From: Dan Nowlan <dnowlan**At_Symbol_Here**BERRYMANPRODUCTS.COM>
Subject: Re: [DCHAS-L] A pesticide question to boggle the mind
Date: Wed, 12 Sep 2018 14:43:19 +0000
Reply-To: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**PRINCETON.EDU>
Message-ID: 96B01B2E9C84674ABE1BA48CDA33910303361D23FC**At_Symbol_Here**BPMAIL.bpi.local
In-Reply-To <165cde6b1d9-1ebf-376b**At_Symbol_Here**webjas-vab163.srv.aolmail.net>


YesÉwell, unless there is something outside of the scope of the pesticide regs that precludes a particular useÑa hap situation, a VOC or an OSHA reg, etc.  In my former life, I had a very real need for a CIT/MIT blend (isothiazolone mixtures) for some water-based chemistry we needed to protect from biological growth.  The registered product was $2.35/lb; however, we weren't planning to use it exactly for its registered use.  As such, we just bought the unregistered product for $1.65/lb and went on our merry way.

 

Best regards,

 

Dan Nowlan

Chemist, R&D

Berryman Products, Inc.

(817) 640-2376, ext. 147

 

From: ACS Division of Chemical Health and Safety [mailto:DCHAS-L**At_Symbol_Here**PRINCETON.EDU] On Behalf Of Monona Rossol
Sent: Wednesday, September 12, 2018 8:10 AM
To: DCHAS-L**At_Symbol_Here**PRINCETON.EDU
Subject: Re: [DCHAS-L] A pesticide question to boggle the mind

 

First, thanks for the sublimation data which is exactly what I need.  Second:  Wow, Dan.  You said:

I imagine metaldehyde can be procured as the plain vanilla chemical. Of course, the chemical manufacturer is required to provide an SDS and note the primary hazard on the chemical label, but I doubt a pesticide-use labeled product is utilized for this theater affect application. A pesticide label and EPA registration is required for material sold for one or more specific pesticide applications detailed on the pesticide label. 

If I read between the lines in the above, that means if you can get any pesticide chemical in a generic form, you don't have to follow any EPA rules regarding its use.  So that also explains why aluminum fluoride and sodium aluminum fluoride are used as ceramic glaze ingredients with abandon, while the same chemicals used on crops have all kinds of limitations. Or why butyl tin is used in curing agents for polyester resins.  And why lithium carbonate for ceramics is available in a 25 pound bags -- enough to keep every manic depressive in the country regulated for weeks.

 

So does this also mean that while the pesticide-use metaldhyde is limited on soil to protect wildlife, crops, and ground water, the film producers can cover the ground in the white stuff if it is used as "snow"?   

 

 Oy, veh is mir.

 

 

Monona Rossol, M.S., M.F.A., Industrial Hygienist

President:  Arts, Crafts & Theater Safety, Inc.

Safety Officer: Local USA829, IATSE

Safety Consultant:  SAG-AFTRA

181 Thompson St., #23

New York, NY 10012     212-777-0062

actsnyc**At_Symbol_Here**cs.com   www.artscraftstheatersafety.org


 

 

-----Original Message-----
From: Dan Blunk <blunk**At_Symbol_Here**UCSC.EDU>
To: DCHAS-L <DCHAS-L**At_Symbol_Here**PRINCETON.EDU>
Sent: Wed, Sep 12, 2018 4:44 am
Subject: Re: [DCHAS-L] A pesticide question to boggle the mind

Monona,

 

Metaldehyde sublimes (at atmospheric pressure) around 234 F. Sublimation is simply a physical state change, from solid directly to a gas, not a chemical change. It has been noted that decomposition with partial regeneration of acetaldehyde occurs above 176 F.

 

Since the sublimed gas would immediately enter the relatively cool ambient temperature air, I would suspect very little decomposition of the metaldehyde to occur, but rather the gas would rapidly cool and solid metaldehyde recrystallize. This assumption appears consistent with the analytical work conducted.

 

I imagine metaldehyde can be procured as the plain vanilla chemical. Of course, the chemical manufacturer is required to provide an SDS and note the primary hazard on the chemical label, but I doubt a pesticide-use labeled product is utilized for this theater affect application. A pesticide label and EPA registration is required for material sold for one or more specific pesticide applications detailed on the pesticide label.

 

Dan

 

From: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**PRINCETON.EDU> On Behalf Of ILPI Support
Sent: Tuesday, September 11, 2018 10:06 AM
To: DCHAS-L**At_Symbol_Here**PRINCETON.EDU
Subject: Re: [DCHAS-L] A pesticide question to boggle the mind

 

OMG and then some.  See https://www3.epa.gov/pesticides/chem_search/ppls/005481-00091-20120214.pdf and scroll down to the part where it says "Metaldehyde is a systemic toxin. There is no antidote. The following instructions are meant for laypeople. There is no home treatment. Exposed individuals and animals should receive emergency care as quickly as possible."  And keep on reading from there.

 

Given that it is classified by the U.S. Environmental Protection Agency (EPA) as a Restricted Use Pesticide (RUP), I'd call in a HazMat response to the film location and tell them to send the manufacturer the bill.  And ask a class action lawyer for a referral fee.

 

Who the heck is selling this pesticide for such egregiously unlawful use? 

 

Report the violation here: https://echo.epa.gov/report-environmental-violations   See also https://www.epa.gov/pesticide-incidents/how-report-spills-and-environmental-violations  I wonder if there are financial rewards for reporting incidents like this?

 

Rob Toreki

 

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On Sep 11, 2018, at 12:35 PM, DCHAS Membership Chair <membership**At_Symbol_Here**DCHAS.ORG> wrote:

 

From: Monona Rossol <actsnyc**At_Symbol_Here**cs.com>
Re; new thread: pesticide question to boggle the mind

I need advice.  There is a product used on film and TV locations as artificial snow.  The SDS on the product says it is 98% metaldehyde.  And metaldehyde when exposed to high heat produces this snow-like stuff. This reaction has been known to magicians for years.  I looked it up a 1936 book of parlor tricks and there it was. The trick was done with pure metaldehyde in a dish with the "snow" reaction started by putting a hot soldering iron into the metaldehyde.

So this snow product is composed of
               1) 98% metaldehyde and
               2) about 2% of a chemical source of heat (probably a fuse-like cord).

Metaldehyde (CH3CHO4) is a polymerized acetaldehyde. More specifically, it is a cyclic tetramer of acetaldehyde and is used extensively around the world as a molluscicide in agriculture for the control of slugs to protect crops. Acetaldehyde is a gas. Polymerized acetaldehyde (metaldehyde), it is a white solid (usually in granules).

As for how metaldehyde makes snow, the theory that best fits these observations is that when heated, this white powder sublimes and re-solidifies in the form of the white fluffy flakes. The heat could convert it into some unregulated aldehyde-related chemical, but considering the white solid state, I'm guessing that the flakes probably are still metaldehyde.

The product was just used again on the film location and as usual, we had health complaints.  The producers hired a lab to "test the air" during the shoot. The lab chemists made an assumption that the metaldehyde converts to acetaldehyde when heated so they only tested the air for acetaldehyde and other aldehydes.  Their study found very low amounts, amounts so low that it is more likely that they came from the burning of the heat source chemicals.  Because IF the snow product, which is 98% metaldehyde DID all convert and become acetaldehyde gas, the amounts in the air would by vastly larger than the amounts found.  And IF the 98% of metaldehyde DID all convert to acetealdehyde gas, there would be NO SNOW.  It would just disappear into the air since it is a gas.

So the lab report supports the theory that the white stuff is, indeed, metaldehyde in a different form.   Until and unless the lab analyzes the white snow material and determines otherwise, I am assuming it is metaldehyde.

And metalaldehyde is toxic. For example, effective October 18, 2016, the EPA has set tolerances on various foods for methaldehyde to protect consumers from toxic effects (FR Doc. 2016-25166, amending ¤180.523 Metaldehyde; tolerances for residues).  The EPA re-registered metaldehyde as a Ôrestricted use pesticide' and required risk-reduction measures to be adopted due to the potential short-term and long-term effects on wildlife. The World Health Organization (WHO) classifies metaldehyde as a "moderately hazardous" pesticide (class II). The European Commission has adopted a directive that restricts pesticides levels to 0.1 ?g/L in drinking water ( the U.S. doesn't have an MCL for metaldehyde).

So it makes no sense to me that the product's metaldehyde is being thrown all over the whole location, in bits and pieces, some of it in particles small enough to inhale, get in the eyes, take home on your clothes, etc. The product is usually used outdoors, but there are times they are used indoors where exposure is even more concentrated.

MY QUESTIONS FOR YOU:

1.  Is the white stuff metaladehyde or an unregulated related chemical?
2.  Does anyone have an EPA contact that might actually want to look at this use of a pesticide?  We need to get this stuff out of our working lives.


Monona Rossol, M.S., M.F.A., Industrial Hygienist
President:  Arts, Crafts & Theater Safety, Inc.
Safety Officer: Local USA829, IATSE
Safety Consultant:  SAG-AFTRA
181 Thompson St., #23
New York, NY 10012     212-777-0062
actsnyc**At_Symbol_Here**cs.com   www.artscraftstheatersafety.org

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