The issue of so-called inert ingredients in pesticides is one NAHMMA has been involved in for more than 10 years. Of particular concern is the lack of disclosure of these ingredients on the labels of pesticide products used in households, despite their health and environmental impacts. NAHMMA first commented on this issue in 2006, as part of a coalition of organizations petitioning EPA. In 2009 we commented on a rulemaking proposal that would require disclosure of inerts:
Office of Pesticide Programs
Re: Docket EPA-HQ-OPP-2009-0635
NAHMMA, The North American Hazardous Materials Management Association, is a membership organization made up of state and local government representatives and waste management professionals dedicated to pollution prevention and reducing the toxicity of the municipal waste stream. As an organization we strongly support the disclosure of so-called inerts in pesticides, and we were a signatory organization to the Northwest Coalition for Alternatives to Pesticides (NCAP) petition in 2006.
There are thousands of collection programs around the country for hazardous waste generated by households and CESQG’s (conditionally exempt small quantity generators), including many operated by NAHMMA members. Programs such as ours endeavor to test, process, store and dispose of all wastes we receive in a manner that is protective of our workers and the environment. When product ingredients are not identified on the label, including ingredients that definitely do pose risks to workers and the environment, our job is made much more difficult.
Many of our members also conduct education programs that focus on teaching the public about the hazards of household products, including pesticides. One important principle of these programs is that users should carefully read product labels, find out the ingredients of products, and understand the hazards of these ingredients. These efforts are frustrated when ingredients are not disclosed on the label.
NAHMMA position is that full ingredient disclosure on pesticide labels is essential to safe and ethical marketing of pesticide products. We believe that the value of health and environmental protection afforded by such a requirement outweighs any burden to the pesticide industry in doing so.
In 2014 EPA released a statement that denied the 2006 petition and dropped the 2009 rulemaking, in favor of non-regulatory actions that they plan to take. A recent news story announces the first such action. A close look at this story shows that EPA is banning 72 ingredients that have been used as inerts in pesticide products- but that none of them are currently in use in the US. EPA also intends to move forward with additional actions on a case-by-case basis, using safety and risk analysis, but considering the slow pace of actions to date, and the likelihood that EPA activities will be greatly curtailed in the near future with the incoming administration, there is little hope that the inerts issue will be resolved any time soon.