PANUPS: Active "Inert" Ingredients

                         P A N U P S
                   Pesticide Action Network 
                        North America
                       Updates Service
                   EMAIL: panna@panna.org

July 28, 1997

"Inert" Pesticide Ingredients Pose Hazards

At least 382 of the chemicals on the U.S. Environmental 
Protection Agency (EPA) list of pesticide inert ingredients 
are or were once registered as pesticide active ingredients. 
According to the Northwest Coalition for Alternatives to 
Pesticides (NCAP), a group currently undertaking a study of 
pesticide ingredients, these pesticidal substances can be 
used legally in pesticide products without being listed on 
the product label. There are approximately 2,500 inerts on 
EPA's list.

U.S. pesticide law defines an inert as any ingredient in a 
pesticide product other than the active ingredient. Inerts 
are added to perform a variety of functions, including 
dissolving a pesticide, helping it stick to its target or 
increasing the pesticide's efficacy in some way. Active 
ingredients are defined as chemicals which "prevent, destroy, 
repel or mitigate any pest." Federal law requires that active 
ingredients be listed on the label, but inerts -- which can 
comprise up to 99% of the product -- may remain secret.

NCAP's findings indicate that EPA allows manufacturers to use 
certain active ingredients as though they were inerts -- NCAP 
calls these substances "active inerts." According to NCAP, 
the fact that so many "active ingredients can be used legally 
in pesticide products without being disclosed on the label 
constitutes a major oversight by EPA."

In 1987, EPA announced an inerts strategy it said was 
"designed to reduce the potential for adverse effects from 
the use of pesticide products containing toxic inert 
ingredients." Central to the strategy was the creation of 
four toxicity categories. List 1, "Inerts of Toxicological 
Concern," includes carcinogens, teratogens and neurotoxins. 
EPA stipulated that no new products could use these toxic 
inerts and that, in existing products, their use and a 
warning must be disclosed on the label. List 2, "Potentially 
Toxic/High Priority for Testing," is made up of chemicals 
that are structurally similar to List 1 inerts and/or that 
had incomplete data sets. List 3 is called "Inerts of Unknown 
Toxicity" and List 4 contains substances generally regarded 
as innocuous. Inert ingredients on Lists 2, 3 and 4 are not 
required to be listed on product labels. 

Approximately 70% of the active inerts are found on List 3, 
"Inerts of Unknown Toxicity" -- 264 out of the 382 active 
inerts. Included in the list are: 
-- naphthalene, an insecticidal fumigant that is a common 
component of mothballs. According to U.S. Health and Human 
Services, it can cause brain damage, convulsions and death in 
-- chlorothalonil, a fungicide and a probable human 
carcinogen according to the U.S. EPA) and 
-- chloropicrin, a fumigant and respiratory tract irritant 
that can cause asthma, pulmonary edema, bronchopneumonia and 

Butylated hydroxyanisole (BHA) is also among the 1,981 
pesticide inerts included on List 3, "Inerts of Unknown 
Toxicity." However, in 1987 the International Agency for 
Research on Cancer (IARC) classified BHA as a possible 
carcinogen, and according to EPA's own criteria, chemicals 
that have been assessed as known, probable or possible 
carcinogens by IARC qualify for List 1. This discrepancy is 
particularly troubling because BHA is a commonly used 
antioxidant in butter, vegetable oils, cereals, baked goods, 
potato chips, meat products and many other foods.

In 1997, IARC classified two commonly used inerts as known 
carcinogens: crystalline quartz silica and cristobalite. 
Neither is required to be listed on pesticide product labels, 
and, based on information obtained by NCAP from a Freedom of 
Information Act request to EPA, crytalline quartz silica can 
be found as an inert ingredient in at least 1,560 pesticide 

NCAP is calling on EPA to revise their inerts policy to 
include the required listing of all ingredients on product 
labels regardless of toxicity. In addition, NCAP states that 
all chemicals used in pesticide formulations must be subject 
to the same health and safety testing requirements as active 
ingredients. Under U.S. law, EPA must disclose the identities 
of pesticide ingredients that pose "an unreasonable risk of 
injury to health or the environment." However, EPA cannot 
determine whether a chemical poses such a risk when it has 
little or no information.

NCAP will release a more detailed report of their findings 
this fall.

Source: Journal of Pesticide Reform, Summer 1997.
Contact: NCAP, P.O. Box 1393, Eugene, OR 97440; phone (541) 
344-5044; fax (541) 344-6923; email ncap@pesticides.org; 

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