Disclosure of Inerts
The U.S. Environmental Protection Agency is requesting public comment on options for disclosing inert ingredients in pesticides. In this anticipated rulemaking, EPA is seeking ideas for greater disclosure of inert ingredient identities. Inert ingredients are part of the end use product formulation and are not active ingredients. EPA believes that revealing inert ingredients including those not deemed hazardous will help consumers make informed decisions and will better protect public health and the environment.
What are Inerts?
According to FIFRA (the Federal Insecticide, Fungicide, and Rodenticide Act), the active ingredient must be identified by name on the pesticide product's label together with its percentage by weight. An active ingredient is one that prevents, destroys, repels, or mitigates a pest, or is a plant regulator, defoliant, desiccant or nitrogen stabilizer. All other ingredients in a pesticide product are called "inert ingredients." An inert ingredient means any substance (or group of similar substances) other than an active ingredient that is intentionally included in a pesticide product. Called "inerts" by the law, the name does not mean non-toxic. In fact, many inerts are more toxic than the active ingredient.
Pesticide products often contain more than one inert ingredient. Inert ingredients play key roles in the effectiveness of pesticides. Examples include inerts that prevent caking or foaming, extend product shelf life, or solvents that allow herbicides to penetrate plants.
Why should they be disclosed?
Ingredients in packaged food and cosmetics are disclosed; thus, the precedent has been set. EPA believes public disclosure is one way to discourage the use of hazardous inert ingredients in pesticide formulations. "Consumers deserve to know the identities of ingredients in pesticide formulations, including inert ingredients," said Steve Owens, assistant administrator for EPA's Office of Prevention, Pesticides and Toxic Substances. "Disclosing inert ingredients in pesticide products, especially those considered to be hazardous, will empower consumers and pesticide users to make more informed choices."
Pesticide manufacturers usually disclose their inert ingredients only to EPA. Currently, EPA evaluates the safety of all ingredients in a product's formulation when determining whether the pesticide should be registered. Personally, I can't help but wonder a few things. If EPA has evaluated their safety, shouldn't that be enough? If some inerts are so hazardous, why has EPA approved them for sale in the marketplace? Also, isn't the toxicity of a pesticide determined after the inerts have been added to make the formulated product? Can't a pesticide user simply read the product label or MSDS to find toxicity information?
I also question just how helpful this additional information will be to the average consumer. Sure, I can read the can of my favorite hairspray to determine all of its ingredients. But on the surface, I know nothing about those big chemical names listed. I could do some research to learn about them, but I'm happy with the product and in the end I trust the FDA to ensure the safety of its use. Perhaps I am naïve.
I can, however, see the merit in inert disclosure for those who are wishing to avoid products that contain specific inerts for health reasons such as allergies or even more serious conditions. One source I read stated that xylenes used as inert solvents in as many as 2,000 pesticides, are linked to increased frequency of leukemia in workers and may cause memory and hearing loss, liver and kidney damage, eye irritation, inflamed lungs, low birth weight, and even fetal death. Formaldehyde, bisphenol A, sulfuric acid, toluene, benzene and styrene are other inerts that are allowed in pesticides but are not identified on labels.
According to www.cornucopia.org, some are carcinogens, while some may cause reproductive or respiratory problems if people are exposed. Not all inerts are toxic, including coffee grounds, sunflower oil, and licorice extract. So, this information could be very useful to many people.
When are they currently disclosed and why aren't they always disclosed?
EPA requires registrants to identify to the Agency all ingredients in their pesticide products. A challenge for inerts disclosure by registrants is that their pesticides may include proprietary products whose contents are held confidential by the manufacturer. Federal confidentiality regulations (40 CFR part 2, subpart B) require EPA to protect information claimed as confidential by companies. One exception is when EPA provides inert ingredient information to medical professionals treating persons in connection with exposure to a pesticide.
EPA requires labels of pesticide products to identify any inert ingredient that it has determined is of "toxicological concern." In 1987, EPA required that the approximately 50 inerts of "toxicological concern" (called "List 1") must be listed on pesticide labels. Since then, nearly all List 1 ingredients have disappeared from pesticide formulations. Manufacturers replaced these toxic chemicals with less toxic ingredients.
Today, no List 1 ingredients are permitted in pesticides applied to food because they do not meet the stringent safety standards of the Federal Food, Drug, and Cosmetic Act. A very small number of List 1 chemicals can be used in pesticides applied to non-food sites if human and environmental exposures of concern are not expected, such as commercial plastics manufacturing. Also, certain states have their own regulations that require label identification of certain inert ingredients.
What spurred this recent action? Why is EPA calling for this change now?
On October 1, 2009, EPA responded to two petitions [one by Northwest Coalition for Alternatives to Pesticides (NCAP), and a second by several state attorneys general including Lisa Madigan of Illinois], that designated more than 350 inert pesticide ingredients as hazardous. These chemicals are already considered hazardous under other environmental laws, including the Clean Air Act. The petitioners asked EPA to require that these ingredients be identified on the labels of products that include them in their formulations. This was on August 1, 2006, three years prior.
However, the history of this inert disclosure campaign runs deeper than this. According to NCAP's website, in January 1998, NCAP petitioned the EPA to require listing of all ingredients on product labels. In July of 2001, the petition was formally denied by EPA. In fact, it appears that since the mid-1990s, there has been much pressure on EPA to disclose inert ingredients.
There was a federal court ruling in October of 1996 that said that the EPA cannot make a blanket policy against the disclosure of inerts, but must treat each pesticide on a case-by-case basis. Under the Obama administration, EPA has stated it wants increased transparency in its practices and policy. Perhaps it is ready to put this issue to rest.
What was EPA's response to the latest petitions?
EPA stated that it will consider ideas to increase the disclosure of inert ingredient identities "to an even greater degree" than that requested by the petitioners by requiring the disclosure of all inerts rather than limiting disclosure only to those substances considered to be hazardous.
What is EPA doing now?
The agency is inviting comment on various regulatory and voluntary steps to achieve this broader disclosure. EPA will accept comments on the advance notice of proposed rulemaking for 60 days after December 23, 2009, when it was published in the Federal Register.
EPA's Advance Notice of Proposed Rulemaking (ANPRM) outlines general options for inert disclosure on pesticide labels, including mandating disclosure only of potentially hazardous ingredients; mandating disclosure of most or all inert ingredient identities, regardless of hazard; and non-regulatory voluntary disclosure initiatives by pesticide registrants. The ANPRM solicits ideas for both regulatory and non-regulatory approaches and sets forth a series of questions for comment. EPA believes participation and comment by all stakeholders, including the public, is important for developing workable and effective solutions.
The Agency cites a number of issues that must be considered in pursuing regulatory action that seeks to achieve full public disclosure of inerts. Specifically, EPA must establish the criteria for determining what inert ingredient identities should be made public, the extent to which disclosure independent of hazard can be supported under existing statute, whether a concentration threshold should trigger a disclosure requirement, whether public disclosure should be made on pesticide labels or though some other vehicle such as the Internet, and what form the disclosed ingredients should take (e.g., Chemical Abstract Service names, common chemical names, trade names, etc.).
What does the chemical industry think about this?
Obviously, they are not too happy about it as they are concerned they will be revealing trade secrets about their formulas. It's confusing because the products already undergo risk assessments and they are approved for use. I'm sure they will submit comments during this comment period. One counter argument is that anyone who knows how to use a spectrometer can determine what the inerts are in a formulation.
For more information and to submit comments to EPA, please visit: http://www.epa.gov/opprd001/inerts/index.htm.
For a history of the "inerts disclosure campaign": http://www.pesticide.org/inertspage.html
For an interesting article on this subject from the American Bar Association (yes, lawyers are paying attention): http://www.arnoldporter.com/resources/documents/Arnold&PorterLLP_PesticidesChemicalRegulationandRighttoKnowNewsletter_12.09.pdf
(Adapted by Michelle Wiesbrook from an EPA press release dated 12/22/09. Information was also compiled from the following sources: http://www.epa.gov/opprd001/inerts/index.htm; http://www.cpda.com/CPDA-News-Items; http://www.cornucopia.org/2009/12/epa-announces-plan-to-require-disclosure-of-secret-pesticide-ingredients/)
Understanding the Cancer Risk of Turf and Lawn Care Pesticides
In the last issue of this newsletter, we wrote about the recent closing of the Breast Cancer and Environmental Risk Factors (BCERF) program at Cornell University. As of this writing, their website is still up and running but we're told this too shall soon end. One of their last efforts was the creation of a "Brief for Landscaping Professionals on Understanding the Cancer Risk of Turf and Lawn Care Pesticides" (called the Turf Brief).
It includes information on how cancer risk is assessed, how to find cancer information on pesticides used in turf care and landscaping, and advice on improving communication with co-workers, clients, and the community. Although it focuses on products registered for use in New York, applicators in Illinois should find much of the information to be interesting and useful.
In creating this publication, BCERF used a survey to collect feedback from over 1,200 New York State (NYS)-certified applicators and technicians on an array of topics related to work, pesticides, and health. Their findings follow in a slightly adapted version of the aforementioned publication.
Surveyed applicators reported that pesticide safety is a high priority in most of their turf, landscaping, golf, and other green industry workplaces. Managers are prioritizing the use of lower risk products, workers are taking responsibility for their own safety, and minimizing pesticide use is being emphasized. There is also strong concern among many workers about the potential health risks posed by some pesticide products. Half of the applicators surveyed worry about developing disease, such as cancer, as a result of their pesticide exposure. There is strong interest among turf and lawn care applicators in learning more about the potential health risks, including cancer risk, associated with some pesticides.
Making sense of cancer risk
Hereditary factors account for only a small portion (10-20%) of cancer cases each year. The vast majority of cases can be attributed to environmental factors, such as dietary (e.g., alcohol intake) and lifestyle factors, such as occupational chemical exposures or smoking. Studies of gene-environment interactions show that some individuals and families are more susceptible to developing cancer than others. In addition, some cancers may take 30 years or more to develop.
In order to assess the potential cancer risk posed by a chemical, scientists must evaluate the results of dozens of studies before a cancer risk categorization can be made. Studies done in laboratory animals, as well as studies of human populations, cell cultures, and other methods are each important sources of scientific information used in cancer risk assessments. Risk assessments using all of this information are used to determine the extent to which a chemical may pose a risk to human health.
Not all man-made chemicals hold the potential to cause cancer in humans, but some do. In many cases, we do not have definitive scientific information on whether a chemical will cause cancer or not. In these cases, chemicals may be categorized using words such as 'Possible' or 'Probable' human carcinogen (see box on EPA Cancer Classifications).
Pesticide registration, labeling, and cancer risk
Risk is the chance of harmful effects to human health from exposure to a hazardous chemical (or other harmful stressor). Risk is a function of both the hazard and the probability of exposure. The US Environmental Protection Agency (EPA) works to minimize the potential risks to human health posed by pesticide active ingredients by developing regulations and guidelines that help to reduce exposures. Formulation, application rates, type of use (e.g., general vs. restricted), and other factors are taken into account to decrease exposure.
Applicators must follow the pesticide label's application specifications as well as requirements to use personal protective equipment. These requirements are based not only on what is best to control pests. They are also based on what levels of pesticide active ingredient are predicted to not be harmful to human health based on the scientific information available at the time the pesticide was registered.
Since scientific methods for understanding health risks are constantly evolving, product label requirements can change periodically as well. Some pesticides used today were first reviewed several decades ago using older scientific methods. These chemicals are now being re-evaluated by the EPA. Pesticide product labels are required by law to provide health risk information on short term, or acute, health effects, such as eye or skin irritation.
Current federal labeling law does not require information on the product labels on chronic health effects such as cancer, reproductive, neurological, or other risks to long-term health. Therefore, it is important to read the label and also seek out additional health risk information on the pesticides and other chemicals you use.
Finding cancer risk information on the pesticides you use
Pesticide product labeling and Material Safety Data Sheets (MSDS) are important sources of pesticide safety information, but do not provide complete health and safety information. The sources listed below provide health and safety information beyond what is included in pesticide product labels or MSDS.
Cornell University's Turf Pesticides and Cancer Risk Database is an easy-to-use, searchable online database that provides cancer risk information for chemicals found in over 3,000 turf and lawn care pesticide products registered for use in NYS. The database is accessible at http://envirocancer.cornell.edu/turf. The database integrates information on a limited number of chemicals that have been evaluated for carcinogenicity by the EPA with over 100 pesticide active ingredients found in turf, lawn, and ornamental pesticide products.
Users can search for information three ways: (1) by product name, (2) by active ingredient, or (3) by cancer risk category (EPA's Cancer Classification). The database provides both product- and active-ingredient-specific information as well as information on pesticide regulation and cancer risk assessment. Downloadable PDFs are available with additional chemical-specific risk information.
Cancer risk information is not yet available for approximately two-thirds of the active ingredients found in turf and ornamental pesticide products due to historic cancer risk testing priorities. Recent federal regulatory decisions now mandate cancer risk evaluations to be completed for all active ingredients, but implementation of this testing will take many years.
REDUCING RISK: Things you can do
There are a number of ways that turf and lawn care professionals can reduce the risks posed by turf and lawn care pesticides.
• Integrated Pest Management (IPM) techniques should be used as a first step towards reducing, minimizing, or possibly eliminating the need for pesticides. The use of IPM has become the norm for pest management in many areas. IPM techniques not only reduce risk, but are often more cost effective than using traditional pesticides for pest control.
• Choose organic products, which are now being used in lieu of traditional synthetic pesticide products in many applications with success.
• Seek out health risk information on the active ingredients found in the pesticide products you are considering using and determine whether alternative, less risky products may be used instead.
• If synthetic pesticides are to be used, applicators should always take the time to read the label and use the product only as directed. Instructions for using personal protective equipment should be followed or exceeded, and common hygienic practices such as hand washing, laundering of soiled work clothes, and bathing should be followed closely.
Improving communication with your co-workers, clients, and community
Communicate with your co-workers, clients, and the community you serve. Over half of the applicators surveyed reported discussing pesticide exposure or safety issues with their supervisors or managers less than once a month, with nearly 20% reporting that they never discuss such issues. Similar results were found with regard to discussing pesticide exposure or safety with co-workers, clients and customers, friends and family, and doctors and health care providers. While a majority of applicators surveyed reported that talking with clients and the public is part of their job, less than half reported receiving training in how to do so. Research shows that the great majority of applicators want to learn more about the health risks, such as cancer, posed by the pesticides they use and that they would most like to receive this information online or through their certification and training courses. Increasing health and safety communication and training should continue to be important priorities for workers and pesticide safety educators alike.
EPA Cancer Classifications for Pesticide Active Ingredients in Currently Registered Turf and Ornamental Pesticide Products in New York State
|
EPA Cancer
Classification |
Active
Ingredients |
Products* |
|
Known human carcinogen |
0 |
0 |
|
Likely/Probable human carcinogen |
19 |
252 |
|
Possible human carcinogen/Suggestive evidence |
29 |
582 |
|
Not likely/Evidence of non-carcinogenicity |
46 |
412 |
|
Not classifiable/Inadequate information |
16 |
243 |
|
Multiple descriptors |
2 |
12 |
*Includes products that are discontinued and scheduled for cancellation in NYS as of December 12, 2008.
(Michelle Wiesbrook, adapted slightly from "Brief for Landscaping Professionals on Understanding the Cancer Risk of Turf and Lawn Care Pesticides" written by Heather Dantzker, formerly of Cornell University's Program on Breast Cancer and Environmental Risk Factors.)
Fungicide Toxicity, Continued
The following fungicide products have been around for many years. Some people have become complacent about their use. As a result, they may ignore proper safety precautions and fail to appreciate the risk involved when using these fungicides.
This article can help the user understand the risk of misusing and mishandling these products. Consider this information when selecting fungicides. Of course, pesticide labeling information should first be consulted in the event of a poisoning. The following information is summarized from the National Pesticide Information Center web site and is a continuation of fungicide toxicity information found in the last issue of this newsletter.
Thiocarbamates are usually purchased as dusts, wettable powders, or water suspensions. These types of fungicides are used as seed and seedling protectants, as well as fungicides on ornamentals, turf, vegetables, and fruits. Thiocarbamates have little, if any insecticidal properties compared to the N-methyl carbamates. In addition, most of these fungicides have no significant effect on cholinesterase. Those that do show some effect exhibit a very weak effect.
Metam-sodium is considered to be a fumigant. In the United States, its use in home landscapes is no longer allowed. This product can be very irritating to skin. There have been no reports of oral poisoning. When metam-sodium decays in water, it releases a gas that causes extreme irritation to the eyes, as well as to respiratory mucous membranes and lungs. The gas can cause coughing of bloody, frothy matter from the mouth. Because of this gas, metam-sodium is considered a fumigant. Therefore, one must take all precautions to avoid inhaling the gas in addition to avoiding skin contact.
Treating skin contamination includes washing with soap and water immediately. For eye contamination, flush the eyes with plenty of water immediately to avoid burns and corneal injury. If skin and eye irritation continues, seek specialized medical treatment as soon as possible.
If large amounts of metam-sodium are ingested, then gastric emptying, or charcoal and emptying of the bowels should be considered. Seek medical help immediately.
The gas is methyl isothiocyanate, which is the decomposition of metam-sodium in water. If this gas is inhaled and pulmonary irritation or edema occurs, transport the person(s) to a medical facility immediately.
Thiram is not only a fungicide, but it is also a common component found in latex. This may be a possible reason some people have an allergic reaction to latex gloves.
Thiram, as a dust, can cause moderate skin, eye, and respiratory mucous membrane irritation. Skin inflammation has occurred in occupationally exposed workers. Some individuals have become sensitized to thiram. Very few systemic poisoning cases of humans have been reported – most likely due to limited absorption during human exposure. However, reported toxic reactions to thiram have been similar to disulfiram (Antabuse – used in alchohol aversion treatment).
Both thiram and disulfiram inhibit the acetaldehyde dehyrogenase enzyme. This enzyme converts acetaldehyde to acetic acid. The toxic reaction occurs when a person who has been exposed to thiram drinks alcohol too soon after the exposure. The reactions include nausea, vomiting, severe headaches, dizziness and light headiness, confusion, heavy sweating, skin rashes, and abdominal and chest pains.
For skin exposure, wash with soap and water immediately. For eye contamination, flush the eyes with plenty of water immediately. If skin and eye irritation continues, seek specialized medical treatment as soon as possible.
If thiram has been ingested in large amounts and effective vomiting has not occurred within 60 minutes, then the stomach may need to be emptied by pumping the stomach while protecting the airway from the vomitus. If small amounts of thiram have been ingested, then an oral administration of activated charcoal followed by its removal may be all that is necessary. If severe vomiting and diarrhea occur, then replacement of needed electrolytes may be needed via appropriate IV fluids.
If a severe disulfiram-like reaction occurs, laying a person on his or her back and elevating the feet higher than the head, as well as administering oxygen and IV fluids may be appropriate. To avoid a disulfiram-like reaction, a person who has absorbed a significant amount of thiram should avoid all alcohol consumption for at least three weeks.
Ziram and ferbam are two other thiocarbamates sold as either a flowable or as a wettable powder. They are used on fruits, nut trees, vegetables and tobacco. The dusts of these two fungicides cause skin, eye, and respiratory irritation. In addition, a disulfiram-like reaction may be possible, but none has ever been reported.
For skin exposure, wash with soap and water immediately. For eye contamination, flush the eyes with plenty of water immediately. If skin and eye irritation continues, seek specialized medical treatment as soon as possible.
If large amounts of either ferbam or ziram have been ingested recently, "gastric emptying" should be strongly considered. If several hours have passed or only a small amount has been swallowed, then the appropriate oral administration of activated charcoal and its removal should be considered.
If hemolsis (the appearance in the plasma of hemoglobin after it has separated from the red blood cells) occurs, the appropriate IV fluids should be administered to induce an increase in excretion of urine.
(The above material has been slightly edited from Recognition and Management of Pesticide Poisonings 5th Edition (1999) by James E Schuster. In the next issue, EBDC compounds will be summarized.)
New Sprayer Calibration Fact Sheet Available
A recent fact sheet from Kansas State University Agricultural Experiment Station and Cooperative Extension Service explains in detail how to successfully calibrate a sprayer. The fact sheet, titled Calibrating Boom Sprayers, was authored by Robert E. Wolf, an Extension Specialist with the Department of Biological and Agricultural Engineering at Kansas State University, and Scott Bretthauer, an Extension Specialist with the Department of Agricultural and Biological Engineering at the University of Illinois.
The fact sheet first explains all of the variables that determine the application rate for a sprayer. These variables include nozzle flow rate, ground speed of the sprayer, and the width sprayed per nozzle. It is important for an applicator to understand how these variables impact the application rate, not only for the initial calibration but also in order to make sure the sprayer is operated correctly to optimize performance of the nozzles and provide good pest control while minimizing drift.
For each of these three variables, the fact sheet provides details on the factors that affect these variables, how the variables impact the application rate, and how an applicator can best change these variables to adjust or maintain the desired application rate.
The process for determining the required nozzle flow rate to make an application at a specific gallons-per-acre (GPA), ground speed, and sprayed width is given in a series of detailed steps. Next, a pre-calibration test is described to prepare the sprayer for calibration and to check for uniform spray pattern, worn or plugged nozzles, and proper overlap. Following this, the actual calibration process is described in a step-by-step process. The fact sheet provides all equations required for calibrating a sprayer, as well as a few sample problems that help illustrate the process. To download a free copy of the new fact sheet, visit the following webpage: http://web.extension.uiuc.edu/psep/facts/calibration/mf2894.pdf
(Scott Bretthauer)
New Sprayer Calibration Tool Available
Nozzle flow rate, measured in gallons per minute, is one of the key variables involved in calibrating a sprayer. The flow rate from a nozzle is determined by the size of the nozzle orifice and the operating pressure. Accurately measuring the flow rate from a nozzle is important, not only when initially calibrating it, but also in determining the degree of nozzle wear and assessing whether or not you need to replace your nozzle.
There are two ways to measure the flow rate from a nozzle. One is to collect spray in a container marked with the appropriate measuring units, usually fluid ounces, for a specific period of time, often one minute. The flow rate in gallons per minute can then be calculated, verifying whether or not the sprayer is properly calibrated.
A new calibration device is now available that eliminates the need to use a measuring cup and stopwatch. The SpotOn Sprayer Calibrator provides an accurate gallon per minute (GPM) flow reading in just a few seconds.
To use the SpotOn Sprayer Calibrator, all you need to do is turn it on, hold it under the nozzle at a slight angle, ensure that all spray from the nozzle is collected in the calibrator, and wait for the unit to give you a flow rate reading. When finished, simply pour the water out of the top to empty the device. The device can be set to provide flow rate readings in GPM, fluid ounces per minute, and Liters per minute.
There are two models available. Model SC-1 is recommended for use with nozzles when the measured flow rate will be below 1 GPM. For flow rates between 1 and 4 GPM, the SC-4 is available. Both units provide a resolution of 0.01 GPM. To learn more about the SpotOn Sprayer Calibrator and find out where they are available for purchase, visit www.spotonproducts.com (Scott Bretthauer)
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