Adverse Effects:

This chemical is in the class of perfluoroalkyl sulfonates [PFOS]. On December 9, 2002, EPA stated that the "PFOSH component of these chemical substances may be hazardous to human health and the environment."

In response to comments from Waste Not, EPA stated in the Dec 9, 2002, Final Rule, that this chemical would be removed from the Inerts list. However, EPA's updated List 3 Inerts of August 2004, includes it.

Environmental

PFOA and PFOS are perfluoridated chemicals that are persistent in the environment. They do not hydrolyze, photolyze, or biodegrade under environmental conditions

YES

US EPA List 3 Inert

January 15, 2005. Canada Gazette. Part 1. Vo. 139, No. 3.

Notice with respect to certain perfluoroalkyl and fluoroalkyl substances. Pursuant to paragraph 71(1)(b) of the Canadian Environmental Protection Act, 1999, notice is hereby given that the Minister of the Environment requires, for the purpose of assessing whether the substances listed in Schedule 1 to this notice are toxic or are capable of becoming toxic, or for the purpose of assessing whether to control or the manner in which to control the listed substances, any person described in Schedule 2 to this notice who possesses or who may reasonably be expected to have access to the information required in Schedule 3 to this notice to provide that information no later than April 28, 2005, at 3 p.m. Eastern Standard Time.

SCHEDULE 1 Substances
The substances included in the scope of this notice are those that meet the following criteria: Perfluoroalkyl and fluoroalkyl substances that contain the chemical fragment R-(CF2)n-R', where n is greater than or equal to 3, R is any atom or molecular moiety, R' is any atom or molecular moiety other than H, F or Cl, and any F may be substituted with a perfluoroalkyl group. (Excluding perfluorooctane sulfonate (PFOS), its salts, and its precursors that contain the

1-Propanaminium, 3-[[(heptadecafluorooctyl)sulfonyl]amino] N,N,N-trimethyl-, iodide. CAS No. 1652-63-7 was included in the following list:

14. Perfluoroalkylsulfonamide aminopropyl derivatives

February 27, 2004. Letter from EPA to the French Ministry of Environment.

Re: Notice of Export of 1-Propanaminium, 3(((heptadecafluorooctyl)sulfonyl)amino)-N,N,N-trimethyl-, iodide.

The USEPA "is required by section 12(b) of the Toxic Substances Control Act (TSCA) of 1976 to notify your government when certain chemical substances are exported to your country ..."

Note: This inert is included in the

Perfluoroalkyl Sulfonates; Significant New Use Rule.
December 9, 2002. Federal Register.

"EPA is issuing a significant new use rule (SNUR) under section
5(a)(2) of the Toxic Substances Control Act (TSCA) for 75 substances
including perfluorooctanesulfonic acid (PFOSH) and certain of its salts
(PFOSS), perfluorooctanesulfonyl fluoride (POSF), certain higher and
lower homologues of PFOSH and POSF, and certain other chemical
substances, including polymers, that are derived from PFOSH and its
homologues. These chemicals are collectively referred to as
perfluoroalkyl sulfonates, or PFAS [FAN: now referred to as PFOS]. This rule requires manufacturers and importers to notify EPA at least 90 days before commencing the manufacture or import of these chemical substances for the significant new uses described in this document. EPA believes that this action is necessary because the PFOSH component of these chemical substances may
be hazardous to human health and the environment. The required notice
will provide EPA with the opportunity to evaluate an intended new use
and associated activities and, if necessary, to prohibit or limit that
activity before it occurs."

On July 9, 2002, Ellen Connett (on behalf of Waste Not) submitted comments to EPA at the time this New Use Rule was proposed. One of the questions in this submission:

Does EPA still include this chemical on List 3 Inerts

CAS No. 1652-63-7
PFOS List Name: 1-Propanaminium, 3- [[(heptadecafluorooctyl)sulfonyl]am ino]-N,N,N-trimethyl-, iodide

This was EPA's response on December 9, 2002:

... EPA confirms that none of the PFAS chemicals on the inerts
list identified by Waste Not, including the named chemical without a
CAS number provided, are currently formulated into pesticide products,
and they will all be removed from the EPA List 3 Inerts list the next
time that list is updated. EPA notes that, although these PFAS [FAN: now referred to as PFOS] chemicals will remain on the List 3 Inerts list until that list is updated, the manufacture or import of chemicals listed in this rule for use as inert ingredients in pesticide products would be a significant new use subject to this rule. Although TSCA does not regulate chemicals manufactured for use solely as pesticide active ingredients, chemical intermediates and pesticide inert ingredients are subject to regulation under TSCA ...

Due to EPA's statement, FAN wongly referred to this chemical as a "former inert." A check at EPA's List 3 inerts in March 2005 -- more than TWO YEARS LATER -- reveals that it hasn't been removed. Until we receive clarification from EPA, we have to assume that this chemical is approved for use as a List 3 inert.

Note also that this chemical contains the halogen iodide.

US EPA List of Inerts. This substance is on List 3. - as of March 2005

EPA lists it as: CAS No. 1652-63-7
3-(((Heptadecafluorooctyl)sulfonyl)amino)-N,N,N-trimethyl-1-propanaminium iodide

Note: US EPA allows so-called "Inert" ingredients to be commonly mixed with the "active" pesticidal ingredient to create a formulated pesticide product. According to EPA, "The term `inert' is not intended to imply nontoxicity; the ingredient may or may not be chemically active." "Inert" ingredients include solvents, emulsifiers, spreaders, and other substances mixed into pesticide products to increase the effectiveness of the active ingredients, make the product easier to apply, or to allow several active ingredients to mix in one solution. Both US EPA and California Department of Pesticide Regulation require pesticide manufacturers to identify inert ingredients in their products but do not disclose this information to the general public because the pesticide industry considers product formulations trade secrets, protected by law and by the US EPA. The US EPA category of Inerts (as of September 2003):

List 1 - Of Toxicological Concern
List 2 - Potentially Toxic / High Priority for Testing
List 3 - Of Unknown Toxicity
List 4A - Generally Regarded as Safe
List 4B - EPA states it has Sufficient Information to Reasonably Conclude that the Current Use Pattern in Pesticide Products will not Adversely Affect Public Health or the Environment

See good report: Toxic Secrets": "Inert" Ingredients in Pesticides 1987-1997, published by Northwest Coalition for Alternatives to Pesticides.

Perfluoroalkyl Sulfonates; Significant New Use Rule. FINAL RULE.
EPA is issuing a significant new use rule (SNUR) under section
5(a)(2) of the Toxic Substances Control Act (TSCA) for 75 substances including perfluorooctanesulfonic acid (PFOSH) and certain of its salts (PFOSS), perfluorooctanesulfonyl fluoride (POSF), certain higher and lower homologues of PFOSH and POSF, and certain other chemical substances, including polymers, that are derived from PFOSH and its homologues. These chemicals are collectively referred to as perfluoroalkyl sulfonates, or PFAS. This rule requires manufacturers and importers to notify EPA at least 90 days before commencing the
manufacture or import of these chemical substances for the significant new uses described in this document. EPA believes that this action is necessary because the PFOSH component of these chemical substances may be hazardous to human health and the environment. The required notice will provide EPA with the opportunity to evaluate an intended new use and associated activities and, if necessary, to prohibit or limit that activity before it occurs.

This chemical is one of the 75 affected chemicals.
EPA lists it as
1-Propanaminium, 3- [[(heptadecafluorooctyl)sulfonyl]amino]- N,N,N-trimethyl-, iodide

Perfluorooctyl Sulfonates; Proposed Significant New Use Rule; for the following chemical substances: Perfluorooctanesulfonic acid (PFOSA) and certain of its salts (PFOSS), perfluorooctanesulfonyl fluoride (PFOSF), certain higher and lower homologues of PFOSA and PFOSF, and certain other chemical substances, including polymers, that contain PFOSA and its homologues as substructures. All of these chemical substances are referred to collectively in this proposed rule as perfluorooctyl sulfonates, or PFOS. This proposed rule would require manufacturers and importers to notify EPA at least 90 days before commencing the manufacture or import of these chemical substances for the significant new uses described in this document. EPA believes that this action is necessary because the chemical substances included in this proposed
rule may be hazardous to human health and the environment. The required notice would provide EPA with the opportunity to evaluate an intended new use and associated activities and, if necessary, to prohibit or limit that activity before it occurs.

This chemical is one of the 75 affected chemicals.
EPA lists it as
1-Propanaminium, 3- [[(heptadecafluorooctyl)sulfonyl]amino]- N,N,N-trimethyl-, iodide