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From: Dan Nowlan <dnowlan**At_Symbol_Here**BERRYMANPRODUCTS.COM>
Subject: Re: [DCHAS-L] A pesticide question to boggle the mind
Date: Sep 12, 2018 14:43 UTC
Reply-To:
ACS Division of Chemical Health and Safety
In-Reply-To: Re: [DCHAS-L] A pesticide question to boggle the mind
Yes�well, unless there is something outside of the scope of the pesticide regs that precludes a particular use�a 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
-----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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