• LIving Near Fields Increases Pesticide Exposure
  • Learn About Pesticides in Foods
  • SNAP Display at Event
  • SNAP Tour of Organic Vegetable Garden
  • Link to SK Organic Resources
  • Grow a Lush Garden Organically
  • Driving Near Recently Sprayed Fields Exposes People to Pesticides
  • Learn to Keep Insects Out of your Crops
  • Learn To Manage Weeds Without Chemical Pesticides
  • Weeds Can Be Managed Without Chemical Pesticides

General

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Formulants (called Inerts in the U.S.): 'any substance or group of substances other than the active ingredient (AI) that is intentionally added to a pest control product to improve its physical characteristics (e.g. sprayability, solubility, spreadability or stability)' (definition from PMRA Reg2004-01) Formulant ingredients are present in virtually all pesticide products. They are substances added to pesticides to make them more potent or easier to use, but their identities are often claimed as confidential and they have only minimal testing requirements.

versus Active ingredient (AI): the actual pesticide registered to be active in the formulation.

Why worry about formulants?

Formulants make up the largest part of most pesticicide formulations, especially domestic ones for home owners.

While the list includes several non-toxic products, many of the chemicals currently used are known or suspected toxins such as chemicals related to windshield washing fluid, endocrine disrupting substances such as phthalates (recently banned inplastic bottles) and various petroleum solvents including known cancer-causing benzene, toluene and xylene.

Furthermore, high levels of Volatile Organic Compounds (VOCs) (4-200 mg/m3) have been measured up to 4 hours after spraying indoors. Studies of healthy young adults have noted that VOC concentrations of 25mg/m3 of air or below are associated with headache, fatigue, and eye and throat irritation. 

In Canada, as in the U.S. most of these formulants/inerts are still secret. Most of the work on formulants / inerts has been done in the U.S. As you see below, the disclosure battle is not yet won.

Inerts and Health   “Health problems caused by the socalled inert. ingredients in pesticides may be quite common but are rarely documented because there is so little publicly available information about them.”   Reported health effests most likelyrelated toiners/fromulants include: asthma, pneumonitis, respiratory, neurological and fertility problems, and unexpected Symptoms,   JPR, Volume 21, No. 2, Summer 2001, p. 21.

Inert Ingredients: Who's Keeping Secrets? PDF JPR, Volume 19, No. 3, Fall 1999

Are "Inert" Ingredients in Pesticides Really Benign? PDF JOURNAL OF PESTICIDE REFORM/ SUMMER 1999 • VOL.19, NO. 2  Despite lack of testing, many inerts pose known hazards. About a quarter of inerts have already been classified as hazardous by state, federal, and international agencies.

Toxic Secrets: Ingredients in Pesticides, 1987-1997 PDF from Californians for Pesticide Reform (1998) This document analyzed the success of the 1987 EPA's policy to "reduce the potential for adverse effects" and "encourage the use of the least toxic inerts available". It found that 26% of the inerts used were identified as hazardous. The analysis also showed that manufacturers would rather switch to an alternative inert / formulant or even discontinue a product than disclose the use of a toxic chemical as an inert. Disclosure requirements clearly encourage use of least toxic ingredients in pesticide formulations. This document has been particularly useful because of its list of known hazardous ingredients by CAS numbers which allows comparisons between countries and lists.

Hidden Toxic ‘Inerts’: A Tragicomedy of Errors  JPR Vol. 17, 2, 1997, p.10. At the time and until the new  Pest Control Products Act (Canada) (2006), pesticide active ingredients could be added to pesticide formulations as preservatives without being marked on the label.

Secret Inert Ingredients JPR Vol. 12, 3, 1992   p2 Basic information on inerts / formulants.

Safe Haven for Pesticide Toxins: List 3 Inerts (JPR/Volume 9, No. 4, Winter 1989/1990, p.6)

 

Canada

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As the Pest Management Registration Agency's web site may be difficult to use, and the documentsmay be large and cumbersome the following summary may be of help:

The number of formulants allowed in pesticide products in Canada dropped from 1588 formulants (REG 2004-01) to1379 (2007), of which 74 (5.38%) had no CAS identification number. The 2010 list increased that number to 3173 products of which 4 were in list 1, 593 in list 2, 1393 in list 3, 464 in list 4A and 716 in List 4B. 

Of  these 3173 formulants, only 25 have to be listed on labels with the 9 allergens subdivided in 35 formulants for a total of 51 (1.6%) formulants that have to be listed on labels The 593 list 2 (potentially toxic) formulants remain secret, as do known toxins in other categories.

Formulants list analysis. Paule Hjertaas attempted this task twice and saw the llist changed before the analysis was produced which made it obsolete. It would be a very time consuming work to compare each formulant to all lists of banned or dangerous products in the US, Canada and Europe. It is beyond my capacity to accomplish at this time. 

 

PMRA references

List of Formulants 2010 replaces List of Formulants 2007 which is no longer available on the internet  which, in turn, replaced Regulatory Note REG2005-01, PMRA List of Formulants. In this version, a list of formulant trade names, usually formulant mixtures, has been added to the list of single substance formulants.

Regulatory Note: PMRA List of Formulants (March 31, 2005, ISBN: 0-662-39992-7 (0-662-39993-5) Cat. No.: H113-7/2005-1E (H113-7/2005-1E-PDF) (REG2005-01) The full document can no longer be accessed directly. An electronic copy must be ordered.

PMRA- formulants_policy_memo-e 8-05 indicates that only allergens( 9 substances making 35 formulants) and preservatives (which are all active ingredients) have to be listed on labels. 

Order Amending the List of Pest Control Product Formulants and Contaminants of Health or Environmental Concern (2008) lists the 25 formulants (including allergens) that have to be listed on labels.

List of Pest Control Product Formulants and Contaminants of Health or Environmental Concern (Nov. 2005)

List of Pest Control Product Formulants and Contaminants of Health or Environmental Concern under the new Pest Control Products Act. (Notice of intent) (NOI2005-01) (June 2005)  This means the public will be able to have access to information on the identity and concentration of substances on this List. It applies the directives of the Toxic Substances Management Policy (TSMP) and the Montreal Protocol to formulants that meet the criteria of these policies.

U.S.

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72 Toxic Inert Ingredients No Longer Used in Pesticide Products Cancelled, 300 Others Still Not Listed on Labels  (Beyond Pesticides, December 23, 2016)  The Environmental Protection Agency (EPA) has finalized a proposal to ban 72 inert (or secret hazardous) ingredients from use in pesticide formulations following a long fight with environmentalists who, in 2006, asked that pesticide product labels disclose any of 371 inert ingredients that could be in products. SNAP Comment: 'Inerts' are called 'formulants' in Canada. Meanwhile in Canada, the List of Formulants 2010 is still current. (/Canada). It lists 3173 formulants, of which only 25 have to be listed on labels with the 9 allergens subdivided in 35 formulants for a total of 51 (1.6%) formulants that have to be listed on labels The 593 list 2 (potentially toxic) formulants remain secret, as do known toxins in other categories.

Public Comment Needed for Inert Ingredient Disclosure Guidelines (Beyond Pesticides, December 23, 2009) On October 1, 2009, EPA responded to two petitions; one by Northwest Coalition for Alternatives to Pesticides, and a second by several state attorneys general, that designated more than 350 inert pesticide ingredients as hazardous. The petitioners asked EPA to require that these ingredients be identified on the labels of products that include them in their formulations. 

EPA announces plan to require disclosure of secret pesticide ingredients Environmental Health News (Dec. 23. 2009) In September, the EPA denied that part of the petition, preferring to enact a new rule and saying that the chemical-by-chemical approach was not practical and “would potentially result in numerous challenges regarding individual products.”

Inert Use Information | InertFinder | Pesticides | US EPA

Following is what industry lawyers say about inert disclosures: Protection of Confidential Inert Ingredient Information in a World of Disclosure (This article appeared in the January – March 2010 issue of the Chemical Producers and Manufacturers Association's “CPDA Quarterly”)

Toxicity

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Co-Formulants in Glyphosate-Based Herbicides Disrupt Aromatase Activity in Human Cells below Toxic Levels  (Int. J. Environ. Res. Public Health 2016, 13(3), 264; doi:10.3390/ijerph13030264)  All co-formulants and formulations were comparably cytotoxic well below the agricultural dilution of 1% (18–2000 times for co-formulants, 8–141 times for formulations), and not the declared active ingredient glyphosate (G) alone. The endocrine-disrupting effects of all these compounds were measured on aromatase activity, a key enzyme in the balance of sex hormones, below the toxicity threshold. Aromatase activity was decreased both by the co-formulants alone (polyethoxylated tallow amine—POEA and alkyl polyglucoside—APG) and by the formulations, from concentrations 800 times lower than the agricultural dilutions; while G exerted an effect only at 1/3 of the agricultural dilution. 
Report Links Pesticide Exposure to Globally Declining Amphibian Population 3/8/2013 12:02:41 PM By Victoria Pitcher. Link to full scientific report. Effects were not restricted to a specific class of pesticides and seem to be influenced not only by the active substance but also the formulation additives   Whereas the commercially available Headline formulation caused 100% mortality just after 1 h at the label rate, the formulation with the lower naphta content (BAS 500 18F) revealed 20% mortality at the label and 10× label rate.formulation...Differences in the formulation additives revealed a great influence on toxicity, indicating the need to expand the evaluation from active chemical ingredients to entire products
 
Major Pesticides Are More Toxic to Human Cells Than Their Declared Active Principles  (BioMed Research International Vol. 2014, Feb 26, 2014), see SNAP risk assessment page for more detail. Study includes RoundUp. "Adjuvants in pesticides are generally declared as inerts, and for this reason they are not tested in long-term regulatory experiments. It is thus very surprising that they amplify up to 1000 times the toxicity of their APs in 100% of the cases where they are indicated to be present by the manufacturer (Table 1). In fact, the differential toxicity between formulations of pesticides and their APs now appears to be a general feature of pesticides toxicology. between formulations of pesticides and their APs now appears to be a general feature of pesticides toxicology. As we have seen, the role of adjuvants is to increase AP solubility and to protect it from degradation, increasing its half-life, helping cell penetration, and thus enhancing its pesticidal activity 32 and consequently side effects. They can even add their own toxicity 1. The definition of adjuvants as “inerts” is thus nonsense; even if the US Environmental Protection Agency has recently changed the appellation for “other ingredients,” pesticide adjuvants should be considered as toxic “active” compounds." "This inconsistency between scientific fact and industrial claim may be attributed to huge economic interests, which have been found to falsify health risk assessments and delay health policy decisions 41." detailed effects of several adjuvants in 4. Discussion.

Former Undisclosed Ingredients in Pesticide Products Found in Fish, Birds, and Dolphins  (Beyond Pesticides, October 4, 2016) The compounds, perfluroalkyl phosphinic acids (PFPIAs) (CAS number 68412-69-1) were widely used as anti-foaming agents in pesticide formulations until 2006, when the U.S. Environmental Protection Agency took regulatory action to cancel their use, citing “human health and environmental risks of concern.” However, the chemicals continue to be used today in consumer goods, including carpet cleaning formulas...Researchers detected the presence of PFPIAs in the blood of 100% of animals sampled.“Previous work have shown perfluorophosphinic acids are found in human blood samples from North America and Germany, and 83% of household dust samples. SNAP NOTE: Inerts are called Formulants in Canada. We have little more information than the US on formulants as so few of them have to be disclosed on labels, but there is a list of allowed formulants. Interesting that PFPIAs are considered too dangerous for pesticide formulations inthe USbut still used in carpet cleaning formulas and other uses. A good example of how inadequate the regulatory system isPFPIAs are still listed in the current (as of October 2016) 2010 List of Formulants in Canada: 068412-69-1 PHOSPHINIC ACID, BIS(PERFLUORO-C6-12-ALKYL) DERIVATIVES  List 3

When It Comes To Food, “Generally Recognized As Safe” May Not Mean What It Sounds Like (ConsumeristAugust 24, 2016 By )

GRAS Substances can also be included as formulants in pesticide formulations. This is interesting new information of what GRAS means. Not much as it turns out. Also, I am sure the whole testing is plagued by old thinking that the dose makes the poison, which has been proven false in many cases. However. I assume there is little or no independent testing for endocrine effects on substances generally recognized as safe. The priority would be elsewhere. 

In Canada, GRAS substances would be under list 3 or 4B of the List of Formulants
List 3: List 3 contains formulants that do not meet the criteria of any of the other lists.
List 4A: List 4A contains formulants that appear on the US EPA Minimum Risk Inerts List, which are generally regarded to be of minimal toxicological concern, as well as substances commonly consumed as foods.