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

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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Apparently the List of formulants is getting harder to find and use as has been shown to happen often on government web sites. It is apparently updated twide a year. The new link is at Pest Management Regulatory Agency (PMRA) List of Formulants (March 2019). While the Regulatory Directive is easy to read and has several new sections, the Lists of Formulants are no longer in easy to use table form with several columns indicating the CAS number, name of formulant, and the list it is in. Now you get a hard to read database pdf....Anyhow, the PMRA List of Formulants - Trade Name does give this info. As far as I can see, the first columnis CAS #, then Formulant Trade-Name {Nom-commercial), List-No (No-de-Liste) (1 to 4B).followed by whether it is an Allergen (allergene) or not . N must mean No. It was certainly easier to use in table form and when you could also get the formulants listed according to the list ( degree of toxicity) they are in. 

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

Regulatory Directive: Formulants Policy and Implementation Guidance Document  31 May 2006. This document explains the policy as well as the categorization of Formulants Currently in Use in Canada into lists.

Pest Management Regulatory Agency (PMRA) List of Formulants (last updated on October 1, 2020)

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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also see endocrine disruption

“Inert” Pesticide Ingredients and Failure to Regulate Raise Dangers for All U.S. Residents    (Beyond Pesticides, August 9, 2022) The most widely used pesticide chemicals in the United States are not listed on product labels, yet pose widespread environmental and public health hazards, according to commentary published this month in Environmental Health Perspectives by two veteran researchers. At issue are adjuvants and so-called “inert” (or “other”) ingredients, chemicals that are added to formulated pesticide products, but do not undergo the same safety reviews as the active ingredient in pesticide products.   Researchers first draw a distinction between adjuvant products and inert ingredients in pesticide products. Adjuvants are materials specifically designed to improve the performance of a pesticide spray and are sold separately from formulated pesticide products. Adjuvants are “tank mixed” with a pesticide prior its application. Inert ingredients are any ingredient within a formulated pesticide product that is not designed to prevent, destroy, or repel a pest.   Researchers subsequently zeroed in on the most used material, the adjuvant α-(p-nonylphenyl)-ω-hydroxypoly(oxyethylene) (APNOHO). Over 10 million acres of agricultural land in California is sprayed with APNOHO each year. An analysis in the commentary finds that the little data EPA has produced on APNOHO indicates its hormone disrupting activity is more potent than the active pesticide ingredients and known endocrine disruptors methoxychlor and vinclozolin.     SNAP comment: In Canada, inert ingredients are called formulants. California identifies three CAS numbers for APNOHO: 127087-87-0, 26027-38-3, and 9016-45-9 . All three are  listed in list 2 (Potentially Toxic Formulants with a High Priority for Testing) in the 2021 Canadian list of formulants. It appears that they do not have to be listed on labels. As most formulatns are secret, who knows how much is used in Canada. I never checked if there is a separate lsit of adjuvants. 

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”)

Contaminants

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Report Adds to Evidence of Widespread PFAS Contamination; Calls for Removal of Products   (Beyond Pesticides, May 4, 2023) One of the most widely used insecticides in California, Intrepid 2F, contains harmful levels of per- and polyfluoroalkyl substances (PFAS), or “forever chemicals,” according to a report by the Center for Biological Diversity (CBD) and Public Employees for Environmental Responsibility (PEER). In fact, 40 percent of pesticide products in the report tested positive for high levels of PFASPFAS are common in non-stick cookware, cleaning/personal care products, food packaging, and other consumer products. However, these compounds are also in pesticide products.' Tested products containing PFAs were   the insecticides Malathion 5EC (active ingredient: malathion), Oberon 2SC (active ingredient: spiromesifin)  Intrepid 2F (active ingredient: methoxyfenozide).  SNAP Comment: There are 12 malathion products registered in Canada, 2 methoxyfenozide and 0 spiromesifin.

Despite EPA Safety Assurances, Alarming Levels of PFAS Found in Commonly Used Pesticides  (Beyond Pesticides, October 6, 2022) A new study finds alarmingly high levels of PFAS (Per- and Polyfluoroalkyl Substances) “forever chemicals” in commonly used pesticides, calling into question assurances from the U.S. Environmental Protection Agency (EPA) that contamination is limited to storage containers. For some pesticides, PFAS levels are nearly one billion times higher than the EPA’s recently updated Health Advisory for the PFAS chemical PFOS.    Although the brand names of the pesticides tested were not provided, of the ten products, active ingredients of those found to contain PFAS include: abamectinnovaluronmineral (petroleum) oil, imidaclopridspiromesifen, and malathionThose without PFAS detection include products with the active ingredients Beauveria bassianapyridalylspinosad, and spinetoram/sulfoxaflor.    At the same time as EPA released results on fluorinated containers, the agency announced it is eliminating a set of 12 inert ingredients that could be considered PFAS.  SNAP Comment: I have not yet checked if these formulants/inerts are curently used in Canada.

Producers Warned by EPA that PFAS Is Contaminating Pesticides and Food   (Beyond Pesticides, March 29, 2022) Plastic storage barrels contaminated with polyfluoroalkyl substances (PFAS) may be in violation of the Toxic Substances Control Act (TSCA), according to an open letter released by the U.S. Environmental Protection Agency (EPA) last month. Manufacturers, producers, processors, distributors, users, and those that dispose of fluorinated High-Density Polyethylene (HDPE) containers or other similar plastics that form PFAS as a byproduct were notified in the letter of requirements under federal law. 

EPA Confirms Widespread PFAS Contamination of Pesticides, Announces “Investigation,” Stops Short of Action to Protect Public     (Beyond Pesticides, January 20, 2021) The U.S. Environmental Protection Agency has confirmed that PFAS (per and polyfluorinated alykyl substances) ‘forever chemicals’ are contaminating containers that store pesticide products, and subsequently the products themselves.      According to EPA, high-density polyethylene (HDPE) containers used to store and transport pesticides are commonly treated with fluoride in order to create a “chemical barrier” that will “prevent changes in chemical composition.” The fluorinated container is supposed to be more stable, and “less permeable, reactive, and dissolvable.”    Testing so far has been limited to one pesticide product supplier (likely the company Clarke, maker of Anvil 10+10), but resulted in detection of 9 different PFAS chemicals at levels the agency has not yet released. Earlier testing found PFAS chemicals well above safety limits established by states, as well as EPA’s health advisory.    There are also indications that fluorinated HDPE containers may have other storage uses, such as food packaging. EPA announced that it is subpoenaing the company that fluorinates HDPE containers under the Toxic Substances Control Act, but has done little else from a regulatory standpoint.    Contamination of widely used storage and transportation containers with chemicals that have been linked to cancer, liver damage, birth and developmental problems, reduced fertility, and asthma is a scandal without compare. It is unclear how long such a practice has been commonplace without any regulatory oversight. SNAP comment:.What is important here is that no one seems to have thought that chemicals from packaging cound contaminated the content.leading to potentially massive health and environmental expossure with no monitoring. 'There are also indications that fluorinated HDPE containers may have other storage uses, such as food packaging.'. 'Per- and polyfluoroalkyl substances (PFAS) are a group of water-soluble chemical compounds with an important number of applications, which have been widely used during the last 60 years. Two of them, perfluorooctane sulfonate (PFOS) and perfluorooctanoic acid (PFOA), are the most known and well investigated'. Fact sheet: Perfluorinated chemicals in water. orinated HDPE 

Toxicity

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also see 2,4-D 

Health Implications: Common Herbicide 2,4-D Threatens Most Species Health, Especially Vertebrates   While 2,4-D use had often been replaced by glyphosate, it is making a comeback in formulation with glyphosate for GMO crops. It is also apparently still used in B.C.forestry.    (Beyond Pesticides, April 5, 2022) 'A meta-analysis by the Federal University of Technology – Paraná finds the herbicide 2,4-D causes indiscriminate harm, increasing the mortality rate among exposed animals. The severity of chemical exposure relies on species sensitivity, exposure rate, and lifecycle stage. However, commercial formulations of 2,4-D, commonly used in the environment, prompt a higher species mortality rate than technical (pure) 2,4-D alone. Like many other common herbicides such as glyphosate, 2,4-D has global uses that allow the chemical to accumulate in the environment, including soils, waterways, and tissues of non-target species.  ... vertebrates experience higher mortality rates from 2,4-D exposure, with fish and birds presenting the highest mortality rate.  (2.4-D) is a possible human carcinogen (e.g., soft tissue sarcoma and nonHodgkin lymphoma), can cause neurotoxicities like the development of ALS and loss of smell, kidney/liver damage, and endocrine disruption. The U.S. Environmental Protection Agency (EPA) finds babies born near areas of high 2,4-D use, such as farming communities, have higher rates of birth abnormalities, respiratory and cardiovascular issues, and developmental defects.

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.

Also see wildlife/insects, pesticide drift

Chemicals Added to Herbicides to Reduce Drift Actually Drift Themselves, Are Significant Air Pollutants  (Beyond Pesticides, November 2, 2022) Inert ingredients called “amines” that are added to pesticides in attempts to reduce drift and volatility are themselves highly volatile and may represent a significant source of air pollution, according to research recently published in Environmental Science and Technology.   Large quantities of herbicide-amine mixtures are being sprayed onto crops across the country... Amines are chemical compounds derived from ammonia and often added to herbicide formulations for glyphosate, dicamba, and 2,4-D products to increase solubility and reduce volatilization. In theory, amines reduce volatilization by forming herbicide-amine salts which lock the herbicide vapors in place.   Researchers conducted an experiment measuring amine and herbicide losses from herbicide-amine salts...Generally, more amines than herbicide residues were lost during the drying process, but this shifted slightly under higher temperatures. With increasing heat, researchers found both higher amine releases, and evidence of increased herbicide volatility, reinforcing earlier studies.   With half of glyphosate, 44% of 2,4-D, and nearly 90% of dicamba use employing an amine-based product formulation, the study estimates that herbicide use releases approximately 4,000 metric tons of amines in the US annually. When considering the use of these herbicides in other countries, as US applications account for only roughly 12% of global use, herbicide amine emissions can be compared to the 285,000 metric tons of amines globally recorded as released into the atmosphere each year from other sources, such as industrial manufacturing and livestock emissions.   Despite their listing as an “inert” ingredient, amines are toxicologically active substancesOnce present in the atmosphere, amine vapors oxidize and form nitrosamines and nitroamines, which are potent carcinogens. Their release and transformation in the atmosphere likewise results in the creation of fine particulate matter that can affect heart and lung health.

Secret Inert Ingredient in ‘Bee Safe’ Pesticide Found to Kill Bumblebees     (Beyond Pesticides, November 11, 2021)' Evidence is building that so-called ‘inert’ ingredients in pesticide formulations are harming pollinators and undermining regulatory determinations that designate products as ‘bee-safe.’ According to a new study published in Scientific Reports, the fungicide Amistar causes lethal and sublethal effects that can be primarily attributed not to its active ingredient azoxystrobin, but to alcohol ethoxylates, a co-formulant, or inert ingredient intentionally added to a pesticide formulation.    Further, Amistar’s formulation in Europe may differ from its formulation in the United States and other countries, despite that fact that chemical company Syngenta/ChemChina is the primary registrant in both locations.     Researchers found that bees that weighed more at the beginning of the study were more likely to survive. That is because alcohol ethoxylates were causing sub-lethal impacts that didn’t necessary kill every exposed bumblebee outright.   Dissection after the experiment determined that alcohol ethoxylates were creating dark brown patches in bumblebee guts. This was leading to a range of observable warning signs. “Whilst 30 percent of bees exposed to the fungicide product died, the other 70 percent were far from healthy; they had damaged guts, were eating about half as much food and were losing weight,” said study coauthor Ed Straw, PhD. “Pesticide regulation typically only looks at whether or not a bee dies, but we found that even bees who survive can be under severe stress.”...other research done under field-realistic conditions within the PoshBee project show similar results. This combination of results, enabled by this European-wide project, really supports the idea that co-formulants in pesticides need to be considered more seriously as threats to bee health.”    SNAP comment: In Canada, inerts are called formulants/Canada. The CAS number for alcohol ethoxylates is 84133-50-6. They are listed as a formulant in the latest PMRA formulants list (2017). It is listed in category 4B "formulants of minimum concern under specific conditions of use". Section 4.6:"When a formulant reaches List 4B, no further regulatory action is anticipated unless the use pattern for which it is being considered is beyond that approved, in which case the PMRA will require an independent review". A formulants are still secret except if very toxic or allergens, I suspect there is no listing of alcohol ethoxylates in pesticide formulations or on MSDS sheets. As of 18 November 2021, there are 44 PMRA registered products containing azoxystrobinnone with the name Amistar.

Roundup Shown to Kill Bees—But Not How You Might Expect  (Beyond Pesticides, April 20, 2021) 'Roundup products manufactured by Bayer-Monsanto kill exposed bumblebees at high rates, according to a new study published in the Journal of Applied Ecology, which points to undisclosed inert ingredients (those that typically make up a majority of the product formulation) as the primary culprit.Bumblebees sprayed with consumer use Roundup Ready-To-Use (contains glyphosate) experienced a shocking 94% mortality. Subsequent experiments were conducted at lower application rates for that product, and significant mortality was seen for the 1:1 dilution (98% mortality) as well as the 1:3 dilution rate (78% mortality). The agricultural use Roundup Proactive (contains glyphosate) saw lower rates of death at 30%. Weedol, a glyphosate-based consumer product, displayed a mortality rate (6%) similar to the unexposed control group of bumblebees (4%). However, Roundup Speed Ultra' (containing acetic acid and no glyphosate) 'was found to kill 96% of exposed pollinators.'. SNAP Comment: Interesting that the UK formulation containing acetic acid andno glyphosate was so toxic as this is considered an alternative product. On a glyphosate label search on 20 April 2021, thereare 195 glyphosate products registered as pesticides in Canada. (also registered as an antibiotic- I haven't searched that or other possible uses). The issue with undisclosed inerts, called formulants in Canada, is the same as in the US. There have been many unsuccessful efforts over decades in making them public.

Toxic Levels of Heavy Metals and PAHs Discovered in Some Alternatives to Glyphosate-Based Weedkillers   (Sustainable Pulse, Oct 22 2020)     The formulants (or inerts) are toxic and almost all are still undisclosed in Canada.Link to The Detox Project which supports alternative non chemical weed control such as RootWave (electrical) and FoamStream (heated foam made of natural ingredients).   'Prof. Seralini’s team recently analysed 14 formulations of some of the new alternative chemical herbicides using gold standard mass spectrometry. Heavy metals were detected at toxic levels of up to 39 mg/L, including iron, lead, nickel, silicium, titanium and arsenic. Carcinogenic polycyclic aromatic hydrocarbons were also detected, at levels up to 32–2430 μg/L in 12 of the herbicides studied.   Sustainable Pulse Director, Henry Rowlands, stated; “These results show that the difference between “active ingredient” and “inert compound” is a regulatory assertion with no demonstrated toxicological basis and thus an immediate ban on both these specific new alternative herbicides and glyphosate-based herbicides is required.”'

Ignoring Adjuvant Toxicity Falsifies the Safety Profile of Commercial Pesticides   (Robin Mesnage and Michael N. Antoniou, Frontiers in public Health,  22 January 2018)   SNAP comment: Canada and US regulatory system is based on the outdated principle of 'the dose makes the poison', not precaution. This whole concern about adjuvants (also called formulants or inerts) could start with total disclosure in ALL pesticide formulations. They are currently secret except for a few allergens and a few very toxic ones.   ' Despite the known toxicity of adjuvants, they are regulated differently from active principles, with their toxic effects being generally ignored. Adjuvants are not subject to an acceptable daily intake, and they are not included in the health risk assessment of dietary exposures to pesticide residues... Urgent action is needed to lift the veil on the presence of adjuvants in food and human bodily fluids, as well as in the environment (such as in air, water, and soil) and to characterize their toxicological properties. This must be accompanied by regulatory precautionary measures to protect the environment and general human population from some toxic adjuvants that are currently missing from risk assessments.'

Toxicity of formulants and heavy metals in glyphosate-based herbicides and other pesticides  (Toxicol Rep. 2018; 5: 156–163, Published online 2017 Dec 30)   SNAP Comment: I am sure Seralini’s study is accurate, however he works in France and of most of the products listed on the chart, few appear registered under these names in Canada. It doesn’t mean there is no heavy metal contamination in Canadian products, but simply that no one looked. I suspect that, with the low concentrations identified, heavy metals are more contaminants than formulants.  'In Fig. 6, we observe that the sum of heavy metals in formulations after their different recommended dilutions can reach up to 80 ppb.'    Glyphosate herbicides under Glyphosate Isopropylamine Salt (https://www.trc-canada.com/product-detail/?G765004} have the following listed under synonyms: Bayer Glyphosate Concentrate (same as Bayer GC), Clinic E.V, Glyfos AU; Glyfos BIO (same as Glyfos?), Glyphogan) but all listed under the same CAS number 38641-94-0   Other herbicides: 6160 2,4-D products registered but 0 under 'Lonpar', 0 Isoproturon and 0 Fluoroxypyr.  Fungicides: 18 Folpet products registered including 3 under “Folpan’, 0 under Prochloraze, 32 Tebuconazole products but 0 under 'Maronee', 0 Epoxiconazole, 13 Boscalid products but 0 under 'Pictor', 3 Fenhexamid products including 0 under 'Teldor'.  Insecticides: 29 Chlorpyrifos products including 3 under ‘Pyrinex’, 0 Acetamipride

Take Action: What’s In the Bottle, Bag, or Box Is Not Tested Fully for Adverse Effects  (Beyond Pesticides, March 17, 2019)   'Forget about single-pesticide issues: this affects every single one of them. EPA is allowing massive data gaps to persist for each and every pesticide product it registers by conducting the bulk of its health and environmental risk assessments using active ingredients alone. With its current practices, EPA is failing its federal mandate to protect public health and the environment and misleading the public about what is “safe.”   Based on EPA’s current policies, the agency does not require any testing on the health effects of pesticide products, as commonly applied, in the areas of chronic toxicity, carcinogenicity, mutagenicity, developmental and reproductive toxicity, or subchronic oral toxicity, inhalation toxicity, and neurotoxicity. Nor does it require any testing on the effect of whole pesticide products on avian oral toxicity, avian dietary toxicity, avian reproduction, freshwater aquatic invertebrate life cycle, freshwater fish early-life stage, or honey bee acute contact toxicity.  To put it another way: EPA has no idea whether the pesticide products it registers and claims pose an “acceptable risk” could cause cancer, chronic disease, developmental delays, or infertility. EPA has no idea whether the pesticide products it registers could harm or kill birds, fish, aquatic invertebrates, or honey bees. These data gaps are alarming and unacceptable, and a misinterpretation of the law.'

 SNAP Comment: Same is done in Canada. more info under Inert ingredients (called formulants in Canada)/Canada including updated links to the PMRA web site links on formulants.

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.