The Secret Hazards of Pesticides:

Inert Ingredients

Attorney General of New York
New York State
Office of the Attorney General
Environmental Protection Bureau
February 1996


The Secret Hazards of Pesticides: Inert Ingredients

Look at any label on a pesticide product and you will find a list of "active" ingredients, with a few long chemical names, and then typically the phrase "inert ingredients," with only a single percentage figure given and no listing of individual ingredients. The active ingredients are the chemicals used to control the target pest and must be listed on the label. The so-called "inert" ingredients are used as carriers for the active ingredients, to help dissolve them, make them easier to apply or to preserve them.

Unfortunately, many people will conclude from the term "inert" that such ingredients could not possibly have any adverse health or environmental effects. This is not the case at all. The chemicals used as inerts include some of the most dangerous substances known. Some of these chemicals are suspected carcinogens and have been linked to other long-term health problems like central nervous system disorders, liver and kidney damage and birth defects. They can also cause short-term health effects like eye and skin irritation, nausea, dizziness and respiratory difficulty. The U. S. Environmental Protection Agency (EPA), the agency responsible for regulating the use of pesticides, has categorized inert ingredients into four groups: substances known to cause long-term health damage and harm the environment, chemicals suspected of causing such health or environmental damage, chemicals of unknown toxicity, and those of minimal concern. Although EPA has published a list of chemicals used as inerts, this list does not tell consumers which products contain these inerts. Furthermore, pesticide manufacturers are not required to list all inerts on the product label. Thus, people must play blind man's bluff when it comes to which inerts might be in the pesticides they buy or are used where they live, work or play.

Inerts usually make up at least half if not most of consumer pesticide products. For instance, 99.1 percent of Raid's Ant and Roach Killer is inert ingredients and Ortho Diazinon Dust is 96 percent inerts. Of the 85 pesticide products examined by the Attorney General's office, 75 percent contained over 90 percent inert ingredients (see Table 1 on page 7 for a list of these products). Despite the health effects EPA associates with inerts, people do not know to which chemicals they may be exposed since inerts are not identified on the label. Health effects of some inert ingredients are listed in Table 2 on page 9.

Pesticides are widely used throughout the United States in non-agricultural settings--in homes, outside homes, in offices, schools, and recreational areas. Over 70 million pounds of pesticides are applied on lawns alone every year. The use of lawn care pesticides is increasing at about 5 to 8 percent annually. In fact, four times as many pesticides are used on home lawns as are used to grow food crops. Commercial lawn care is now a $1.5 billion industry. In addition, according to a 1985 study, pesticides used on golf courses accounted for nearly 12 million pounds nationwide. And all these pesticide products--whether used in lawn care, household fumigation, pet care or in personal-care products like insect repellents--contain substantial amounts of inert ingredients.

Who knows what the secret inert ingredients are? Obviously, the pesticide manufacturers and formulators know. Under the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA) pesticide registrants (primarily manufacturers and formulators) must report the identity of inert ingredients to EPA. So one might assume that EPA knows the identity of the inert ingredients in every registered pesticide product. Unfortunately, that does not appear to be the case.

In 1987, EPA announced an "Inerts Strategy" designed to eliminate the most toxic inert ingredients from use, require improved label disclosure of inert ingredients, increase disclosure of inert ingredients, and increase the toxicity testing required for inerts. That strategy, if effectively implemented, could have enhanced the level of protection afforded to the public. In 1991, the EPA Inspector General reported on an investigation of EPA's implementation of its own "Inerts Strategy." The Inspector General reported that:

"EPA has not... enforced the 1987 Inert Strategy requirements for inerts with toxic effects... EPA identified 68 inerts as potentially toxic, and assigned them to a high priority for testing... EPA has no specific procedures or timetables for insuring that these inerts are reviewed."

"EPA is not sure how many chemicals registrants are using as inert ingredients because the inerts were not accurately coded into... [the EPA database]... there were about 600 registrations for which ... the chemical name was not available."(1)

How has EPA responded to this criticism of its implementation of the Inerts Strategy? Not very effectively. According to a 1993 internal memo from the EPA Inspector General's office, corrective actions originally scheduled for completion in 1992 or 1993 had been delayed until 1995 or beyond. Attempts to develop a computer database for inert ingredients had failed, and further development of the system was contingent upon further funding.(2)

Thus, the EPA does not necessarily know the identity of the inert ingredients in the pesticide products sold to the general public, and that situation may not be resolved for years to come.

Even when EPA knows the identity of the inerts, FIFRA instructs it to keep that information secret if the manufacturer requests confidentiality unless the agency decides "that disclosure is necessary to protect against an unreasonable risk of injury to health or the environment".(3) Enacted almost half a century ago, the "trade secrecy" section of FIFRA was intended to protect manufacturers from any competitors who might copy the recipe for a successful product. Today, inert pesticide ingredients are still considered confidential under this obsolete regulation even though "trade secrets" are not necessarily secrets within the industry. Companies can now use commonly available "reverse engineering" techniques to find out the inert ingredients in their competitors' products. Now, this information is secret only to the public.

The Attorney General's office went directly to pesticide manufacturers to ask them to name the inert ingredients in some of their products sold in New York State. Many of the companies contacted refused to provide such information. Others agreed to identify inert ingredients only with an expectation of confidentiality. However, a few companies did cooperate without reservation. Thus, the survey shows that inerts information is generally not available to the public; most companies continue to withhold the identity of inert ingredients under a claim of confidentiality.

Ironically, many non-pesticide products containing the same chemicals used as inert ingredients in pesticides are governed by various laws, regulations, standards or guidelines because of their potential toxicity. There are limits for many of these chemicals in air, water and the workplace. There are restrictions on disposal of these chemicals, penalties for spills and special requirements for their transportation. These laws include the Toxic Substances Control Act, the Clean Water Act, the Clean Air

Act, the Resource Conservation and Recovery Act (RCRA), and regulations issued by EPA and the Occupational Safety and Health Administration, as well as guidelines from the National Institute for Occupational Safety and Health. (See Table 3 on page 11 for a selected list of regulations, laws, and advisories concerning chemicals used as inerts.)

Even though some laws limit human exposure to these chemicals by restricting their release into air, water or the workplace, there is no way of knowing when the same chemicals are released as inert ingredients in pesticides. As long as pesticide ingredients are kept secret, people cannot even take steps to avoid exposure. And if an individual experiences a health problem in reaction to a pesticide, precious time can be lost while the doctor tries to obtain information concerning the chemicals to which the patient has been exposed.

The Federal Insecticide, Fungicide and Rodenticide Act should be amended to require pesticide manufacturers and formulators to disclose the total composition of pesticide products sold to the public. Product labels should identify each inert ingredient in the formulation. This information is simply too important to keep secret any longer because what the public does not know now about pesticides may very well hurt them some day.


This report was originally prepared in June 1991 by Michael H. Surgan, Ph.D., Chief Scientist and Assistant Attorneys General Deborah Volberg, Nancy Stearns and James A. Sevinsky, with assistance from other members of the Environmental Protection Bureau.



Table 1: Percent Inerts in a Sampling of Pesticide Products(4)
Ant, Roach, and Spider KillerDexol Industries99.5
Aphid and Mite AttackRinger Corp.97.96
Crawling Insect AttackRinger Corp.99.56
Flea Kill FoggerThe d-Con Co. Inc.98.35
Hyponex Bug SprayHyponex Corp.99.78
Insecticidal Soap for Indoor PlantsSafer, Inc.98.0
Mite KillerSafer, Inc.98.0
No-RoachGaston Johnston Corp.82.034
Ortho Flea-B-GonChevron Chemical Co.99.17
Ortho Hi-Power Ant, Roach & Spider KillerChevron Chemical Co.95.11
Ortho Hornet & Wasp KillerChevron Chemical Co.99.50
Raid Ant & Roach KillerS.C.Johnson & Sons Inc.99.10
Raid Flying Insect KillerS.C.Johnson & Sons Inc.99.2
Raid Fogger IIS.C.Johnson & Sons Inc.85.0
Raid FumigatorS.C.Johnson & Sons Inc.87.4
Raid House and Garden Bug KillerS.C.Johnson & Sons Inc.97.504
Spectracide Garden, Rose & Household Plant SprayKenco Chem. & Mfg. Corp.99.5
Spectracide Home Insect ControlKenco Chem. & Mfg. Corp.99.17
Spectracide Indoor FoggerKenco Chem. & Mfg. Corp.99.40
Spectracide Wasp and Hornet KillerKenco Chem. & Mfg. Corp.99.3664
Wasp and Hornet AttackRinger Corp.99.56


Lawn and Turf FungicideFaesy & Besthoff, Inc.92.0
Lawn Disease PreventerGlorion Corp.95.0
Lawn FungicideLebanon Chemical Corp.99.945


2-Way Green PowerLebanon Chemical Corp.96.52
Balan 2, 5GElanco Products Co.97.5
Expel Dandelion KillerLebanon Chemical Corp.97.92
Longlife Weed and FeedFrank's Nursery & Crafts99.9845
Preen'n GreenLebanon Chemical Co.99.26
Spectracide Grass and Weed KillerKenco Chem. & Mfg. Corp.99.7
Step 1 Crab Grass PreventionO.M.Scott & Sons Co.99.85
Step 2 Weed ControlO.M.Scott & Sons Co.97.205
Super Turf Builder Plus 2O.M.Scott & Sons Co.97.66
Super Turf Builder Plus HaltsO.M.Scott & Sons Co.98.97
Surety Weed and Feed PlusHoward Johnson Ent. Inc.99.063
Team 2GElanco Products Co.98.0
XL 2GElanco Products Co.98.9


BugoutLebanon Chemical Corp.98.86
Chinch Bug & Grub PreventerGlorion Corp.97.28
Deluxe Weed and FeedGlorion Corp.97.28
Grub BusterFree Flow Fertilizer98.5
Insect ControlO.M.Scott & Sons Co.96.40
Lawn Insect ControlGlorion Corp.98.86
Lawn Insect ControlO.M.Scott & Sons Co.94.16
Lawn InsecticideFree Flow Fertilizer95
Lawn InsecticideGreensweep Household Products58.5
Longlife Lawn & Garden InsecticideFrank's Nursery & Crafts95.000
OftanolGlorion Corp.98.5
Spectracide Lawn & Garden InsectKenco Chem. & Mfg. Corp.95
 Control (granular)
Spectracide Lawn & GardenKenco Chem. & Mfg. Corp.18.7
 Insect Control (liquid) 
Step 3 Insect ControlO.M.Scott & Sons Co.96.40


2 in 1 Crabgrass PreventerGlorion Corp.98.78
AAtrex 4LCIBA-GEIGY Corp.57.0
ArsenalAmerican Cyanamid Co.72.4
ChopperAmerican Cyanamid Co.72.4
Ortho Kleenup Super EdgerChevron Chemical Co.99.50
ProwlAmerican Cyanamid Co.57.7


Dexol Bordeaux MixtureDexol Industries87.35
Garden FungicideSafer, Inc.99.6
Pipron L.C.Elanco Products Co.17.6
Rubigan E.C.Elanco Prodcuts Co.87.5


Liquid SevinFaesy & Besthoff, Inc.77.5
Ortho 3-Way Rose & Flower CareChevron Chemical Co.98.85
Rose & Flower Spray or DustBonide Chemical Co. Inc.84.5
Spectracide Rose & Garden Insect KillerKenco Chem. & Mfg. Corp.99.88


Abate 1-SGAmerican Cyanamid Co.99
AmdroAmerican Cyanamid Co.99.12
Cygon 400American Cyanamid Co.56.5
Gypsy Moth Biological ControlAcme Burgess Inc.99.14
Mosquito AttackRinger Corp.50
Ortho Diazinon Soil & Foliage DustChevron Chemical Co.96
Ortho Diazinon Plus Insect SprayChevron Chemical Co.75
Ortho Home Orchard SprayChevron Chemical Co.62.5
Ortho Isotox Insect KillerChevron Chemical Co.90.6
Ortho Orthene Systemic Insect ControlChevron Chemical Co.90.6
Ortho Rose & Flower Insect KillerChevron Chemical Co.99.70
Ortho SevinChevron Chemical Co.95
Raid Yard GuardS.C.Johnson & Sons Inc.99.125
Yard and Garden Insect AttackRinger Corp.99.56


Hartz 2 in 1 Flea and TickThe Hartz Mountain Corp.99.332


Cutter Insect RepellentMiles Laboratory67
OffS.C.Johnson & Sons Inc.85.00
Ortho Outdoor Insect FoggerChevron Chemical Co.91.385


DeadlinePace National Corp.96
Ortho Slug-getaChevron Chemical Co.98

Table 2. Some Adverse Health Effects Of Certain Inert Pesticide Ingredients
Carbon tetrachloride*Irritation of skin, eyes nose, throat; dizziness, vomiting, abdominal pain; diarrhea; damage to kidneys, liver; central nervous system depression; suspected carcinogen.
Chlorobenzene*Eye and skin irritation, burns and inflammation; chest pain, slow heart rate, ECG irregularities; lung, liver and kidney damage; central nervous system depression; coma.
Chloroform*Irritation to eyes and gastrointestinal tract; damage to liver and kidneys; central nervous system depression; nausea, dizziness, fatigue, respiratory distress; gonadal atrophy; fetal resorption; mutagen; coma and death by cardiac arrest; suspected carcinogen.
ChloroethaneIrritation of eyes; abdominal cramps, nausea, vomiting; liver and kidney damage; nervous system dysfunction; blood cell disorders; suspected carcinogen.
CresolsSkin irritation, burns, and inflammation; irritation of eye, permanent damage and blindness; pneumonia; pancreatitis; central nervous system disorders; kidney failure.
DibutylphthalateIrritation of eyes and throat; photophobia, conjunctivitis,nausea, dizziness.
Diethylhexylphthalate*Eye, nose and throat irritation; liver damage; testicular damage; central nervous system depression; suspected carcinogen.
DimethylphthalateIrritation of eyes, mouth, nose, throat; dizziness, abdominal pain, nausea, vomiting, diarrhea; central nervous system depression; reduced respiratory rate; paralysis, coma.
Epichlorohydrin*Skin and eye irritation, conjunctivitis, corneal clouding; nausea, vomiting, fatigue; liver and kidney damage; inflammation of lungs, chronic bronchitis; death by respiratory paralysis; mutagen; fetotoxic.
EthylbenzeneIrritation of eyes, nose and throat; skin irritation, inflammation, blisters and burns; liver and kidney damage; central nervous system disorders; headache, sleepiness, difficulty in breathing; unconsciousness and coma.
Ethylene dichloride*Nausea, vomiting, diarrhea; damage to liver and kidneys; central nervous system depression; death due to circulatory and respiratory failure.
IsophoroneIrritation of skin, nose, throat, respiratory system; lung congestion and degeneration; central nervous system disorders; kidney and liver damage; suspected carcinogen.
Methyl bromide*Eye and skin irritation; blurredvision, headache, dizziness, nausea, abdominal cramps; anorexia; bronchopneumonia, pulmonary edema; brain damage, convulsions, coma; kidney and respiratory failure.
o-DichlorobenzeneEye irritation and cataracts; skin irritation and lesions; headache, nausea, vomiting, drowsiness; respiratory depression; anemia, kidney and liver damage; chromosomal breaks.
p-DichlorobenzeneIrritation of skin, eyes, respiratory system; headache, dizziness, hyperactivity, weakness, weight loss; liver and blood disorders; kidney damage; lung congestion, difficulty in breathing; mutagen.
PhenolIrritation of eyes, nose, throat; headache, dizziness, fainting, abdominal pain, nausea, vomiting, diarrhea; damage to liver, kidney and heart; chromosomal aberrations and damage; mutagen.
Propylene dichloride*Eye and skin irritation; dizziness, disorientation, nausea, vomiting; liver and kidney damage; central nervous system damage; coma; hemolytic anemia; suspected carcinogen.
1,1,2-Trichloroethane*Gastrointestinal inflammation and congestion; liver and kidney damage; immune function disorder; central nervous system depression; suspected carcinogen.
TolueneSkin, eye and respiratory irritation; abdominal pain, headache, nausea, dizziness, drowsiness, hallucinations; anemia; liver disorders and enlargement; central nervous system dysfunction; coma and death.
Trichloroethylene*Eye irritation, visual distortion; abdominal pain, nausea, diarrhea; anorexia; liver and kidney damage; peripheral nerve damage, numbness and paralysis; blood disorders; cardiac arrhythmia; suspected carcinogen.

*This chemical was identified as an Inert Ingredient by EPA in 1991, but is absent from the most current list of Inert Ingredients released in May, 1995.


U. S. Environmental Protection Agency, Chemical Profiles, Interim Guidance, Chemical Emergency Preparedness Program, 1985

U. S. Environmental Protection Agency, Office of Health and Environmental Assessment, Health Assessment Documents

U. S. Public Health Service, Agency for Toxic Substances and Disease Registry, Toxicological Profiles

New York State Department of Health, Chemical Fact Sheets



Number of ___________________________________________________________________REGULATIONS AND ADVISORIES**_____________________________________________________________________



p-Dichlorobenzene21XX X XXXXX XXXXXXXXX XXXX 
Ethylene dichloride20XX X  X  X XXXXXXXXXXXXXXX
Carbon tetrachloride19XX X     X XXXXXXXXXXXXXXX
Chlorobenzene19  XX XXXXX XXXXXXXXX X XX 
o-Dichlorobenzene19  XX XXXXX XXXXXXXXX X XX 
Propylene dichloride19  XX XX XX XXXXXXXXX XXXX 
Trichloroethylene17XX X     X XXXXXXXXX X XXX
Methyl bromide16  X X X  XXXXXXXXX X X XX 
Toluene16  XX  X  X XXXX XXXX X XXX
1,1,2-Trichloroethane15  XX  X  X XXXXXXX X X XX 
Diethylhexylphthalate15     X  XX XXXX XX XXXXX X
Epichlorohydrin15   X  X  XXX X  X XXXXXXXX
Phenol15      X  XXXXXX XXXX X XXX
Chloroethane14  X X X  X XX XX XXX X XX 
Dibutylphthalate14     XX XX XXXX XXXX X X  
Dimethylphthalate13     XX XX XXXX XX X X X  
Ethyl benzene13  XX  X  X XX X  XXX X XX 
Cresols12         X XXX  XXXX X XXX
Isophorone11    X X  X  X X  X X X XXX

* Adapted from: Suspect Chemicals Sourcebook, K.b. Clansky, Ed., 1989 Edition

(Updated to Jan. 1, 1990) Roytech Publications, Inc.

** See "Explanation of Regulations and Advisories" which follows for specific identification.

Explanation of Regulations and Advisories for Selected Chemicals Used As Inerts


1. Maximum Contaminant Levels (MCL)

Requires the U. S. Environmental Protection Agency (EPA) to establish primary drinking water regulations which 1) apply to public water systems, 2) specify contaminants which may have adverse health effects, 3) specify Maximum Contaminant Levels (MCL, the maximum permissible level of a contaminant in water) or treatment techniques for each listed contaminant, 4) establish public notification requirements.

2. Maximum Contaminant Level Goals

Establishes non-enforceable Maximum Contaminant Level Goals (MCLG) which are set at a level at which no known or anticipated adverse health effects occur and which provide an adequate margin of safety.

3. Monitoring Requirements

Requires monitoring for contaminants likely to be found in the system's drinking water, including contaminants not regulated under National Primary Drinking Water Regulations. Results must be reported to both the State and EPA and made available to the public.

4. 1986 Amendments/Statutory Contaminants

Requires EPA to regulate 83 contaminants by publishing MCLG's and promulgating National Primary Drinking Water Regulations for each of the 83 listed contaminants.

5. 1986 Amendments/Drinking Water Priority List

Requires EPA to establish a priority list of contaminants which may have adverse health effects and are known or anticipated to occur in public water systems.


6. Section 4(a), Final Test Rules

Requires EPA to test substances which meet certain criteria, such as those which may present an unreasonable risk or injury to health or environment, in order to develop health or environmental data.

7. Section 8(d), Health and Safety Data Rule

Requires manufacturers, importers and processors of listed substances to submit to EPA copies and lists of unpublished health and safety studies on the listed substances with which they deal.

8. Section 4(a), Dioxins/Furans Rule

Requires manufacturers and importers of certain organic chemicals to test for the presence of halogenated dibenzodioxins (HDD) and halogenated dibenzofurans (HDF) as contaminants. Results and existing test data must be submitted as well as additional information if HDD and/or HDF concentrations exceed designated levels.

9. Section 12(b), Export Regulations

Requires exporters of chemical substances to notify EPA of such exportation if any exported substances are affected by TSCA Sections 4, 5, 6 or 7.


10. CERCLA. Hazardous Substances

Establishes a list of substances which must be reported to the National Response Center when released in quantities exceeding a specified reportable quantity.

11. SARA. Title III Section 302 and 304, Extremely Hazardous Substances

Requires facilities handling substances named on the list of extremely hazardous substances to notify the State of the presence of these substances in excess of their Threshold Planning Quantities and must notify local authorities of their release in excess of their Reportable Quantities.

12. SARA. Title III Section 313, Toxic Chemicals

Establishes a list of toxic chemicals. Manufacturers, processors and users of these chemicals must submit release reporting forms.

13. CERCLA Section 104(i), Priority list of CERCLA Hazardous Substances

Requires EPA and the Agency of Toxic Substance and Disease Registry to 1) prepare a prioritized list of hazardous substances commonly found at National Priorities List sites which pose the greatest potential health risk, 2) to develop Toxicological Profiles of these substances, 3) establish a research program to fill data gaps.


14. Requires notification of EPA by anyone who generates, transports, treats, stores or disposes of wastes specified under Section 3001 of RCRA.

15. Hazardous Constituents for Groundwater Monitoring

Requires groundwater monitoring at RCRA land-based hazardous waste disposal units for all constituents listed in Appendix IX to 40 Code of Federal Regulations (CFR) 264.

16. Land Disposal Prohibitions - Halogenated Organic Compounds

Restricts land disposal of waste containing halogenated organic compounds above specified concentrations.

17. Land Disposal Prohibitions

Lists the hazardous wastes identified in 40 Code of Federal Regulations 261 which were scheduled for restricted/prohibited land disposal after enactment of the Hazardous and Solid Waste Amendments to RCRA in 1984.


18. Section 304, Water Quality Criteria; Section 307, Priority Pollutants

Requires EPA to publish and periodically update ambient water quality criteria. Criteria are to reflect latest scientific knowledge on the identifiable effects of substances on public health and welfare, including but not limited to aquatic life, aesthetics and recreation. Establishes a list of toxic pollutants for which EPA is required to publish ambient water quality criteria. Under Section 304, these chemicals shall be subject to effluent limits resulting from the application of best available technology.

19. Section 311, Hazardous Chemicals

Requires EPA to publish a list of substances that are considered hazardous if spilled in navigable waters.


20. Air Contaminants (29 CFR 1910.1000)

Establishes a list of air contaminants and sets exposure limits for the workplace.


21. Report on Carcinogens

Identifies carcinogens and subdivides them into Known and Anticipated. Categorizes 162 substances on this basis.


22. Threshold Limit Value Chemicals

Provides various workplace exposure limits (time-weighted average, short-term exposure limits, ceiling limits) for each covered substance.


23. Human Carcinogens (Groups 1, 2A, and 2B)

Identifies carcinogens and classifies them as: Group 1 (sufficient evidence of human carcinogenicity); Group 2A (probable human carcinogen); Group 2B (possible human carcinogen).


24. Hazardous Materials

Regulates interstate commerce of hazardous materials, including all CERCLA hazardous substances, Specifies requirements for description, shipping names, class, labeling and packaging, as well as spill notification.


25. Section 111, Potential Human Health Hazards

Lists substances published by EPA pursuant to Section 111 of the Clean Air Act, which pose a potential health hazard and for which specific control techniques are defined.


26. Criteria Documents

Specifies a NIOSH Recommended Exposure Limit and appropriate preventive measures to reduce or eliminate adverse health effects.

1. "Inert Ingredients in Pesticides," USEPA, Office of the Inspector General, Audit Report E1EPF1-05-0117-1100378, Sept. 27, 1991.

2. Memo from Michael Simmons, Associate Assistant Inspector General for Internal and Performance Audits to Victor J. Kimm, Acting Assistant Administrator for Prevention, Pesticides and Toxic Substances, September 17, 1993. See Foreword for an update on the computer database.

3. FIFRA, Section 10(d)(1)(C), entitled, "Protection of Trade Secrets and Other Information".

4. Based on a market survey conducted during the spring and summer of 1990.

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