TOXICS INFORMATION PROJECT (TIP)

TOXICS INFORMATION PROJECT (TIP)

(Lighting the way to Less Toxic Living)

Liberty Goodwin, Director

P.O. Box 40441, Providence, RI 02940

Tel. 401-351-9193, E-Mail: TIP@toxicsinfo.org

EXCERPTS FROM PHYSICIAN'S GUIDE TO PESTICIDE POISONING

(Indicating lack of easily available information on toxic “other ingredients) and the need to improve disclosure requirements for public safety and health considerations)

Net Contents and ingredient statement

The front panel of the label shows the net contents that is, how much product is in the container. Each label also must list what is in the product. the list shows active and inert ingredients. It also shows the amount of each.

Active ingredients are the chemicals that control the target pest. they must be identified by their chemical name or official common name. Most products also have inert (inactive) ingredients. These do not act on the target pest. However, they may contribute to poisoning (See Toxic Inerts later in this chapter).

Signal Word

Every label has a signal word required by the EPA. These are "DANGER," "WARNING" "CAUTION." This word gives a signal of how dangerous the product is to humans. The signal word does not tell the risk of delayed effects or allergic reactions. The signal word appears in large letters on front of the label usually next to the statement, "Keep Out of Reach of Children," which is required on every product.

DANGER. This word signals that the pesticide is highly toxic, or could cause severe eye or skin injury. Highly toxic pesticides also carry the skull and crossbones symbol and the word POISON printed in red. Pesticides than can badly damage the skin or eyes may have the signal word DANGER without the word POISON.

WARNING signals any product that is moderately toxic.

CAUTION signals any product that is slightly toxic.

All DANGER labels must include a section of First Aid Treatment, Poison Signs or Symptoms, Note to Physicians (or Antidote), and an Emergency Assistance Call telephone number. WARNING and CAUTION labels may have only an Emergency Assistance Call telephone number. Table XV lists statements on DANGER labels that are valuable aids to physicians and other health care professionals. These are not all in the same place. See Table VI for relative positions of each of these statements.

Physicians should advise patients with suspected pesticide poisoning to bring the pesticide label with them. This is very important. The pesticide label can provide the physician will most of the information necessary to save the life of someone suffering from pesticide poisoning. Without the label, treatment of many pesticide poisonings will be like shooting in the dark.

STATEMENTS OF FORMULA

Pesticide formulations consist of a blend of ingredients. On the label, the active ingredients are usually the only ones listed. The rest of the ingredients are inert ingredients. These are listed for registration purposes in the confidential statement of formula. Physicians or the general public seldom, if ever, are made aware of inert ingredients in pesticides. Only the active ingredients are listed in packaging and on MSDS sheets. An exception is in the EPA policy on toxic inert ingredients.

In the Confidential Statement of Formula, EPA requires the registrant to list all ingredients that go into a pesticide formulation. These ingredients include all active and inert ingredients, the weight per batch, the percentage in the formulation, and sources of the ingredients. Table XXII shows a facsimile of EPA Form 8750-4 with a Confidential Statement of Formula.

The CSF is exactly what it says confidential. Only the registrant and the EPA knows what is in it. It is not available to the public, medical professionals, or emergency personnel. It takes special emergency requests for information, primarily to the registrant to get medical information on the ingredients in a pesticide. CSF information on formulations that may contribute to poisoning or create a health hazard in those exposed to a pesticide is not easy to get. Sometimes, it is impossible to get, particularly when formulators use inert ingredients from suppliers who do not divulge their contents and regard them as trade secrets.

Know how to use pesticide labels

It is extremely important for physicians to know how to use the label on pesticide products to get information from manufacturers. All DANGER labels will have emergency "hot line" numbers for medical personnel to call. This is the only way to get information on medical treatment for chemicals not listed in the active ingredients. It is the ONLY way to get information on toxic inert ingredients.

TOXIC INERT INGREDIENTS

Pesticide active ingredients are not the only part of a pesticide formulation that may pose health hazards. Until 1987, unstated ingredients on the label also posed significant health hazards to poisoning victims. On April 22, 1987, regulations published in the Federal Register required pesticide registrants to add warnings.

EPA developed several lists of inert ingredients included in pesticide formulations that required specific warnings. We include toxic inerts on EPA List 1 and List 2. These are in Tables XXIII and XXIV. List 1 contains toxic inert ingredients with known toxicities. List 2 contains toxic inert ingredients with undetermined toxicity and a high priority for testing. Only ingredients on List 1 required the following warning on the front panel of the label. The warning will be near the ingredient statement in a type size comparable to that found in other front panel statements

Table XXII shows the inerts of toxicological concern in List 1.

Because of concern that some inert ingredients in pesticide products might cause adverse effects to humans or the environment, EPA developed a strategy for the regulation of inert ingredients.

Table XXIII shows the inerts of toxicological concern as List 2.

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STATEMENT BY TIP

NOTE THAT ALTHOUGH LIST 2 CONTAINS POTENTIALLY TOXIC INERTS WITH A HIGH PRIORITY FOR TESTING, NO WARNING STATEMENT HAS BEEN REQUIRED FOR ANY OF THEM - AND NO INDICATION FOR PHYSICIANS ON WHAT MIGHT BE CAUSING A DANGEROUS REACTION TO A PRODUCT. WHILE THE LATTER ARE TRYING TO FIND OUT WHAT THE TOXIC MAY BE, THE PATIENT COULD DIE.

Also, some of the chemicals mentioned in List 2 are really generally recognized as toxic and apt to cause allergic or asthmatic effects, in addition to some being carcinogenic and banned in some places. Toluene, Xylene, Methyl Bromide, Phthalates, etc. are hardly harmless components of these products.

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Most of the chemicals on List 2 have been designated for testing through several government agencies. EPA has been reluctant to register any formulation with inert ingredients on list 2. However, to date, no "toxic inert warning statement" has been required for inert ingredients on List 2.

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FOR MORE ONLINE INFORMATION ON TOXIC INERTS SEE:

www.pesticide.org/inertspage.html

www.epa.gov/opprd001/inerts/

http://pubs.acs.org/subscribe/journals/esthag-w/2005/sep/science/rr_inerts.html

(Includes reference to POEA in Roundup)

http://www.getipm.com/thebestcontrol/physicians_guide/section-II.htm#TOXIC%20INERT%20INGREDIENTS

(Info for Physicians about toxic inerts in pesticides)

www.oag.state.ny.us/environment/inerts96.html

(Info from NY Attorney General’s office)

www.safe2use.com/ca-ipm/01-02-22.htm

(Action by NY, CT, MA & Alaska re: fuller disclosure on labels)

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