Mono- and bis-(1 H, 1 H, 2 H, 2 H-perfluoroalkyl)
phosphates where the alkyl group is
even numbered and in the C6-C12 range

ACTIVITY: Former EPA Inert used as a Defoaming Agent

Regulatory Information
(only comprehensive for the US)
US EPA Registered: No 
Of special interest:
This is a PFOS chemical. EPA did not include a CAS No.

Adverse Effects:

No information available.

US EPA List of Inerts. This substance was a former List 3 Inert.

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
List 4 (all)

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

US Federal Register
Date Published Docket Identification Number Details
August 9, 2006 EPA-HQ-OPP-2006-0253 nert Ingredient; Revocation of the Tolerance Exemption. FINAL RULE.
EPA concluded that it was unable to determine that the tolerance exemption met the safety requirements of FFDCA section 408(c)(2) and proposed the revocation of the tolerance exemption in the Federal Register on April 19, 2006. . The current inert ingredient tolerance exemption under 40 CFR 180.920 was established on January 23, 1985 by a final rule published in the Federal Register (50 FR 2983). The Agency established this tolerance exemption in response to a petition from the American Hoechst Corporation. The petitioner requested that the new tolerance exemption limit the use of the compound in pesticide products to a defoaming agent used only on growing crops at no more than 0.5% of the pesticide formulation. This action becomes effective 18 months after the publication date of this final rule in the Federal Register.
April 19, 2006 EPA-HQ-OPP-2006-0253

Proposed Revocation of Pesticide Inert Ingredient Tolerance Exemption.
The existing tolerance exemption under 40 CFR 180.920 for the inert ingredient mono- and bis-(1H, 1H, 2H, 2H- perfluoroalkyl) phosphates where the alkyl group is even numbered and in the C6-C12 range allows for its use as a defoaming agent at not more than 0.5% of pesticide formulation. Due to potential risk from use of these perfluoroalkyl phosphates EPA is proposing to revoke the tolerance exemption at 180.920 under FFDCA section 408(e)(1) because the Agency is unable to determine that the tolerance exemption meets the safety requirements of FFDCA section 408(c)(2).

It has been demonstrated that compounds containing perfluoroalkyl chains (PFAC), such as the perfluoroalkyl phosphates described in Sec. 180.920 will undergo degradation (chemical, microbial, or photolytic) of the non-fluorinated portion of the molecule leaving the remaining perfluorinated acid untouched (Ref.: A. Remde and R. Debus, Biodegradability of Fluorinated Surfactants Under Aerobic and Anaerobic Conditions, Chemosphere, 32(8), 1563-1574 (1996)). Among the degradation compounds that can be produced is perfluorooctanoic acid (PFOA). Further degradation of the perfluoroalkyl residual compounds is extremely difficult.

EPA has received significant and troubling data on PFOA. Biological sampling recently revealed the presence of PFOA in fish, birds, and mammals, including humans, across the United States and in other countries. The widespread distribution of the chemical suggests that PFOA may bioaccumulate. PFOA has shown liver, developmental, and reproductive toxicity at very low dose levels in exposed laboratory animals (Ref.: (AR226-1093) Seed, Jennifer. Hazard Assessment of Perfluorooctanoic Acid and Its Salts-USEPA/EPA/RAD. Washington, DC. November 4, 2002.).

On March 7, 2006, EPA published a proposal to amend the polymer exemption rule to exclude certain perfluorinated polymers (71 FR 11484, March 7, 2006, FRL-7735-5). EPA believes this change to the current regulation is necessary because, based on recent information, including the data on PFOA and the potential for these perfluorinated polymers to degrade to PFOA, EPA can no longer conclude that these polymers will not present an unreasonable risk to human health or the environment, which is the determination necessary to support an exemption under section 5(h)(4) of TSCA, 15 U.S.C. 2604(h)(4), such as the Polymer Exemption Rule. Because (1) PFOA and other PFACs are produced from the degradation of the perfluoroalkyl phosphates described in Sec. 180.920 and (2) the potential risks to human health and the environment associated with PFOA, EPA is unable to determine that there is a reasonable certainty that no harm will result from exposure residues of the perfluoroalkyl
phosphates described in Sec. 180.920. Therefore, the tolerance exemption does not meet requirements of FFDCA section 408(c)(2), and EPA is proposing to revoke this tolerance exemption in Sec. 180.920 in accordance with FFDCA section 408(e)(1).

April 28, 2004 OPP-2003-0368 Pesticides; Tolerance Exemptions for Active and Inert Ingredients for Use in Antimicrobial Formulations (Food-Contact Surface Sanitizing Solutions). FINAL RULE.
-- Defoaming agent. Not more than 0.5% of pesticide formulation. For use in pesticide formulations applied to growing crops only:
Fluoride Action Network | Pesticide Project | 315-379-9200 |