Comments Sought on the Disclosure of Inert Ingredients in Pesticides

On December 23, 2009, the Environmental Protection Agency (EPA) published a federal register notice seeking public comments on the disclosure of inert ingredients in pesticides.  EPA responded to two petitions, one from 22 non-governmental organizations and the other from Attorneys General of 15 U.S. States and territories. The petitions identified hazardous inert ingredients and argued that the public would be served by disclosing these inert ingredients to consumers. They said that this disclosure would allow consumers to make informed decisions regarding product safety and environmental protection. EPA’s federal register notice requests comments on reasons and methods for disclosure, not just for hazardous inert ingredients, but for all inert ingredients in pesticides. Public comments on the notice are due no later than February 22, 2010.

Inert ingredients are the many chemicals that are present in pesticides (products for controlling weeds, insects, plant diseases, and vertebrates as well as disinfectants). The so-called inert ingredients are chemicals or mixtures of chemicals in pesticides that serve a purpose other than pest control; i.e. they may be solvents, emulsifiers, etc. Many are, in fact, quite hazardous to human health or the environment.  Generally, inert ingredients are considered proprietary information and are not required to be disclosed to purchasers on product labels. Information about inert ingredients is difficult, if not impossible, to obtain from manufacturers. 

MOA supports full disclosure of all inert ingredients to the purchaser at the point of sale. This provides information that buyers can use in selecting products that are safer to people and the planet. Failure to provide this information disrupts free choice and creates artificial market flow.  Educated choices by buyers can constitute a vote for safer products, and market flow should be more favorable to these products. Organic producers and handlers will benefit from full disclosure of inert ingredients as they make decisions about allowed inputs in their organic systems.

EPA would like to hear from you, and MOA encourages your comments. You can view the regulation and submit comments electronically by following instructions at http://www.regulations.gov 

Or you may submit comments by mail to:
Office of Pesticide Programs Regulatory Public Docket (7502P)
Environmental Protection Agency
1200 Pennsylvania Avenue NW
Washington DC 20460-0001
Comments must be identified by docket identification number EPA-HQ-OPP-2009-0635