~< - • -~· ~ • - I ... - j 0 t1l f' '"'"\ - .·', I UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON, D.C. 20460 DEC I f 1990 Rep. James Mcclure Clarke One north Pack Square OFFICE OF F>ESTICIPES ANO TOXIC SUBSTANCES suite 434 Asheville, North carolina 28801 Response to Freedom of Information Act Request Submitted by Ms. Elizabeth Iglesias 7 o 9 J 7 e:. s--- s-o'( )··Dear Rep. Clarke: R.I:;: \: : .__ r I am enclosin9 a 1ist of all pesticide active ingredients and the most recent list of chemicals used as inert ingredients in pesticides which Ms. Iglesias had requested. I also am enclosing a eopy of "The Federal Insecticide, Fungicide, and Rodenticide Act as Amended" (FIFRA). Be1ow, r wi11 try to answer her questions/requests: 1. Ia hazardous waste leqally allowed by B~A ~o be recycled into pesticides as inert inqredient.s, contami:ttants, active inqredien~s or otherwise? Zf hazardous was~a is to ba recycled into pesti~i4a products, what are .--·-.--·) I allo•ed the products, what specific hazardous was~e :i.s beinq .•..••. -······--·~········· -· ( ...•.-· recycled and who generates these was~es? Hazardous waste is legally allowed by EPA t·o be recycl9d into peeticidee ac woll ~G other commodities under certain circumstances and on a case-by-case basis (see Chapter 40 of the Code of Federal Regulations, Part 261, Sections 261.2 and 261.6 which is enclosed). To date, I have not been able to determine if any pesticide pr~duct registered with EPA contains recycled hazardous waste as an ingredient (see Subpart c--Pro~uot Chemistry Data ReqUirements, Part 158, Chapter 40 of the Code of Fede~al Regulations) • • . .; .~; 2. ' . Has EPA allowed ehlordane to ba used ··a.s an inert or as a eontaminant in other pesticide formulations? The only commercial use of chlordane products still permitted is for fire ant control in power transformers. The salet distribution and shipment of existing stocks of all cancelled chlordane products has been prohibited in the United states since April 15, 1988 (see entry for chlordane in "Suspended, cancelled, and Restricted Pesticides" which was sent to you previously). 3. Is low-level radioactive waste desiqnated as "Below Regulatory Concern," either currently or in the future, being permitted by EPA for use in pesticides? Low-level radioactive waste designated as "Balow Regulatory concerntt is not being penni tted by EPA for use in pesticides. 4. "1 request the final twelve necropsy reports from tumor studies done on rats which survivad the longest during registration teats for Dow Chemical's Dursban product. I am informed that these studies, which are required for registration, were never given to EPA. Xf this is the case, is Dursban illegally registAred or its prcduet. without );Sroper registration?" I am enclosing a listing of all studies submitted by Dow chemical Company on chlorpyrifos, the active ingredient in oursban and Part 158--0ata Requirements for Registration from Chapter 40 of the Code of Federal Regulations. section 6 (a) (2) of FIFRA says that "if at any time after the registration of a pesticide the registrant has additional factual information regarding unreasonable adverse effects on the environ~ent of the pesticide, he shall s"Qbmit such in~ormat1on to the Administrator." If such information l.S not submitted, the registrant is in violation of the Act. any questions, please contact me. My telephone If y ou have ) 557 _ 443 7 or (703) 557-2805. Please refer to the ~~::~t i~d~~~ification Number (RIN) when contacting me about ~~·~1o reqUest. ~\ 1 }P sincerely, /~_·u~ Michael Yanchulis PUblic Response Section Field Operations Division office of Pesticide Programs Enclosures {JIJ C