TPM Integrated Pest Management Program http://hdl.handle.net/1813/52630 UN Cornell Cooperative Extension

Active Ingredients Eligible for Minimum Risk Pesticide Use: Overview of the Profiles

Developed by the New York State Integrated Pest Management Program at Cornell University

New York State IPM Integrated Pest Management Program

UNIV ELL U CORNEL FOUNDE D. 186

Cornell Cooperative Extension

Active Ingredients Eligible for Minimum Risk Pesticide Use: Overview of the Profiles

Brian P. Baker and Jennifer A. Grant

New York State Integrated Pest Management, Cornell University, Geneva NY

Purpose

The New York State Integrated Pest Management (NYS IPM) Program at Cornell University, with support from the New York State Department of Environmental Conservation (NYS DEC), has produced profiles of the 31 active ingredients allowed in pesticides that are exempted from the federal pesticide product registration of the United States Environmental Protection Agency (EPA). These pesticides are termed "minimum-risk pesticides" by the EPA and are also known as '25(b)' pesticides, because of the section of the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA) giving EPA the authority to grant exemptions (see https://www.epa.gov/minimum-risk-pesticides/conditions-minimum-risk-pesticides). The EPA has determined that the risk to the public and the environment is sufficiently low as to not require all the data and review necessary for registration. Thus, there are often data gaps for these substances compared to the active ingredients in registered pesticides. These profiles identify available data for the physical and chemical properties, human health information, environmental effects information, efficacy, and standards and regulations that apply to the substance. The profiles are intended to help officials, practitioners, and the public to better understand the potential risks and benefits of the active ingredients in minimum-risk pesticides. State pesticide regulators have the authority to require registration of some or all pesticide products exempt from federal registration; and many states do register them.

The profiles are informational only and any mention of a pesticide product should not be construed as an endorsement by Cornell University, NYS IPM, or NYS DEC.

Minimum-Risk Pesticides

The statutory basis in FIFRA [PL 92-516, $25(b) (1972)] was codified and amended as 7 USC 136w(b). The EPA first proposed exempting certain pesticide products from registration based on criteria established

This overview document references profiles of 31 active ingredients eligible for exemption from pesticide registration when used in a Minimum Risk Pesticide in accordance with the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA) section 25b. These profiles were developed by the New York State Integrated Pest Management Program at Cornell University, for the New York State Department of Environmental Conservation. The authors are solely responsible for its content. Mention of specific uses are for informational purposes only, and are not to be construed as recommendations. Brand name products are referred to for identification purposes only, and are not endorsements.

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through rulemaking in 1994 [59 Federal Register 47289 (1994)]. The agency then developed criteria to add other active ingredients and make provisions for non-active or 'inert' ingredients. EPA undertook this process of exempting certain pesticides from registration to encourage the adoption of lower-risk pesticide products (Andersen et al. 1996). During the rulemaking process, public comment was invited on the factors for exemption, what pesticide formulations would qualify for exemption, risks posed by the proposed active ingredients, and whether any additional active ingredients might qualify for exemption.

In publishing the final regulation, the EPA considered the following factors when considering what active ingredients would be eligible for exempt products:

1. whether the active ingredient is widely available to the general public for other uses;
2. if it is a common food or constituent of a common food;
3. if it has a nontoxic mode of action;
4. if it is Generally Recognized As Safe (GRAS) by the Food and Drug Administration (FDA) [when used in food];
5. if there is no information showing significant adverse human health or environmental effects on any population;
6. if its use pattern would result in significant exposure, and
7. if it is likely to persist in the environment [61 Federal Register 8876 (1996)].

In order to be exempt from the requirement of registration as a pesticide, a product must meet the following conditions (US EPA 2016):

1. The product's active ingredients must only be those that are listed in 40 CFR 152.25(f)(1).
2. The product's inert ingredients may only be those that have been classified by EPA as either Listed in 40 CFR 152.25(f)(2), are commonly consumed food commodities, animal feed items, and edible fats and oils as described in 40 CFR 180.950(a), (b), and (c); and certain chemical substances listed under 40 CFR 180.950(e).
3. All of the ingredients (both active and inert) must be listed on the label. The active ingredient(s) must be listed by label display name and percentage by weight. Each inert ingredient must be listed by label display name.
4. The product must not bear claims either to control or mitigate organisms that pose a threat to human health, or insects or rodents carrying specific diseases.
5. The name of the producer or the company for whom the product was produced and the company's contact information must be displayed prominently on the product label.
6. The label cannot include any false or misleading statements.

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To clarify the eligibility and requirements for exemption, EPA proposed revisions to the regulation at the end of 2012 (US EPA 2012). These proposed revisions were amended after public notice and rulemaking, and took effect on February 26, 2016 (US EPA 2015d), with a full compliance date of February 26, 2019. The revisions more precisely identify the eligible active ingredients, disaggregating previously broader categories. Even though 41 active ingredients are now identified, no new substances were added and the clarification can be interpreted as a narrowing of the scope of eligible active ingredients. However, our profiles are arranged by the 31 active ingredients originally identified by the EPA in 1996. The revisions also codify the inert ingredient list to be consistent with other reforms the EPA is undertaking with formulated products that have both active and non-active substances. In the interest of transparency and accountability, manufacturers as well as vendors now need to be identified on the product labels.

Table 1 summarizes the uses of these minimum risk pesticide active ingredients in two particular categories: usage in organic production under the United States Department of Agriculture's National Organic Program (USDA Organic), and permissible use in food products. None of the 31 active ingredients have a tolerance established for residual contamination of food, animal feed, and other agricultural commodities, but many are explicitly exempt from the requirement of a tolerance. Many 25(b) substances are also either a commonly consumed food or GRAS food additives.

Table 1: Uses of Active Ingredients Eligible for use in Minimum Risk Pesticides

Active Ingredient	Uses and Applications	USDA Organic	Food Use
Castor oil	Insecticide, Rodenticide	Yes	Yes
Cedarwood oil¹	Insecticide, Nematicide	Yes	No
Cinnamon and cinnamon oil	Fungicide, Insecticide	Yes	Yes
Citric acid	Fungicide, Herbicide	Yes	Yes
Citronella and citronella oil	Insecticide	Yes	No⁴
Cloves and clove oil	Fungicide, Herbicide, Insecticide	Yes	Yes
Corn gluten meal	Herbicide	Yes	Yes
Corn oil	Insecticide	Yes	Yes
Cottonseed oil	Insecticide	Yes	Yes
Dried blood	Vertebrate repellent	Yes	No
Eugenol	Insecticide	Yes²	No⁴
Garlic and garlic oil	Fungicide, Insecticide	Yes	Yes
Geraniol	Insecticide	Yes	Yes
Geranium oil	Insecticide	Yes	No⁴
Lauryl sulfate	Insecticide	No	Yes
Lemongrass oil	Insecticide	Yes	No⁴
Linseed oil	Fungicide, Insecticide	Yes	Yes
Malic Acid	Fungicide	Yes²	No⁴
Mint and mint oil³	Fungicide, Insecticide	Yes	Yes
Peppermint and peppermint oil	Fungicide, Insecticide, Vertebrate repellent	Yes	Yes
2-Phenethyl propionate	Insecticide	No	No⁴
Potassium sorbate	Fungicide	No	Yes
Putrescent whole egg solids	Vertebrate repellent	Yes	Yes
Rosemary and rosemary oil	Fungicide, Insecticide	Yes	Yes
Sesame and sesame oil	Insecticide, Nematicide	Yes	Yes
Sodium chloride	Fungicide, Herbicide	Yes	Yes
Sodium lauryl sulfate	Insecticide	No	Yes
Soybean oil	Insecticide	Yes	Yes
Thyme and Thyme oil	Fungicide, Acaricide, Insecticide Vertebrate repellent	Yes	Yes
White pepper	Vertebrate repellent	Yes	Yes
Zinc	Algicide	No⁵	No

¹Limited to Virginia, Texas and Chinese cedarwood oil beginning in 2015. ²Must be from a non-synthetic source for organic status with the NOP. ³Limited to corn mint and spearmint beginning in 2015. ⁴Generally Recognized As Safe (GRAS) as a food additive by FDA, but not exempt from the requirement of an EPA food Tolerance. ⁵Structural use as roofing material is outside the scope of the NOP.

Ingredients that are not exempt from the requirement of a tolerance, and are not considered commonly consumed foods, are permitted to be used only where the use and application is not expected to result in residues in food. Therefore, dried blood, cedarwood oil, citronella and citronella oil, eugenol, geranium oil, 2-phenethyl propionate, and zinc metal strips are not permitted for food uses (US EPA 2015c). All 25(b)-eligible active ingredients are permitted for non-food uses. Most minimum risk pesticides are allowed for organic production under the NOP. However, products containing the active ingredients lauryl sulfate, sodium lauryl sulfate, potassium sorbate, and 2-phenethyl propionate, do not comply with the organic standards. Zinc metal strips used to prevent algal growth on roofs appear to be outside the scope of the organic standards.

Eligible active ingredients can be placed in broader categories by their chemical structures and specific functions. The largest single category is essential oils and their plant sources and derivatives. Essential oils are the volatile secondary metabolites found in plants that provide documented insect repellent, allelopathic, and fungistatic properties. These consist mostly of terpenoids, but may include aliphatic and aromatic esters, phenolics, and substituted benzene hydrocarbons. Many essential oils identified as phytoalexins-substances in plant tissue that are produced in response to parasitic organism damage to inhibit the organism's growth. Essential oils eligible for exemption as active ingredients in pesticides include cedarwood, citronella, cloves, geranium, mint, peppermint, rosemary, and thyme. Also included in this category are the essential oil derivatives eugenol and geraniol.

The next important category is vegetable oils and their plant sources. These are oils obtained from seeds, bulbs, or other plant parts. They are distinguished from essential oils in that they are more stable and do not have the aromatic properties found in essential oils. This category includes corn, cottonseed, linseed, and soybean oils. Castor, sesame, and garlic oil are also categorized as vegetable oils, even though they all contain secondary metabolites. These metabolites have a different mode of action that is explained more fully in the substances' individual profiles. Related to these vegetable oils are plant by-products. These include corn gluten meal, sesame by-products, and garlic.

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Three profiled substances are used almost exclusively as deer repellents: dried blood, putrescent whole egg solids, and white pepper. White pepper is used in some insecticides for its synergistic properties, but this volume of use is relatively small compared with its use in deer repellents.

Citric acid and malic acid are carboxylic acids that may be plant- or fermentation-derived, and are common substances found in nature. Malic acid may also be synthesized. A few synthetic substances also appear on the 25(b) eligible list, including potassium sorbate, lauryl sulfate, sodium lauryl sulfate, and 2-phenethyl propionate. Rounding out the list are sodium chloride or common table salt, and zinc in the form of metal strips used to prevent algal growth on rooftops.

Note that a product is not necessarily a 25(b) minimum-risk pesticide just because it contains one or more ingredients listed in Table 1. To be a minimum-risk pesticide, it must meet ALL of the requirements listed earlier. For example, a product that contains citric acid plus an active ingredient NOT found in Table 1 would be subject to federal pesticide product registration requirements. (See http://www2.epa.gov/minimum-risk-pesticides/conditions-minimum-risk-pesticides for more information on the requirements.)

Guide to the Profiles

A profile has been prepared for each of the original 31 minimum-risk-eligible pesticide active ingredients. Profiles include the identity and a brief summary and background of the substance, physical and chemical properties, human health information, environmental effects information, efficacy, standards and regulations, and literature cited. A glossary of technical terms used in the profiles is included in Appendix A.

Each document begins with a summary section that includes the label display name as it appears in 40 CFR 152(f)(1), Table 1, its other names, and its Chemical Abstract Service (CAS) number. The EPA's Pesticide Classification (PC) code is given, along with other descriptors from their pesticide active ingredient database (US EPA Office of Pesticides and Toxic Substances 2016). To aid readers in identifying the substance, other codes used to identify the substance, such as the California Department of Pesticide Registration (CDPR) chemical code (CDPR 2016), the Beilstein Reference Number (BRN), Flavor and Extract Manufacturers Association Code (FEMA), and the International Numbering System (INS) are given. Basic information on the chemical and physical properties, synonyms, discoveries, first syntheses, and summaries of uses was obtained from the Merck Index (Merck 2015) and the chemical structure database Chemspider (Royal Society of Chemistry 2015).

Besides noting its main target pests, pesticidal use information for each substance may include specific uses in crops and food, its uses against structural pests or as an antimicrobial. Here and throughout most of each profile, each substance's information is presented as a technical grade active ingredient (TGAI) unless stated otherwise. Sometimes information is presented as a generic substance outside the context of pesticide use, or as one ingredient in a formulated product. Also, in cases where the substance contains components that are isolated and found to be biologically active, information on those active constituents is also presented. The pesticidal uses are later covered in greater depth in the efficacy section.

Efficacy data on formulated minimum risk products is reported when available. While the exemption means that the EPA does not review efficacy data, regulations still outlaw any false or misleading label claims, including those related to the efficacy of the product [40 CFR 152.25(f)(3)(iv) and 40 CFR 156.10(a)

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(5)(ii)]. Data showing the efficacy of exempt pesticide products and specific active ingredients eligible for exemption are often difficult to find. Therefore, we included data from pesticide formulations made with eligible active ingredients that are registered or have unknown 25(b) status if we deemed the reference helpful and not misleading to the reader. For example, when used as pesticides, many of the substances are combined with other ingredients and formulated into products to improve performance. These co-formulants are not always reported, and in such cases some may be ineligible as inert ingredients in exempt formulations. In some instances, multiple active ingredients eligible for exemption are used in combination.

Some studies involved registered pesticide products and were conducted prior to the establishment of the regulatory exemption. Also, studies conducted outside the US are not under EPA's jurisdiction, so their use may be subject to a different set of regulatory requirements, and their potential 25(b) status has not been determined. The EPA status, or lack of knowledge of that status, is reported. As a general rule, pesticides that were registered and had active ingredients that were not eligible for exemption in addition to 25(b) eligible active ingredients were not included.

The summary also includes a safety overview that briefly states the basis for EPA's determination of minimum risk for that substance. In some cases, this was found in the EPA's most recent work plan for the substance or a Reregistration Eligibility Decision document (when available). Areas of concern identified by EPA with respect to human health, effects on non-target organisms, and environmental fate are also reported here. The later sections on human health and environmental effects information, as well as standards and regulations, cover product safety in greater depth.

The Background section includes a brief description of the sources, manufacturing processes, history of use, and regulatory history of the substance. Consulted references include Milne 2004, Gwynn 2014, Kegley et al. 2014, and US EPA 2015a. In most cases, primary sources were retrieved, verified, and cited directly. The scope of the review for the profile is also given. Some exemptions are for a family of substances, particularly in the case of the various essential oils. Sources specific to essential oils were searched for relevant data and studies (Baser and Buchbauer 2009; Khan and Abourashed 2010). The background provides general information on the substance profiled, including its standard of identity or constituent components.

Each profile has a table that summarizes the Chemical and Physical Properties of the substance. Properties may include chemical composition or molecular structure, physical state at standard temperature and pressure, color, specific gravity, density, solubility, vapor pressure, melting point, boiling point, pH, octanol/water partition co-efficient, viscosity, miscibility, flammability, storage stability, corrosion characteristics, soil half-life, water half-life, and persistence. Where data was missing for a substance, characteristics of the main active constituent were included. For example, with cinnamon and cinnamon oil, the properties of the main active constituent cinnamaldehyde was used when the data for cinnamon or cinnamon oil could not be found. EPA data is reported when available. Other sources consulted include the Pubchem database (US NLM 2016) and the combined chemical dictionary and natural products database (ChemNetBase 2015).

Sources used for the general background and chemical and physical properties include the EPA's Pesticide Active Ingredient Database (US EPA Office of Pesticides and Toxic Substances 2016), the Merck Index (Merck 2015), the US National Institute of Health's Hazardous Substances Database (HSDB) (HSDB 2015),

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the American Chemical Service's SciFinder database (ACS 2017), and the Royal Chemical Society's Chemspider (Royal Society of Chemistry 2015). If a data search of other specific sources was unsuccessful, the values were reported as 'Not Found'. Sources of every data value were reported and where possible, the original sources were reviewed and cited. Where primary sources were not readily accessible, secondary sources were cited. Where empirical data was unavailable, environmental fate estimates from the Estimation Programs Interface (EPI 2012) suite of models were reported.

The Human Health Information section includes data on the acute, sub-chronic and chronic toxicity of the substance. Acute toxicity results from exposure to a substance for less than 24 hours. Sub-chronic toxicity is measured by repeated exposures over a period of 1-3 months, and chronic toxicity results from exposures of more than three months (Klaassen et al. 2001). When available, values were reported for acute oral, dermal, and inhalation toxicity measured by the lethal dose for 50% of the test organisms (LD₅₀) or the lethal concentration for 50% of the test organisms (LC₅₀); eye and skin irritation; and skin sensitization-using EPA's Office of Chemical Safety and Pollution Prevention (OCSPP) guidelines (US EPA 2017). EPA's ACTor database was searched by common name, chemical name, and CAS number; and EPA data was reported when available (US EPA 2015a). If EPA data was not available, other sources were searched and referenced when appropriate. They included the Hazardous Substances Data Bank(HSDB 2015) which is part of the National Institute of Health's Toxnet dataset. Other significant sources were SciFinder (ACS 2017), and data from peer-reviewed journal articles.

Sub-chronic toxicity includes studies of the adverse effects of long-term or repeated exposure at doses that were not acutely toxic, mostly with animal models. Oral, dermal, and inhalation toxicity studies in rodents and non-rodents, as well as reproductive/developmental toxicity and fertility effects screening tests-with a narrative summary of relative risk-were also cited. Where EPA data is unavailable, ToxNet, HSDB and peer-reviewed studies were sometimes included. If none of those sources had data, those values were reported as 'Not Found'. If EPA reviews explicitly waived specific data requirements, the relevant agency documents were cited (US EPA 2015a). Not all sub-chronic toxicity tests follow OPPTS protocols.

Chronic toxicity and carcinogenicity were reported with a narrative summary of relative risk, where appropriate. In most cases, chronic toxicity was reported when the substance was mutagenic based on a Salmonella typhimurium model (Ames et al. 1973; Ames et al. 1975). Additional data from ToxNet, HSDB, the International Agency for Research on Cancer (IARC) (IARC 2014), the EPA's Toxic Release Inventory (US EPA 2015b), or the California Proposition 65 list (Cal-EPA 2017) was presented when available. If EPA, IARC, or HSDB did not have data, then the values were reported as 'Not Found'. Note: none of the 31 substances have been identified as carcinogens by EPA, IARC, or California's Proposition 65 list.

Data from the Office of Pesticide Program's Incident Data System (IDS) was also included when found in various EPA reports and work plans. One of the databases in the IDS, the National Pesticide Information Center (NPIC) database, was searched for poisonings that involve the active substance (NPIC 2016). Human health and animal exposure incidents reported to NPIC are displayed in Figure 1. The three 25(b)-eligible active ingredients that accounted for the greatest number of incidents-putrescent whole egg solids, dried blood, and garlic oil-were related to their use as vertebrate pest repellents, primarily for deer. These incidents were largely related to children or pets eating the repellents, causing nausea and other symptoms. Many of the eligible active ingredients can cause allergic reactions in sensitive individuals. At the other end of the spectrum, corn gluten meal and zinc had no incidents reported to NPIC over the 20-year period from April 1, 1996 to March 30, 2016.

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Many reported incidents involved products with multiple active ingredients, some of which are not eligible for use in 25(b) products and may be the cause of the incident. Narrative information identifying the specific formulation and whether it was registered with EPA was not available in all cases. In some cases, the narrative identified the formulation as unregistered, and the statistics also include incidents that involved registered pesticides. Some of these registered formulations involved active or inert ingredients that were ineligible for use in 25(b) products, and the incident may have been related to exposure to those ineligible ingredients.

Figure 1: Human Health Incidents and Animal Incidents Involving Pesticide Products Containing One or More 25(b)-eligible Active Ingredients as Reported to the National Pesticide Information Center April 1, 1996 to March 30, 2016

The Environmental Effects Information section summarized the impact of the substance on non-target organisms, including acute toxicity on aquatic invertebrates, aquatic vertebrates, non-target avian species, non-target plants and non-target insects. Additional studies were included when the EPA identified data gaps with reference to the specified guidelines. Searches were conducted of bibliographic databases including Web of Science (Thomson-Reuters 2016), SciFinder (ACS 2017), and Google Scholar (Google 2016b). Keyword searches paired the substance name with clarifiers like 'pollinators' and 'aquatic invertebrates'; If no data was found in EPA accessible documents or in searches for peer-reviewed sources using the databases cited above, then the values were reported as 'Not Found'. EPA's reports of incidents involving animals and environmental releases were searched and summarized (NPIC 2016). Reported incidents

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that involved neither human health nor animal effects were assumed to be environmental in nature. These may have involved abandoned pesticides, spills, misapplications, and unknown exposures.

Next, the environmental fate, ecological exposure and environmental expression were summarized. The parameters include leaching; photodegradation in water, air, and soil; and ready biodegradability. EPA sources were given priority (US EPA 2015a; EPI 2012).

Efficacy is the next section. EPA sources were the first resource searched for public health claims, and verification if such claims were supported by agency review (US EPA 2015a). Applications involving indirect public health claims-including the control of mosquitos and ticks, or releases into an aquatic environment-were prioritized. While 25(b) products do not need to be registered with EPA, minimum risk pesticide labels cannot state or imply that the product can or will control or reduce rodent, insect or microbial pests in a way that reduces threat to human health. Neither can these labels mention any specific disease that an insect or rodent may be carrying. In order for product labels to make such public health claims, they must have efficacy data reviewed and approved by the agency, and be fully registered.

Thus, efficacy data involving registered pesticides may be included in the profiles.

The search for efficacy data in scientific literature included Web of Science (Thomson-Reuters 2016), SciFinder (ACS 2017), and Google Scholar (Google 2016b), and any patents that were granted-both in the US and internationally-claiming efficacy of formulations with active ingredients used in products that are exempt from registration (US PTO 2016; Google 2016a). Only patents in English were reviewed. Efficacy for the control of specific pests or specific uses and applications were reported. The reader should beware that patent claims are reviewed by examiners and are not considered peer reviewed. Applicants that make false or fraudulent claims can have their patents invalidated. In addition, pesticide products that are exempt from registration are barred from making any false or misleading claims of efficacy.

The profiles cite references involving technical grade active substances, registered pesticides with those substances declared as active ingredients, exempt formulations sold in the US, and formulations made and sold outside the US that are not subject to FIFRA. Some of these formulations, and experimental formulations used under laboratory conditions, may not be 25(b) exempt. Many efficacy studies involve multiple 25(b)-eligible active ingredients as well as non-active formulants-both of which may have possible synergistic effects. We have included these studies because they may be informative to those seeking information on 25(b)-eligible active ingredients, and it is sometimes difficult to determine from the reports whether the pesticide studied met 25(b) criteria. Summary information was provided to distinguish what was tested for efficacy. Thorough review of these products and formulations with multiple 25(b)-eligible active ingredients is beyond the scope of the project.

Finally, the substance's status under various regulations, laws and standards was summarized by looking at Titles 21 and 40 of the Code of Federal Regulations. Official EPA and FDA documents were also cited. The FDA and EPA have shared responsibilities for regulating pesticides in food. Status with FDA was one criterion that the EPA used to determine if a given active ingredient should qualify to be eligible for use in minimum risk pesticides, and whether the pesticide could be used on food crops. Specifically, every substance has a summary of its status with respect to tolerances for residues in food, feed, and other agricultural commodities and whether the FDA has declared the substance as Generally Recognized As Safe (GRAS) status as a food product [21 CFR 182, inter alia] or considers it a commonly consumed food. None

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of the 31 active ingredients has a residue tolerance established, but many are explicitly exempt from the requirement of a tolerance. Such exemptions, listed in 40 CFR 180, are cited.

Note that products intended for use where food is grown, produced, or handled can only include active ingredients with applicable tolerances for residual contamination or tolerance exemptions established in 40 CFR 180. Where tolerances have not been set or exemptions granted, the EPA does not have sufficient information to know whether residues on food are safe (US EPA 2015d). Table 1 shows which 25(b)-eligible active ingredients are allowed for use on food crops.

A search was also conducted for Occupational Health and Safety Administration (OSHA) requirements, mostly through secondary references to the National Institute of Occupational Safety and Health (NIOSH) and product Material Safety Data Sheets (MSDSs). The substance's status as to whether the ingredient is allowed or prohibited by the USDA's National Organic Program (NOP) was also reported [7 CFR 205], and is summarized above in Table 1.

Most states require the registration of 25(b) exempt pesticides. Appendix B includes a table of the status of 25(b) products in the different states. As of January 2018, the following states do not require registration: California, Georgia, Hawaii, Massachusetts, Minnesota, Missouri, Nebraska, New Jersey, New York, North Dakota, and Texas. California exempts most 25(b) eligible products from registration, but requires some to be registered with additional labeling requirements. North Dakota gives manufacturers of minimum risk products the option either to register or to complete an exemption from registration application and pay the same fee as a registered pesticide. Delaware, Tennessee and Wisconsin require 25(b) exempt products to be registered, but no fee is required. Washington State also has additional labeling requirements for some pesticides exempt from registration.

References were compiled using the Chicago Manual of Style as a guide (Turabian 2013), with URLs to the references when readily available and open access. The hyperlinks to the URLs were active at the time they were accessed and may not be current.

References

ACS. 2017. "Scifinder." 2017. https://scifinder-cas-org.

Ames, Bruce N, Frank D Lee, and William E Durston. 1973. "An Improved Bacterial Test System for the Detection and Classification of Mutagens and Carcinogens." Proceedings of the National Academy of Sciences 70 (3): 782-786.

Ames, Bruce N, Joyce McCann, and Edith Yamasaki. 1975. "Methods for Detecting Carcinogens and Mutagens with the Salmonella/Mammalian-Microsome Mutagenicity Test." Mutation Research 31 (6): 347-363.

Andersen, Janet, Anne Leslie, Sharlene Matten, and Rita Kumar. 1996. "The Environmental Protection Agency's Programs to Encourage the Use of Safer Pesticides." Weed Technology, 966-968.

Baser, K Husnu Can, and Gerhard Buchbauer. 2009. Handbook of Essential Oils: Science, Technology, and Applications. Boca Raton, FL: CRC Press.

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Cal-EPA. 2017. "Chemicals Known to the State to Cause Cancer or Reproductive Toxicity." Sacramento, CA: Cal-EPA. https://oehha.ca.gov/media/downloads/proposition-65//p65122917.pdf.

CDPR. 2016. "California Department of Pesticide Regulation Pesticide Search." Sacramento, CA: California Department of Pesticide Regulation. http://www.cdpr.ca.gov/docs/label/chemcode.htm.

ChemNetBase. 2015. "Combined Chemical Dictionary." Combined Chemical Dictionary. 2015. http://dnp.chemnetbase.com.

EPI. 2012. "Estimation Programs Interface (EPI