Chemical Weapons and/or their Precursors
Fluorinated and Fluoride Pesticides

Note: This is not an exhaustive list.
When time allows more information will be added.

Chemical Weapons Precursors for the production of sarin-family nerve agents

Ammonium bifluoride - Wood Preservative - CAS No. 1341-49-7
Potassium bifluoride - Wood Preservative - CAS No. 7789-29-9
Sodium bifluoride - Insecticide; Former EPA List 3 Inert - CAS No. 1333-83-1
Sodium fluoride - Insecticide, Wood Preservative - CAS No. 7681-49-4

... some of the precursor chemicals which are early in the production process and/or are widely produced in industry (and hence not considered suitable for effective monitoring under the CWC [Chemical Weapons Convention]) have been included on the AGL [Australia Group List], because they are either known or suspected to have been sought for CW purposes. Such precursors include: ...the fluoride chemicals ... for the production of sarin-family nerve agents...

14 [potassium fluoride]
24 [hydrogen fluoride]
41 [potassium bifluoride]
42 [ammonium bifluoride]
43 [sodium bifluoride]
44 [sodium fluoride]

Ref: A COMPARISON OF THE AUSTRALIA GROUP LIST OF CHEMICAL WEAPON PRECURSORS AND THE CWC SCHEDULES OF CHEMICALS by Robert J. Mathews. September 1993. Quarterly Journal of the Harvard Sussex Program on CBW Armament and Arms Limitation. Issue No. 21.

Bifluorides are used as a source of the fluorine atom in the synthesis of all of the G-type nerve agents except Tabun, in which the fluorine atom is replaced by a cyanide group. All bifluorides are synthesized from ammonium bifluoride. Ammonium bifluoride is in turn made from ammonium fluoride which is made by the reaction of ammonium hydroxide with hydrofluoric acid (HF.) Ammonia is manufactured on an extremely large scale (>10 million tons per annum in the US) using the Haber process, for which Fritz Haber (who played a major role in the German chemical weapons program in World War I) won a Nobel Prize. Worldwide hydrogen fluoride manufacture is approximately 400,000 tons. The quantities needed for manufacture of a stockpile of G agent would be miniscule in comparison.
Ammonium fluoride is converted to the bifluoride by dehydrating an aqueous solution of ammonium fluoride. The other bifluorides are manufactured by essentially the same process, except that the water, and the more volatile ammonia, are driven off in the presence of a sodium or potassium compound.
Ref: Nerve Agent Precursors: Bifluorides: Ammonium bifluoride, Potassium bifluoride, Sodium bifluoride.

1995 UN Monitoring and Verification of Iraq's Compliance. The organofluorines on this list include (pesticides highlighted in red):
List A (Precursors):
Hydrogen fluoride
Potassium fluoride
Ammonium bifluoride (
Sodium bifluoride
Sodium fluoride
Potassium bifluoride

List B:
PFIB (382-21-8).
Also included are fluoropolymers (e.g. Aflex COP, Aflon COP 88, F 40, Ftorlon, Ftoroplast, Neoflon, ETFE, Teflon, PVDF, Tefzel, PTFE, PE TFE 500 LZ, Haller).
Ref: 1995 - Chemical & Biological Weapons. Fluorine chemicals.

Note from FAN: Sarin, a chemical weapon, was once used as an insecticide:


Int. Pest Control16(6): 4-9; 1974 (REF:45)

Organophosphorus insecticides.

Cremlyn RJW

Abstract excerpt: PESTAB. The article reviews the main types of organophosphorus insecticides. Early examples such as dimefox, tabun, sarin, pestox, and parathion had the disadvantage of high mammalian toxicity...
[Note: dimefox and sarin are fluorinated.]

Sodium fluoride - Wood preservative, EPA List 4B Inert - CAS No. 7681-49-4

February 19,1999. ALCOA Fined $750,000 by Commerce Department For Illegal Chemical Shipments.
-- The Commerce Department's Under Secretary for Export Administration, William A. Reinsch, imposed a civil penalty of $750,000 on Aluminum Company of America (ALCOA) for 100 violations of U.S. export regulations involving shipments of potassium fluoride and sodium fluoride.
-- The penalty results from Reinsch's affirming an administrative law judge's (ALJ) recommended findings in the case. The ALJ found that ALCOA exported potassium fluoride and sodium fluoride from the United States to Jamaica and Suriname on 50 separate occasions without obtaining the required Commerce Department export licenses. The violations occurred between June 1991 and December 1995. The ALJ also found that the company made false statements on export control documents in each shipment.
-- Potassium fluoride and sodium fluoride are controlled because they can be used to make chemical weapons. These chemicals were added to the Department's control list in March 1991, but ALCOA's export compliance program failed to recognize and incorporate the change. There was no indication that in this case the chemicals were used for weapons purposes.
-- Reinsch observed, "This penalty should send the message that there are significant advantages to having an internal compliance program that catches and reports problems quickly."
-- Reinsch's action imposes the maximum civil penalty of $10,000 for each of the 50 shipping without a license violations. He also imposed a penalty of $5,000 for each false statement.
-- Commerce's Export Administration Regulations provide that an administrative law judge administrative enforcement proceedings be conducted by who recommends an appropriate resolution of the case to the Under Secretary for Export Administration. The Under Secretary may affirm, modify, or vacate the ALJ's recommendation. In this case, Reinsch agreed with the findings but modified the penalties recommended by the ALJ. Reinsch's order and the ALJ's recommendations will be printed in the Federal Register.

Ref: Press Release. February 19,1999. ALCOA Fined $750,000 by Commerce Department For Illegal Chemical Shipments. U. S. Department of Commerce Bureau of Export Administration.

Some excerpts from the ALJ's decision published in the

Federal Register, August 5, 1999:

Bureau of Export Administration
[Docket No.: 97–BXA–20]

Re: Aluminum Company of America

On Friday, February 26, 1999, the Federal Register published the Decision and Order issued by the Under Secretary for Export Administration, Bureau of Export Administration, United States Department of Commerce (BXA) on February 19, 1999 (64 FR 9471). However, the Recommended Decision and Order of the Administration Law Judge (ALJ) was inadvertently not included with the Order of the Under Secretary. This notice is to hereby publish the December 21, 1998, Recommended and Decision Order of the ALJ.
Dated: July 21, 1999.
William A. Reinsch,
Under Secretary for Export Administration.

... 9. During the review period, the water treatment facility in Suriname used sodium fluoride to treat drinking water. Sodium fluoride was used by the ALCOA facility in Suriname to treat drinking water for people living in the Suralco refinery area. All of the sodium fluoride exported from the United States to Suriname was used by this ALCOA subsidiary facility and was fully consumed in the water treatment process. ALCOA sold the water treatment facility to the government of Suriname in July 1994. Therefore, Suralco no longer uses any sodium fluoride (See Respondent’s Answer dated January 20,
1998, page 3).

5. All of the potassium fluoride and Sodium Fluoride exports at issue in this case were sent to ALCOA’s refinery operations in Jamaica (Jamalco) and Suriname (Suralco). These refineries are located near bauxite mines. Bauxite is the raw ore for aluminum. The refineries process the bauxite so as to extract aluminum oride (alumina), which becomes the basic feedstock for ALCOA’s metal and chemical businesses. Both refineries were directly controlled by ALCOA during the period June 14, 1991 through December 7, 1995

3. Potassium fluoride is the key reagent used during the refining of alumina from its bauxite ore. Bauxite is crushed and mixed with a caustic soda solution. This solution dissolves the alumina present in the bauxite. Potassium fluoride is used to determine the level of dissolved alumina in the caustic solution. Only a small amount of potassium fluoride is used per metric ton of bauxite processed (see Respondent’s Answer dated January 20, 1998, page 2).

23. On March 13, 1991, through a notice published in the Federal Register, entitled Expansion of Foreign policy Controls on Chemical Weapons Precursors (56 Fed. Reg 10756), the Department of Commerce amended the Commerce Control List of the Export Administration Regulations (currently codified at 15 C.F.R. Parts 730–774 (1997)),2 ‘‘by expanding the number of countries for
which a validated license is required for 39 precursor chemicals
. Under the rule, the 39 chemicals will require a validated license for export to all destinations except NATO member countries, Australia, Austria, Ireland, Japan, New Zealand, and Switzerland.’’ Potassium fluoride and
sodium fluoride were included on the list of 39 chemicals

... Of all the aggravating factors in this case, one is particularly damming—that the Respondent, over a period of four and one-half (4.5) years, made 50 separate exports of potassium fluoride and/or sodium fluoride in violation of the Export Administration Regulations (emphasis added). Importantly, ALCOA is not a new or small company that doesn’t understand the foreign export regulatory process. Quite to the contrary, the Respondent is a large multinational corporation which had a separate division (Export Supply Division) specifically dedicated to receiving requisitions, locating suppliers, purchasing products, and shipping the requested items in accordance with applicable export licensing requirements. Thus, ALCOA’s conduct, under this backdrop, was flatly inexcusable and the fact that the violations were not intentional or willful is only relevant to the fact that a federal criminal indictment was not handed down. Respondent’s failure to comprehend the change in the Federal Register Notice,
given the existence of its Export Supply Division, is also particularly troubling.1 Moreover, the fact that the unlawful shipments consisted of precursors for chemical weapons, regardless of the lack of
any potential diversion in these instances, is not something that should be viewed as a technical oversight and is clearly an aggravating factor.

In mitigation, ALCOA argues that had it applied for the necessary validated licenses, they would have been presumptively granted. This argument misses the point. Over the past 20 years, a terrorist threat has developed to our Republic and our interests aboard. In order to protect our country and our interests, laws and regulations were passed/implemented to allow the government to monitor and regulate the export of precursor chemicals and if necessary, prevent any such exports that pose a clear and present danger. Given the huge number of exports from the United States, how is the government suppose to monitor the export of precursor chemicals if it doesn’t know that the shipments were being made over a four and one-half year period? ALCOA responds that it filed under general license G–DEST and implies that the government was aware of these 50 separate exports over a four and one-half year period (See Respondent’s Answer dated January 20, 1998, page 8). I disagree. The Respondent did not submit any evidence to support this position. The Respondent cannot shift its responsibility to the government to do that which it is legally required to do. Given the volume of such exports and the limited public resources to regulate these shipments, at the refineries of the Respondent’s subsidiary companies in Jamaica and Suriname. Once again, ALCOA misses the point. The crucial point here is that the government was deprived of possible vital information in its fight to control terrorism. In other words, if the world-wide export of chemicals/biological agents were a puzzle being put together by a U.S. Department of Commerce security team, this information constituted 50 pieces of that puzzle that the government did not have. While it turned out that there was no problem, the fact remains that the government did not have the whole picture. Without the whole picture, or in this case, all of the information about precursor chemical exports, catastrophic errors in preventative decision-making could have occurred.

... The Respondent states that anything more than a nominal fine in this case is unreasonable. In support of this position, ALCOA argues that recent BXA enforcement orders based on settlement agreements establish a range from $2,000 per violation to $5,000 per violation, large portions of which were suspended. The Respondent cites the following settlements in support of it’s argument that the government’s proposed $7,500 per violation is excessive and inconsistent with past BXA practice:

... 3. Sierra Rutil America, Inc. case—The Respondent was charged with eight unlicensed exports of sodium fluoride to Sierra Leone over a two year period in violation of § 787.6. The settlement resulted in a $30,000 fine or $3,750 per violation with half of the fine remitted on probation. This case did not involve exports to controlled or affiliated entities.

5. Snytex case—The Respondent was charged with 13 violations of unlawfully exporting hydrogen fluoride in violation of § 787.2. The fine was $65,000 or $5,000 per violation. One half of the fine was remitted for 2 years and then waived if there were no further violations.

6. Palmeros Forwarding case—The Respondent was charged with 10 violations wherein it used export control documents which represented that the Syntex hydrogen fluoride did not need export licenses. The fine was $50,000 or $5,000 per violation with a two year denial of export privileges. The fine was export privilege denial were suspended on probation.

The Respondent argues in mitigation that it has no prior record of violations. I find this argument is entitled to little or no weight given the fact that for four and one-half years, the Respondent committed one hundred violations of the EAR. Indeed, It is not the prior record that is important here, but the
aggravating factor of 100 violations and the Indeed, the government might well have opted to argue in a criminal forum that ALCOA’s conduct was so grossly negligent as to constitute a willful disregard of federal law. In this case, the amount of care demanded by the standard of reasonable
conduct on the part of the Respondent must be in proportion to the apparent risk. As the danger becomes greater, the Respondent is required to exercise caution commensurate
with that increased risk. Since the Respondent was dealing with precursors for chemical weapons, the March 13, 1991 Federal Register Notice constructively put it on notice that it must exercise a great amount of care because the risk is great. It failed to do so.

Importantly, the government voluntarily lowered the sanction bar all the way down to the level of an administrative civil penalty in this case. That having been done, the Respondent argues that the government is being harsh and should lower the bar further. In effect, the Respondent is attempting to have the government negotiate with itself. This is wrong. Based upon the detailed discussion set forth above, I find the appropriate sanction for each of these unlawful shipments is $10,000. The Respondent is a huge multi-national corporation. As such, a $10,000 penalty per violation is minuscule for ALCOA who describes itself as ‘‘one of the world’s leading producers of aluminum.* * *’’. At no time during this proceeding, did ALCOA’s counsel raise financial hardships for mitigating any civil penalty. At some point, ALCOA has to stand up and take responsibility for it’s gross and long-standing breach of legal duty. Conversely, the United States government must set its civil penalties at a high enough level to insure that large multi-national corporations don’t ignore the law and if they get caught, merely consider the fine as a cost of doing business...

Teflon (PTFE: polytetrafluoroethylene) - US EPA Pesticide List 3 Inert - CAS No. 9002-84-0

Excerpts of The Toxicology of Perfluoroisobutene by Jiri Patocka and Jiri Bajgar.
Perfluoroisobutene ... is a fluoro-olefin produced by thermal decomposition of polytetrafluoroethylene (PTFE), e.g., Teflon [1].
Overheating of PTFE generates fumes of highly toxic PFIB and poses a serious health hazard to the human respiratory tract. PFIB is approximately ten times as toxic as phosgene [2]. Inhalation of this gas can cause pulmonary edema, which can lead to death. PFIB is included in Schedule 2 of the Chemical Weapons Convention (CWC), as a result of the prompting by one delegation to the Conference on Disarmament [3]. The aim of the inclusion of chemicals, such as PFIB was to cover those chemicals, which would pose a high risk to the CWC. Subsequently PFIB, specifically, was included in the final text of the CWC.
[1]. Zeifman, Y.B., Ter-Gabrielyan, N.P., Knunyants, I.L. The Chemistry of Perfluoroisobutylene. Uspekhi Khimii, 1984; 53: 431-461.
[2]. Oberdorster, G., Ferin, J., Gelein, J., Finkelstein, R., Baggs, R., Effects of PTFE Fumes in the Respiratory Tract: A Particle Effect? Aerospace Medical Assiciation 65th Annual Scientific Meeting, 1994; 538: A52.
[3]. CD/CW/WP.239. Verification of the Nonproduction of Chemical Weapons: An Illustrative Example of the Problem of Novel Toxic Chemicals. 12 April 1989.
Ref: Toxicology of Perfluoroisobutene by Jiri Patocka and Jiri Bajgar (Department of Toxicology, Military Medical Academy 500 01 Hradec, Czech Republic). The ASA Newsletter (Applied Science and Analysis, Inc.). 1998.

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