a way to sell against our product. Now, do any of those people talk to the EPA? I don't know. And so maybe there was some of that lobbying of EPA against sodium bromide, that's possible. And also the EPA tends to work in cycles. So they can't, they're not large enough to regulate every single industry simultaneously to the same degree. So they'll say, we'll come back and look at that later. And so there's some of that too. So I think it's a combination of understaffing, just a huge kind of, I don't know what you would call it, the purview of the EPA to cover so much stuff. Um, even the pesticide division and having to do it cyclically, and then probably lobbying to some degree. If I had to guess, I would say it was a combination of those that took them this long to come back to it and also come up with the interim decision. And I think it doesn't always help some of the, well, no one likes to get a manufacturer does not like to get told by the EPA. We got shut down in 94 by the EPA because they they my my dad pissed them off. So basically he's like, you know, we shouldn't have to register, and they're like, Yeah, you do, and we're gonna shut you down to make you. You know, that probably cost us a million dollars. So some of the maybe, I don't know, uncooperativeness with the EPA is earned, but also it can come back to bite you because like it or not, and they're the EPA. We gotta we gotta work with them. So better to be a partner than an enemy in some regards, unless you have to be an enemy.

SPEAKER_05 25:19

Back in the 80s, we we used a chemical called cimazine for black algae. That went away in 1993. The EPA said no more for pool use. The consensus was they took it away because it worked. Do you think that applies?

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SPEAKER_05 27:35

Today is the last day you can tell us the name of the person who has helped you, guided you, mentored you. Go to mentoraward.com, leave off the www. Don't let your mentor go unrecognized. Again, that's mentoraward.com. God bless the pool pro. Michael, we used a chemical called cynazine for black algae. That went away in 1993. The EPA said no more for pool use. The consensus was they took it away because it worked. Do you think that applies to the maybe?

SPEAKER_04 28:05

Well, I mean, if if the if if it is a lobbying is doing this, then yeah, then that's absolutely someone, you know, someone would lobby the EPA to to get heavier on sodium bromide and take it away from the market if they thought they had something to gain. I don't think that's the motivation of the EPA itself. But again, EPA is not expert on everything. They're relying on whoever's in their ear. Whoever's in their ear says sodium bromide needs to go away, and there's because I have something that I think will benefit from it, that's what you get. That's what the that's where the lobbying comes in. But I don't know. I don't I can't comment to how it is.

SPEAKER_05 28:44

Do you think Canada is partially at fault?

SPEAKER_04 28:46

Well, Canada probably has some kind of influence on it in the sense that they also disallowed the use of sodium bromide, and that was also because of the same idea of bromine. But there it was outright, wasn't it, initially? They just said no, nothing. Yeah. Yeah. They said nope, you can't use it in pools. I don't know if it was limited to outdoor pools or if it was in total, it might have been in total total elimination of the chemical.

SPEAKER_05 29:13

Then I think a couple of years later they said, well, all right, you can use it for whatever, but not everything.

SPEAKER_04 29:19

That that sounds about right. And I mean the US US usually tries not to follow trends, but I mean there's always some of that influence. So if you know, if Canada says we're getting rid of it, the EPA might go, maybe we should get rid of it. I think the FDA is a little bit more resistant to influence like that than maybe the EPA, but that's just kind of an impression I have, not necessarily anything I could factually state. But I mean it's it's it's hard to know because I mean we only know what's there are a lot of different ways to go about getting mustard algae out of a pool.

SPEAKER_05 29:52

There are a lot of different things out there, but the folks that use sodium bro bromide for mustard algae control, they are die hard sodium bromide fans.

SPEAKER_04 30:02

Yeah, it works. Like you said, it works and it works consistently and it works predictably and it's cost savings, it's effective, and it's fast. So there's definitely in terms of efficacy, and of course we're biased. We that's our bread and butter sodium bromide-based algae. We basically brought them to the industry back in the 1980, I think was when Yellow Treat came out, or 1981, maybe. So yeah, so that's our baby. So of course we're biased, we think it's the best that's out there. But you can make a pretty good objective argument in that it's the most effective mustard algebraic, and maybe algecide in general, compared to all the other alternatives. Because you have copper sulfate, works, but then you have stains. You have ammonium sulfate, which sort of works, but also requires so much follow-up shocking that it's kind of like is it helping really enough to warrant the cost? And then you have polyquats, which are good preventatives, but they're not super effective at get renewal algae. And then of course you just have shocking, but then you're dumping tons of chlorine into a pool. So, you know, there's all there's pros and cons to each, but sodium bromide's really tough to beat.

SPEAKER_05 31:14

I mean, it's would you agree? Uh, and I'm I don't want to get too far off topic because I do want to talk a little bit more about the study that you did and where people can find that, but do you believe or have you noticed, because I I think it's out there, I'm just gonna say have you probably tracked this on a on a broad scale, increases in mustard algae over the past decade, growth at swimming pools. Have you noticed this, or would you say it's the same as always?

SPEAKER_04 31:40

Yeah, it's tough to say. I think mustard algae is is been more predominant in the industry. I mean, some of that is because over the years we've sold more, so that that would make you go, okay, well, more and more people are using it because alternatives are not working, or it could also just be word of mouth, which is usually how most people know about our product. Some of it can be weather with seasons being a little hotter. That's when mustard algae is uh is happy. So I think a combination of things, yeah. I would say it's more common. It's definitely the number one thing that pool guys will talk to us about. Like for say, hey, what is new in your life? And they're like, man, this season, I'm just getting more and more mustard algae. Like that.

SPEAKER_05 32:23

I do grow diatoms, not for the purpose of growing diatoms. I grow lack algae. I grow cyanobacteria. I keep it very specific by genus, my cyanobacteria, but I do also have diatoms added so that way the cyanobacteria doesn't just completely take over. That's pretty awesome. That's very cool. So I do, but the point is, is I do add things to kill cyanobacteria, and at the same time, simultaneously, I do work with diatoms indirectly, I guess you could say there's side casualties of war, if you will. Yeah. They're tough. Oh yeah. They are tough. We're talking about things that have been around since the dinosaurs.

SPEAKER_04 33:01

Well, they say that like cyanobacteria, which is basically black algae, is probably what gave us oxygen in our atmosphere. That's how it's and mustard algae is pretty tough. You know, when we think of they got a really bad pool, that's a swamp pool, that's green algae, which is depending on what it is in a different genus, in some ways it's easier to kill than mustard algae because it doesn't have that slime layer, I guess what you call it, that it uses to protect itself. It's usually not quite as mobile either. So yeah, there's a reason why of our algacides we sell the most of yellow treatments. You said mobile. It moves. Oh yeah, it's it's a swimmer. It it you look under it in a microscope and and uh the the particular um what'd you call it, phylum that it has, it's actually characterized as having basically a tail and a rudder. Um and that's how it how it swims around in the pool. Cyanobecter is interesting because it's more of a filament that kind of wiggles almost to move around.

SPEAKER_05 34:02

They also do it goes through periods of seeding where it just cyanobacteria just bursts out cells periodically. And I've actually been in pools underwater looking at large colonies when that's occurred, which is interesting as heck. You know, get out, shower twice, extra, whatever. It could be the reason, you know, you never know. But it just I've been putting it on mine to try to fill mine. Is that what it is? Yeah. Where can folks listening find this report of yours aside from the link I'm gonna stick in the show notes?

SPEAKER_04 35:46

Yeah, so you can find uh you can find the full study we did. So we we did the study um and we did in three phases because we frankly we just didn't want to wait for the EPA's approval. We're like, we need we need to, as much as chemically it didn't make sense from from a chemistry standpoint of view, we also just for ethical reasons, so that way I can sleep at night. Like we we have to see what's the real world, what what is the observable amount of bromate that's even produced. Let's assume everything about bromate is correct, how much are we actually looking at, and is it really posing a potential danger? Because if it is, we would pull the mark, you know, pull it from the market, regardless of what the EPA said. Um mantra was don't become the cigarette company. You know, don't hide the data. That's why we said mantra. Worst case scenario, whatever the worst, whatever we found, we're gonna publish it. And what we found was that in the study, uh, that's available on our website, uh hopefully the EPA will also read, is that if algae is present, you don't get any bromate formation. It inhibits it, the bromate formation completely. If the water is clear under without uh, and this was the conditions, without any cyanaric acid in the water, a pH of eight, which would promote bromate formation, and uh without any organics, uh you would get under realistic conditions maybe about 20% conversion. Based on dosing rates, that puts it in what the EPA would determine is tolerable risk, meaning that it's it would be considered safe enough for general use in outdoor pools. When you add in other factors, it's probably even less. Like I said, you add cyanic acid to the water, you kind of slow down some of the chlorine's reaction.

SPEAKER_05 37:34

You say 20%, that's tap water. That's bath water we're talking about, treating that with sodium bromide and chlorine, not what we have in an actual outdoor swimming pool that has a cyanic acid level in it, that has a pH that's lower than 7.5 fingers crossed that scenario.

SPEAKER_04 37:50

So, yeah, so for the study, we actually built it cost us, it has cost us, I think about probably about 70 grand at this point. We built eight above-ground pools, roughly 5,000 gallons, and they're just vinyl liner pools because again, that was expensive enough. That alone was like 20 to 30 grand, getting it all installed and everything. And then we did in phases, we drained the water and refilled it. So, yes, so these were all done in pools. We measured UV, light, radiation, we measured pH, and we let the pH drift high. We used liquid chlorine, probably because it's hypochlorite, is probably gonna drive it more towards bromate. So we really want to look at like what's the worst case scenario realistically. Obviously, if we filled the pools with chlorine and then added sodium bromide, I'm sure we would have gone a crazy number. But we wanted to say, okay, let's say pH is high, no cyaneric acid, dump chlorine in the water, add sodium bromide. Well, I'm sorry, add sodium bromide, dump chlorine in the water, what do you get? And so that was about 20% conversion. Interestingly enough, you compare our results with the bromate work group, that even though the EPA didn't want to accept those results, it kind of tracks. A lot of it tracks with what the bromate work group was reporting for whatever that's worth. So at least it's not in science, if it's something insanely novel that can sometimes be bad in situations like this, because then it, you know, then there's nothing to back it up, and you have to repeat it a number of times. But the existing science out there does support what we found, and we cite all the other studies and based on our conclusions. That is available on our blog. We have a summary of what it is in a little bit more plain English because the report is 19 pages long with all the data and all the breakdown of the science. But you can also download that and just go step by step and how we did each thing, the limitations of it. Like you said, we we don't know for certain what impact cyanic acid has. A reasonable expectation though would be that it would lower um the bromate formation in the water.

SPEAKER_05 39:56

Because again, what we're looking at is solar UV.

SPEAKER_04 40:01

Yes, every day. Yeah, and and what we found, the main driver of how much bromate was formed, other than, you know, if you have any organic material, it lowers it. Um, the presence of uh ammonium compounds, which was also an organic, lowers it. Uh we used artificial swimmer sweat towards the tail end of the study to see if that has an impact, and it does, although it's not huge, but it does. And that's probably also ammonia compounds, basically stunt any formation. Soaks up the some of the chemical energy to drive it to that. Adding pH suppressants like uh sulfamic acid in our case, also suppress it to varying degrees. So what I'm talking about 20%, roughly, somewhere in that range, is like you said, it's pure water, sodium bromide, pH at that. And the biggest driver we found was how hard you shock the pool and uh what the ratio is. If you actually use more bromine relative to an amount of chlorine, you actually get less bromate because less of that oxidizer is distributed. It's just ratio. And we actually have a formula you can use to predict how much bromate theoretically you would see in a pool based on those.

SPEAKER_05 41:08

Now, this product, it's still for sale, it's still for use in 100% spas, indoor, there's no warnings against indoor. If I bought them, what if I just tented the pool? Does that solve the problem?

SPEAKER_04 41:20

That was they discussed that. They basically said at some point in the directions or when they're discussing directions to cover the pool when treatment. And you know, from the EPA standpoint, I don't I don't know if they would find that acceptable. Chemically, would that in theory, although we didn't find a strong correlation between UV radiation and bromate formation. So in the study, I I say it's not clear if if it's just you need some kind of UV radiation, because some studies say that it won't form, but it doesn't matter the amount. I don't know. There's still there's still not as comprehensive as we try to make the study. There's there's still areas where a little bit foggy. Yeah, but I mean theoretically, yes. According from the EPA standpoint, if the pool's not exposed to sunlight, then it can be treated with sodium bromide fine with our labeling of products. And I will also mention that it only applies to EPA registered products. The way that the law goes for EPA pesticides is that you're only required to register technically if you make a pesticidal claim. So you can still go out and buy sodium bromide and it won't have that warning on it because however it's labeled, it's not making a sodium pesticidal claim. So it's a legal loophole whether or not it should be that way. That's just the way the law is. If you're a manufacturer and you're taking advantage of it, I that's an awfully big gamble you're taking because the EPA might still show up and say, yeah, you don't make the claim, but basically everybody's using it that way, and that's how it's and that's how you're alluding to it being used. So we're gonna make you register anyways. But as it stands, buying generic 50-pound sacks of sodium bromine, you can go out and do that and use it however you like. It's only EPA registered pesticides that have not for use in outdoor pools.

SPEAKER_05 43:13

Our listeners, we're probably a bit more focused as far as the market that we hit. It's we're mostly pool professionals. I know there's there's some folks at home listening as well, but we're overwhelmingly pool professional. And we have, I would say, thousands, if not hundreds of thousands of pool professionals that listen, that are all, in my opinion, badasses. God bless the pool pro. What can we do to help?

SPEAKER_04 43:38

That's a that's a great question. Several things. So I wouldn't necessarily say to go up and call the EPA yet, but making your voice heard never hurt. So just be vocal. Just be vocal. And a lot of this is when you're dealing with regulators, you know, it's a PR thing. It's a it's making the EPA go, oh, okay. Okay. So maybe this is more harmful, this regulation, than it's helpful. Because again, it's easy to vilify the EPA. They shut down our company in 94. They're now doing this regulation because they say, well, we don't have evidence, so we're going to assume something that's not necessarily chemically feasible, and worst case scenario, because it's easy and who cares.

SPEAKER_05 44:21

This is within the same time frame that they decided they were going to release all of the files on UFO and alien studies. So, you know, priorities.

SPEAKER_04 44:33

But at the same time, they don't know. They don't know. They're, you know, they're they're they're they might be very well-educated scientists, but they don't know about taking care of a pool. They don't know, like your listeners or I do, or you do, about the ins and outs and what's realistic and what's not. Like I said, they're they're asking other manufacturers, if they ask us, we're going to tell them how great sodium bromide is. If they ask a competitor who wants to benefit from it not being in the marketplace, they're going to get a different story. So being vocal with you know the different groups that you go, like to your different meetings and chapters and sharing the information. And then, yeah, maybe, you know, calling up manufacturers and saying, hey, get get involved in this. I mean, we're all in this together. An ideal scenario for United Chemical would be that we convince the EPA to say, yes, you and only you, and then we, you know, we get to own the market. That would be wonderful for us. That's not realistic though. It's okay. It's okay to have more options. And so talk to the other manufacturers and say, hey, you know, talk to talk to Lonza. If you have Lanza contacts, talk to people who are at Natural Chemistry, anybody that's had sodium bromide saying, we want this, you know, go do something. We're stronger together than we are individually. It's just for us, you know, no more problems in Yellow Trade are flagship products. So we had more invested than a lot of other companies who will just go, we don't sell that much, so we don't care. You gotta make them care.

SPEAKER_05 46:03

And that's just you mentioned a couple of times, and I'm sure people picked up on it, that on this long time family business.

SPEAKER_04 46:11

Oh yeah. So yeah, my my dad was uh was a service guy out in the Brentwood area, and uh, you know, he started he actually started a chemical trying to manufacture cyanic acid way back in the day. I was one of I think that was the first thing he tried doing. And he developed products, he developed his own index, the Hamilton Index, that we still preach today, and really educated the industry and built the company up. And then, you know, my mom and I took it over when he passed away in 2002. So, and just tried to keep that legacy alive of, you know, keeping integrity was always big to him, Misty, being different, and most importantly, education. I mean, probably that's how people know us the most is just from job going out and teaching classes and everything more than any product necessarily. I want to ask one last question before we go.

SPEAKER_05 47:04

Has there ever been, and to your knowledge, a confirmed case of cancer due to adding sodium bromide to a swimming pool?

SPEAKER_04 47:13

No. And also if you look at the comparisons between even potassium bromate being banned and outlawed in use in countries versus not renal cancer rates, uh cancer rates go down. No, not observably so. Now that's that's just that's a very high-level view that doesn't account for everything, but I mean that's the statistics. And um, like I mentioned, more and more evidence is showing that there's probably a threshold. That's what the latest toxicologies know. And I, for what it's worth, I grew up swimming in the test pools at the factory when dad was testing out a lot of this stuff. It's a funny story. You would come out, he came out swimming or swimming with my friends one day, and he came out of the office uh and walked over to the pools, and he's like, Hey, how's the pool feeling? And I'm like, fine. He goes, skin burn at all? We're like, no, your eyes hurt at all? No, and he's like, okay, walked away, and friend and I looked at each other and I'm like, are we the guinea pigs? But uh and I I've used it with my own kids. I got a I got a five-year-old and a uh one-year-old, and I used my products in our pool at home and swimming them, and I'm not losing sleep over it. But that's I can only say that for myself. Everybody's gotta make up their own minds.

SPEAKER_05 48:23

For our listeners that have more questions and want to get a hold of you, how do they reach you, Scott?

SPEAKER_04 48:28

So there's a couple different ways. You can, if you want to, if it's something super technical, you can go to help.unitechemical.com. Basically, open a support ticket. It can be anything you want. It can be about this, it can be about one of our products, can be just about general chemistry. And you can call us. Our phone number is on the back of every single product and it's on our website. So just call us, tell us what you need and how we can help, and um, we're happy to do so. That's that's our thing in the industry. We're here to fantastic.

SPEAKER_05 48:58

Scott, thank you for being with us today and shedding a lot of light on this subject. I know a lot of people have been upset about it in the field. Like I said, very loyal, their go-to product, and we just appreciate you coming on and and chatting with us, the Talking Pools podcast family, for a little while.

SPEAKER_04 49:18

Yeah, and I I appreciate what you do, and I appreciate um more customers out there that are sticking through uh with us through a pretty difficult time. But, you know, we're we're in the fight. We're gonna be talking to EPA and we're gonna see if we can make a good solid scientific argument to get that get that product back in the hands of all the people who want it out there and need it.

SPEAKER_05 49:41

Fantastic. And definitely reach out, come back if you think of something that you need us to do beyond what we spoke of today. Everybody, Scott, thank you so much. United Chemicals, Scott Hamilton, CEO. Again, their product you're most everybody's familiar with, Yellow Treat. My name is Rudy Stankowitz. This is the Talking Pools Podcast. Until next time, be good, be safe.