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State Coalition Petitions EPA to Require Disclosure of Inert Ingredients

August 17, 2006

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On Aug. 1, 2006, a coalition of 14 states and the U.S. Virgin Islands petitioned the EPA to amend its rules governing the disclosure of inert ingredients on pesticide product labels. The petitioners want the agency to require the disclosure of 360 ingredients for which they claim federal determinations of hazard have already been made under the following legal authorities:
  • Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA);
  • Emergency Planning and Community Right-to-Know Act (EPCRA);
  • Toxic Substances Control Act (TSCA);
  • Resource Conservation and Recovery Act (RCRA);
  • Clean Water Act (CWA);
  • Clean Air Act (CAA);
  • Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA); and
  • Occupational Safety and Health Act (OSH).

Petitioners argue that, because the EPA or OSHA has identified the 360 inerts as hazardous under other statutory authorities, the EPA should require that these inerts be disclosed on pesticide labels, consistent with the requirements the EPA imposes on inerts determined to be of toxicological concern (List 1 inerts).

If the agency does not issue a finding covering all 360 ingredients, then the petitioners ask that the EPA either:
  1. Assess as a group the chemicals identified as hazardous under each statutory authority and determine which groups of chemicals are sufficiently hazardous to require disclosure on products labels; or
  2. Assess individually each of the chemicals included under those authorities and determine specifically which individual hazardous chemicals are sufficiently hazardous to require disclosure on product labels.

The petition is available on the Internet at www.oag.state.ny.us/press/2006/aug/ Petition.As%20Submitted.%208_1_06.pdf. The Northwest Coalition for Alternatives to Pesticides (NCAP) and 21 other environmental and public health organizations filed a similar petition with the EPA on Aug 1, 2006.


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