&EPA
United States
Environmental Protection
Agency
Industrial Environmental Research
Laboratory
Research Triangle Park NC 2771 1
EPA-600/2-78-100
May 1978
Research and Development
Development of
Information on
Pesticides
Manufacturing for
Source Assessment
-------
RESEARCH REPORTING SERIES
Research reports of the Office of Research and Development, U.S. Environmental
Protection Agency, have been grouped into nine series. These nine broad cate-
gories were established to facilitate further development and application of en-
vironmental technology. Elimination of traditional grouping was consciously
planned to foster technology transfer and a maximum interface in related fields.
The nine series are:
1. Environmental Health Effects Research
2. Environmental Protection Technology
3. Ecological Research
4. Environmental Monitoring
5. Socioeconomic Environmental Studies
6. Scientific and Technical Assessment Reports (STAR)
7. Interagency Energy-Environment Research and Development
8. "Special" Reports
9. Miscellaneous Reports
This report has been assigned to the ENVIRONMENTAL PROTECTION TECH-
NOLOGY series. This series describes research performed to develop and dem-
onstrate instrumentation, equipment, and methodology to repair or prevent en-
vironmental degradation from point and non-point sources of pollution. This work
provides the new or improved technology required for the control and treatment
of pollution sources to meet environmental quality standards.
EPA REVIEW NOTICE
This report has been reviewed by the U.S. Environmental Protection Agency, and
approved for publication. Approval does not signify that the contents necessarily
reflect the views and policy of the Agency, nor does mention of trade names or
commercial products constitute endorsement or recommendation for use.
This document is available to the public through the National Technical Informa-
tion Service, Springfield, Virginia 22161.
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EPA-600/2-78-100
May 1978
Development of Information on
Pesticides Manufacturing
for Source Assessment
by
G.L. Kelso, R.R. Wilkinson, J.R. Malone, Jr., and T.L Ferguson
Midwest Research Institute
425 Volker Boulevard
Kansas City, Missouri 64110
Contract No. 68-02-1324
Task No. 43
ROAP No. 21AZR
Program Element No. 1BB610
EPA Project Officer: David K. Oestreich
Industrial Environmental Research Laboratory
Office of Energy, Minerals, and Industry
Research Triangle Park, NC 27711
Prepared for
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Research and Development
Washington, DC 20460
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PREFACE
This report presents the results of a project entitled, "Information De-
velopment on Pesticides Manufacturing for Source Assessment," performed by
Midwest Research Institute (MRI) under Contract No. 68-02-1324, Task 43, MRI
Project No. 3821-0(43) for the Industrial Environmental Research Laboratory,
Research Triangle Park, of the U.S. Environmental Protection Agency (EPA).
Mr. D. K. Oestreich has been the project officer for EPA.
The project was conducted from January 1 to April 30, 1976, by Mr. Thomas L.
Ferguson, Senior Chemical Engineer, who served as project leader, Dr. Ralph R.
Wilkinson, Associate Scientist, Mr. Gary L. Kelso, Associate Chemical Engineer,
and Mr. J. R. Malone, Jr., Associate Socioeconoraic Policy Analyst, under the
supervision of Dr. E. W. Lawless, Head, Technology Assessment Section.
Dr. R. von Rumker, RvR Consultants, was a consultant on this project.
MRI expresses its sincere appreciation to the many representatives of
federal, state* and local agencies, and to the many companies who provided
technical information for this report.
ii
-------
CONTENTS
Figures
Tables
1. Introduction ..................... ..... 1
2. Characterization of the Pesticide Industry ....... .... 4
Pesticide Classes ..................... 4
Manufacturing and Formulating Operations . ........ 5
Production Quantities and Numbers of Pesticides
and Formulated Products. ... ............. 7
Location of Pesticide Manufacturers and Formulators in
the U.S ......................... 7
Distribution of Pesticides by Plant Sites ......... 10
Distribution of Plants by Number of Pesticides
Manufactured at Each Plant ......... . ..... 15
Distribution of Pesticide Formulations by Chemical
Class and Type of Formulation .............. 15
Pesticide Development Costs ....... ......... 20
Pesticide Marketing Activities for the Fruit Industry. . . 21
Concluding Remarks Characterizing the Pesticide
Industry .. ...................... 26
References to Section 2 ........ ......... 28
3. Pollution Potential in Pesticide Manufacturing and
Formulation ......................... 29
The Pesticide Facility as an Input-Output System ..... 30
Factors Relevant to the Pollution Potential in Pesticide
Manufacturing ........ . ............. 47
General Methodology for Assessing the Pollution Potential
of a Pesticide Production Process ............ 47
Decision Criteria Used for Determining the Need for
Pollution Control Technology Development ........ 50
References to Section 3 ...... > .......... 65
4. Selection of Individual Pesticides for Future Detailed
Source Assessment ...................... 67
The Limited List of Pesticides and Pesticide Groups. ... 68
Estimated 1974 Production Volumes of Synthetic Organic
Pesticides ....................... 71
Pesticide Priority Rating System ............. 74
Selection of the Final Six Candidate Pesticides ...... 80
Summary and Inter comparison of Pesticide Selections by
the Three Alternate Methods ............... 92
References to Section 4 ................. 96
iii
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CONTENTS (Continued)
5. Present and Anticipated Regulatory Climate Facing Pesticide
Manufacturers. 97
Introduction 97
Government Groups at Interest .... 97
Executive Agencies 97
Legislative Agencies 99
Areas of Regulatory Interest 99
Appendices
A. Industrial Chemicals Also Useful As Pesticides A-l
B. Summary Update to the Pollution Potential in Pesticide
Manufacturing - 1972 B-l
C. Pesticide Toxicity Data c-1
D. Tabulation of Available Emissions Data for the Pesticides
Industry D-l
E. U.S. Environmental Protection Agency Regional Contacts ..... E-l
F. EPA Pesticide Programs F-l
G. State Environmental Agency Contacts* . G-l
H. State Pesticide Related Environmental Programs - 1976 H-l
I. Rebuttable Presumption Category TV Chemicals and Tentative
Schedule of Presumption Notice 1-1
J. Criteria for Selection of Pesticides J-1
K. Alternative Methodology for Selecting Plant Sites K-l
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FIGURES
Number Paye
1 Location of Pesticide Manufacturers and Formulators,
by State, 1976 9
2 Location of Pesticide Production Plants, by State, 1976. ... 11
3 Location of Pesticide Formulators, by State, 1976 12
4 Distribution of the Number of Individual Active Ingredients
Produced at a Specific Number of Plants 14
5 Distribution of Plants by Number of Active Ingredients
Produced at Each Plant 16
6 Distribution of Large Formulation Plants by the Number of
Chemical Classes of Pesticide Active Ingredients Formulated. 18
7 Distribution of Large Formulation Plants by Number of Physical
Types of Formulations 19
8 Historical Development of Modern Synthetic Organic Pesticides. 23
9 Aggregate Marketing Activity for Pesticides in the Fruit
Industry 24
10 Number of Major Pesticides Introduced From 1931 Through 1975 . 25
11 Schematic Representation of Pesticide Manufacturing and
Formulation Plant Bnissions 31
12 Production and Waste Schematic for DDT 37
13 Production and Waste Schematic for Atrazine 45
14 Decision Process for Determining the Nature of an Qnission
Constituent 51
B-l Production Distribution for 22 Major Pesticides B-10
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TABLES
Number paee
1 Pesticide Classes by Purpose 4
2 Chemical Classification of Pesticides 6
3 Master List of Pesticide Manufacturers and Formulators in
the U. S. by EPA Region 8
4 Number of Pesticide Manufacturing and Formulation Sites . . . 13
5 Pesticide Manufacturers Producing a Large Number of Active
Ingredients at a Single Location 17
6 Pesticide Development Costs - 1976 21
7 General Factors Relevant to the Pollution Potential of
Pesticide Active Ingredients. ..... 48
8 Threshold Limit Values of Various Pesticides 57
9 Summary of Candidate Pesticides as Selected by Three
Alternate Methods 69
10 U.S. Production of Synthetic Organic Pesticides, By Usage
Category, in 1974 72
11 U.S. Production of Synthetic Organic Pesticides, By Chemical
Groups, in 1974 73
12 Estimated U.S. Production and Toxicity Ratings of Major
Individual Synthetic Organic Pesticides, By Chemical Group
in 1974 75
13 Priority Ranking of Individual Synthetic Organic Pesticides
for Detailed Source Assessment 81
14 Priority Ranking of Individual Synthetic Organic Pesticides
for Detailed Source Assessment, by Chemical Group 86
vi
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TABLES (Continued)
Number Page
15 Priority Ranking of Synthetic Organic Pesticides For
Detailed Source Assessment by Chemical Group and
Manufacturer 90
16 Candidate Pesticides Selected by Priority and Manufacturer. . 93
17 Individuals Contacted to Discuss Anticipated Regulatory
Pressures Facing Pesticide Manufacturers 98
18 Major Anticipated Areas of Regulatory Interest 99
B-l U.S. Production of Synthetic Organic Pesticides, by
Category, in 1974 >4
B-2 U.S. Production of Synthetic Organic Pesticides, by
Chemical Group, in 1974 B-5
B-3 Estimated U.S. Production of Major Individual Synthetic
Organic Pesticides, By Category, in 1974 B-6
B-4 Uses, Classes and Production Volumes of Selected Pesticides . B-9
B-5 Summary of Manufacturing Wastes and Disposal » B-15
D-l Air Emission Pollutants Generated by Pesticide Manufacturers. D-2
D-2 Raw Wastewater Characteristics of Organic Pesticide
Manufacturers ....... ...... D-3
D-3 Raw Wastewater Characteristics of Organic Pesticide
Formulators D-6
D-4 Measured Wastewater Quality of Selected Inorganic Pesticide
Manufacturers D-7
D-5 Organic Pesticide Manufactures' and Formulators' Final Waste-
water Effluent Quality Measured After Treatment D-8
D-6 Solid Wastes Generated by Pesticide Manufacturers and
Formulators D-9
D-7 National Pollutant Discharge Elimination System, Discharge
Monitoring Report - Atrazine D-10
vii
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TABLES (Concluded)
Number Pace
D-8 National Pollutant Discharge Elimination System, Discharge
Monitoring Report - Herbicides D-12
J-l Pesticide Priority Rating J-3
J-2 Summary of Ratings J-7
J-3 Pesticides Recommended for Study J-8
K-l Estimated U.S. Production and Toxicity Ratings of Major
Individual Synthetic Organic Pesticides, by Category,
in 1974 K-6
K-2 Pesticide Toxicity Ratings K-8
K-3 Plant Location, Company Ownership, Number of Pesticides
Produced, and Rating for Each Pesticide Manufacturing
Plant in the U. S in 1975 K-9
K-4 Plant Location and Company Name of Pesticide Producers that
Manufactured the Major Synthetic Organic Pesticides, in
Each Group, in 1975 K-16
K-5 Summary of Important Characteristics of Each of the 25
Best Candidate Pesticide Plants for Detailed Source
Assessment K-2 6
viii
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SECTION 1
INTRODUCTION
In December 1975, Midwest Research Institute (MRI) was asked by the
Industrial Environmental Research Laboratory, Research Triangle Park, (IERL-
RTP), of the U.S. Environmental Protection Agency (EPA) to assist the
Monsanto Research Corporation (MRC) of Dayton, Ohio, in assessing the need
for emissions control technology development for the pesticide manufacturing
industry. MRC was under contract to IERL-RTP to provide source assessments
of air emissions for various segments of American industry including the pes-
ticide industry.
The primary objectives and responsibilities of the MRI effort were:
• Provide support to MRC in identifying relevant factors for the devel-
opment of decision criteria for establishing if a given pesticide man-
ufacturing industry requires development of emissions control technol-
ogy.
• Select, recommend, and defend by logical argument an initial list of
the six individual pesticides (i.e., six pesticide manufacturing in-
dustries) most worthy of detailed source assessment regarding potential
environmental insult.
Secondary objectives included the following:
• Review and update the 1972 MRI document, '*The Pollution Potential in
Pesticide Manufacturing" (Technical Studies Project TS-00-72-04j NTIS
PB-213 782/3), regarding pesticide emissions data; pesticide active
ingredient identification, production volume, and toxicity data; and
quantifying, wherever possible, the information presented in the Sum-
mary Section.
• Identify and describe the roles of all government groups actively in-
volved in the study of the pesticides manufacturing industry which
could serve as sources of information pertaining to the need for de-
velopment of emission control technology. Identify individuals within
groups who might serve as possible interfaces*
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• Identify and assess regulatory pressure and posture now in force as
well as anticipated trends*
• Make available to MRC any data on pesticide manufacturing emissions
(air, water, and solid waste) which MRI possesses.
Guidelines regarding the relevant factors for determining decision cri-
teria for emissions control technology development for the pesticide manufac-
turing industries included, but were not limited to, the following:
1* Comparison of unacceptable human exposure from manufacturing emis-
sions with that from field formulation and application.
2. Potential seriousness of exposure in terms of (a) acute health ef-
fects and (b) chronic health effects.
3. Potential for mobilization of pollutants from past waste disposal
practices (e.g., leaching from buried waste), persistence, transportability,
etc*
4. Comparison of environmental risks between manufacturing and formu-
lating operations.
5» Availability of control technology.
Methodologies to accomplish the objectives within the guidelines pre-
viously given included contact with manufacturers and formulators of pesti-
cides; contact with various governmental groups and agencies involved in the
pesticide industry; an examination of recent technical and economic litera-
ture on pesticides including governmental documents; an examination of re-
ports, documents, and files within MRI; and discussions with several knowl-
edgeable persons having contact with MRI.
The early sections of the report are concerned with pesticides as eco-
nomic poisons, the characterization and the quantification of the pesticides
manufacturing industries. Data are offered in the form of tables, graphs,
and charts to give a macroeconomic view of the pesticides manufacturing and
formulating industries.
The body of the report first addresses the selection of relevant factors
to gain perspective of the pollution potential from pesticide manufacturing
and formulating operations and leads to the evolvement and defense of a set
of factors for assessing the need for development of emissions control tech-
nology.
-------
The body of the report next addresses the selection of candidate pesti-
cides worthy of detailed source assessment* From a potential listing of some
1,200 pesticide active ingredients, a subset of six candidates worthy of
detailed source assessment was chosen and defended.
The report closes with a section on governmental regulatory pressure
and posture* Future trends likely to develop are assessed*
A series of appendices contains much information on the pesticide in-
dustry and the potential for pollution from several vantage points and in-
dicates the pervasive nature of the pesticide data base.
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SECTION 2
CHARACTERIZATION OF THE PESTICIDE INDUSTRY
PESTICIDE CLASSES
A broad definition of "pesticides" includes those chemicals or classes
of chemicals used to control various kinds of pests in order to increase
food and fiber production or to better free us from disease and objectionable
plants, animals, and other organisms* Pesticides can be classified according
to several organizing principles as will be seen below.
Pesticides are usually classified by the kind of pest they control, pur-
pose of application, or a mode of action on a pest. Table 1 presents current
general usage categories of pesticides*
Table 1. PESTICIDE CLASSES BY PURPOSE
Algicides (A) Herbicides (H) Pheromones
Defoliants (DF) Insecticides (I) (attractants) (P)
Dessicants (D) Larvacides (L) Repellants (R)
Fumigants (FU) Miticides Rodenticides (RO)
Fungicides (F) (acaricides) (M) Sterilants (S)
Growth regulants— Molluscicides (MO) Synergists (SN)
insect and plant Nematocides (N)
(IGR, PGR)
The above classification is not mutually exclusive. A pesticide active in-
gredient may be useful for controlling more than one type of pestj e.g.,
aminocarb, a carbamate, can be classified by (I, M, MO); DBCP, a halogenated
hydrocarbon by (FU, N); endrin, a halogenated aromatic compound by (I, R0)j
Vapam®, a dithiocarbamate by (F, H, N).
Pesticides are often classified to reflect aspects of their chemistry.
The Mrak Commission Report,!/ for example, grouped all pesticides into eight
major types according to their biological activity (i.e., insecticides and
miticidesj fungicides and bactericides; herbicides, defoliants, and dessicants;
nematocides; rodenticides and mammalian biocides; molluscicides; piscicides;
-------
and avicides) but identified about 45 subgroups based on chemical structure
or origin. In another study, 550 pesticidal chemicals were classified into
seven major groups with 44 subgroups according to those aspects of their
chemical structures that were pertinent to disposal of unused pesticides .I/
A 1972 study of the pollution potential in pesticide manufacturing considered
not only the chemical structures and properties of pesticides but also the
production volumes of various use or structure categories in order to select
representative pesticides.2' A 1975 study of the pesticide industry grouped
pesticides into 12 industrial segments according to chemical structures and
reactions «-t'
In the present study, we have found it most convenient to categorize
pesticides primarily according to the production process chemistry. Eleven
categories have been adopted as shown in Table 2 and have been ordered to
reflect to a substantial degree the production volumes of the various cate-
gories. This classification will be discussed in more detail in subsequent
sections.
MANUFACTURING AND FORMULATING OPERATIONS
The pesticides industry includes manufacturers of active ingredients
(who may also formulate pesticide products) and formulators who combine active
ingredients with other substances to yield pesticide products. Both activities
involve packaging and shipping. Both activities are possible sources of toxic
pollutants.
It is essential to distinguish clearly between manufacturers and formu-
lators of pesticides. The pesticide manufacturer takes raw materials (indus-
trial chemicals and intermediates) and by relatively low energy processes
(compared to energy intensive industries such as the metallurgical industry)
transforms them into active ingredients. By-products, intermediates, and
wastes are significant factors in the manufacturing process and each can con-
tribute to the overall pollution potential of the process. In some cases, the
raw materials or wastes are as hazardous as the desired product.
The formulator combines, primarily through simple mixing or blending op-
erations, the active ingredient with other materials (e.g., surfactants, clays,
powders, solvents, etc.) to yield the pesticide formulation. In essence, the
formulator dilutes the active ingredient or renders it more convenient for
handling and use by the consumer.
The formulator usually has no intermediates or by-products and few wastes
unless an error occurred in the formulation process. Wastes result regularly
from cleanup of process equipment, tank cars, and container disposal. Occasion-
ally, off-specification products are obtained because of improper mixing or
blending, contamination from a previous mixing operation, off-specification
active ingredient or other ingredients, packaging problems, etc. If an
5
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Table 2. CHEMICAL CLASSIFICATION OF PESTICIDES
Classification
I. Chlorinated hydrocarbons
II. Organophosphates
Phosphates
Phosphorothioates
Phosphorodithioates
III. Carbamates
Carbamates
Thiocarbamates
Dithiocarbamates
IV. Triazlnes
V. Anilides
VI. Organoarsenicals
and organometallies
VII. Other nitrogenous
compounds
VIII. Diene-based
IX. Ureas and Uracils
X. Nitrated hydrocarbons
XI. Miscellaneous category
Bacterial
Viral
Pheromones
Growth regulators
(insect and plant)
Other synthetic organics
Examples
DDT, toxaphene
Monocrotophos
Methyl parathion
Fensulfothion
Malathion
Merphos
Carbaryl, Bux®
EPTC, vernolate
Maneb, zineb
Atrazine
Simazine
Propachlor
Alachlor
MSMA, DSMA
Copper naphthenate
Captan
Maleic hydrazide
Chlordane
Endrin
Bromacil
Diuron
Trifluralin
Chloropicrin
B. thuringiensis
Ilcar®
Di spar lure®
Altosid
Methyl bromide
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off-specification product cannot be reworked or reblended with other acceptable
products, the pesticide product becomes waste and must be handled and disposed
of properly. Thus, a pollution potential exists for each type of operation.
PRODUCTION QUANTITIES AND NUMBERS OF PESTICIDES AND FORMULATED PRODUCTS
The 1974 production volumes of all synthetic organic pesticides have been
estimated on this program. The results for the major synthetic organic pesti-
cide groups and individual pesticides show that about 1.42 billion pounds of
pesticide active ingredients (AI) were produced in 1974, consisting of 37 major
pesticides (those produced in volumes of 10 million pounds or more), which ac-
counted for a combined production of 1.04 billion pounds or 74% of the market.
The remaining 26% was divided among about 300 other pesticides. A total of 140
to 150 synthetic organic pesticides are estimated to have had production vol-
umes in excess of 1 million pounds in 1974.
The Stanford Research Institute Directory of Chemical Producers indicates
that approximately 50 pesticide active ingredients can also be classified as
industrial chemicals, e.g., acrolein, formaldehyde, sulfur, etc*2/ These are
identified in Appendix A and are considered to be outside the scope of work
since their main usage lies in the nonpesticide areas.
EPA1s Office of Pesticide Programs (OPP) has estimated that in 1975 there
were 1,200 pesticide active ingredients registered for use in pesticide prod-
ucts. This estimate is based on the assumption that some active ingredients
have multiple uses; the 1,200 estimate counts each active ingredient only
onceJi/
These active ingredients are formulated in 23,633 different pesticide
products (as of October 23, 1975) at 5,353 registered formulating plants (as
of July 9, 1975) throughout the United States. These plants are registered
as follows: 4,111, interstate; 1,023, intrastate; and 218, foreign. (Note:
As of February 18, 1976, a total of 5,799 plants were engaged in the pro-
duction and formulation of pesticides.)Z'
LOCATION OF PESTICIDE MANUFACTURERS AND FORMULATORS IN THE U.S.
EPA maintains a data base of pesticide manufacturers and forraulators by
region in the United States; this information is given in Table 3.£/
The heaviest concentrations of pesticide manufacturers and formulators
are in the Middle Atlantic States, the Great Lakes States, Florida, Texas,
and California. Figure 1 presents the location of approximately 5,800 pesti-
cide manufacturers and formulators, by state, as of February IS, 1976.
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Table 3. MASTER LIST OF PESTICIDE MANUFACTURERS AND FORMULATORS IN THE U.S. BY EPA REGION
Alabama
Alaska
Arizona
Arkansas
California
Colorado
Connecticut
Delaware
District of
Columbia
Florida
Georgia
Hawaii
Idaho
Illinois
Indiana.
Iowa
Kansas
Kentucky
Louisiana
Main*
Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
Montana
Nebraska
Nevada
Mew Hampshire
New Jersey
New Mexico
New York
North Carolina
North Dakota
Ohio
Oklahoma
Oregon
Pennsylvania
Rhode Island
South Carolina
South Dakota
Tennessee
Texas
Utah
Vermont
Virginia
Washington
West Virginia
Wisconsin
Wyoming
Puerto Rico
Other possessions
Total
III
EPA Region
38
11
6
18
101
71
10
239
233
190
19
95
30
26
189
518
403
Grand total establishments • 5,825
February 18, 1976
108
421
291
123
52
150
57
166
1,368
VI VII VIII
31
302
125
162
81
111
126
104
219
39
241
13
41
388
131
55
625
69
20
15
24
16
52
43
28
99
128
1,029 584 551 153 760 270
Grand total establishments in U.S. - 5,799
8
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Alaska
None
Hawaii
52
Total: 5,799
Figure 1. Location of pesticide manufacturers and formulators, by state, 1976.
-------
The distribution of pesticide manufacturers in the United States can be
obtained from the Stanford Research Institute Directory of Chemical Producers ..5_/
The data are presented in Figure 2 which shows that there are 139 pesticide
production plants.* The states which have the most pesticide active ingredient
manufacturers are New Jersey and California.
From the data given in Figures 1 and 2, the locations of pesticide forrau-
lators can be derived. Figure 3 presents the locations of 5,660 pesticide for-
mulators, by state, as of February 18, 1976.
Since there are 5,799 manufacturing and formulating sites but only 139
manufacturing sites, the information contained in Figures 1 and 3 is similar
and shows the same general distribution in the United States. Table 4 summarizes
this data, and shows the total number of manufacturing and formulating sites
in the United States, and the percentage of the total pesticides industry repre-
sented by manufacturers and formulators, respectively.
Many of the 139 manufacturing sites also formulate pesticides. The important
point to be noted is that formulation sites represent the larger number of po-
tential sources of pesticide emissions and wastes. This fact coupled with
limited capital for investment in emission control devices leads to the overall
conclusion that formulation operations have a serious pollution potential.
DISTRIBUTION OF PESTICIDES BY PLANT SITES
The preceding information regarding pesticide active ingredients, manufac-
turers, and sites can be recast to yield a distribution plot of the number of
individual active ingredients in relation to the number of plants which produce
them. This arrangement shows how many individual active ingredients are produced
by only one plant, how many are produced by two separate plants, how many are
produced by three separate plants, and so on. Figure 4 presents the distribution
of 307 individual active ingredients and shows how many of these 307 active
ingredients are produced by only one plant, by two plants, by three plants,
etc. The obvious fact of importance is that 205 of these 307 active ingredients,
or about two-thirds of them, are produced at only one plant (though, of course,
there are many different plants that are the sole producers of the 205 active
ingredients).
The 205 pesticides manufactured by sole producers vary widely in quanti-
ties produced. In 1974, production of these pesticides ranged from 110 million
pounds atrazine (produced by Ciba-Geigy Corporation at St. Gabriel, Louisiana),
10 million pounds disulfoton (produced by Mobay Chemical Corporation, Kansas
City, Missouri), 3 million pounds nitralin (produced by Shell Chemical Company,
Denver, Colorado), to < 1 million pounds Perthane®(produced by Rohm and Hass
Company, Philadelphia, Pennsylvania).^'
These 139 plants exclude those which produce industrial chemicals also used
as pesticides.
10
-------
Alaska
None
Hawaii
None
Source: SRI Directory of Chemical Producers 1976
Total: 139
Figure 2. Location of pesticide production plants, by state, 1976
-------
Alaska
None
t 3
Hawaii
52
Total: 5,660
35
235
10
69
6(D.C.)
Figure 3. Location of pesticide formulators, by state, 1976,
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TABLE 4. NUMBER OF PESTICIDE MANUFACTURING
AND FORMULATION SITES
Type of Percent of
pesticide plant No* pesticides industry
Manufacturer 139 2.4
Formulator 5,660 97.6
Total 5,799 100
13
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210 i
Total Active Ingredients = 307
2 3 4 5 6 7 ' 8 ' 9
^Number of Plants Which produce Each Active Ingredient
Figure 4. Distribution of the number of individual active
ingredients produced at a specific number of plants.
14
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Beyond the sole production sites shown in Figure 4 we find that 54
active ingredients are manufactured at two sites, 21 active ingredients at
three sites, etc. There are two pesticides—(2,4-dichlorophenoxy)acetic acid,
n-butyl ester and the corresponding iso-octyl ester—which are manufactured
at 10 different locations each.
DISTRIBUTION OF PLANTS BY NUMBER OF PESTICIDES MANUFACTURED AT EACH PLANT
The same set of pesticide data by manufacturer and plant site can be
used to illustrate the distribution of plants by the number of individual
active ingredients manufactured at each plant site* Figure 5 presents this
distribution and again it is immediately apparent that the vast majority of
the plants produce only one or a few active ingredients. Thus, 59 plants
produce only one pesticide active ingredient, and 26 plants produce only
two. In contrast, Table 5 indicates those plants which produce a large num-
ber of different active ingredients.
These data must be qualified to the extent that the plants either man-
ufacture a given active ingredient or have the capacity of manufacturing a
given active ingredient. In general, pesticide companies do not simultaneously
manufacture their entire product line but do have facilities for production
of various active ingredients without extensive plant modification.
DISTRIBUTION OF PESTICIDE FORMULATIONS BY CHEMICAL CLASS AND TYPE OF
FORMULATION
Distribution data regarding pesticide formulations by chemical class
and formulation type are available from an earlier MRI report.AS' In par-
ticular, Figure 6 presents the distribution of the percentage of formula-
tion plants by the number of chemical classes of pesticide active ingredi-
ents formulated. Approximately 80% of the large formulation plants utilize
from one to three chemical classes of pesticide active ingredients. This
fact may be interpreted as meaning that certain companies specialize in
the manufacture and management of a limited number of product lines*
Figure 7 presents the distribution of the percentage of large formu-
lation plants by the number of physical types of pesticides formulated
(liquids, powders, dusts, granules, strips, baits, etc.). Approximately 627.
of the large formulation plants produce only one physical type of pesticide
formulation. In fact, nearly all (994%) of the formulation plants handle
only one to three physical types of formulations.
15
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60 n
50-
-40
o
2
o
1 30-J
1
-o
i 20
3
10-
Total Plants = 139
0 ' ] ' 2 ' 3 ' 4 ' 5 6789 10 11'121l3'14 15 16'17'18'19'20 21'22 23124I25'26'27'28129130'
Number of Active Ingredients Produced at Each Plant
Figure 5. Distribution of plants by number of active
ingredients produced at each plant.
16
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Table 5. PESTICIDE MANUFACTURERS PRODUCING A LARGE NUMBER
OF ACTIVE INGREDIENTS AT A SINGLE LOCATION
Company
Dow Chemical Company
Agricultural Division
Rorer-Amchem Company
Amchem Products Division
Mobay Chemical Corporation
Chemagro Agricultural Division
Ciba-Geigy Corporation
Agricultural Division
Transvaal, Inc.
Blue Spruce Company
Location
Midland, Michigan
Ambler, Pennsylvania
Kansas City, Missouri
St. Gabriel, Louisiana
Jacksonville, Arkansas
Edison, New Jersey
No. of
active
ingredients
produced
28
22
21
16
16
13
17
-------
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12345
Number of Classes Formulated
Classes: Organophosphate, inorganic, chlorinated
hydrocarbon, nitrogen based,and all
others
Figure 6. Distribution of large formulation plants by the number of
chemical classes of pesticide active ingredients formulated*
18
-------
ou
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Number of Physical Types Formulated
Types: Liquids,powders and dusts, granules,and
all others (strips, baits, etc)
Figure 7* Distribution of large formulation plants
by number of physical types of formulations*
19
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PESTICIDE DEVELOPMENT COSTS
The cost of introducing a new pesticide into the market has increased
from approximately $2 million in 1960 to $8 million in 1976.-iLlI/ These fig-
ures include research and development, testing, manufacturing and formulat-
ing, capital investment, registration requirements, and marketing costs. A
candidate pesticide that fails midway in the process can represent a signi-
ficant loss in investment and future revenues to the unlucky company. On the
other hand, a successful candidate can represent a highly lucrative product,
particularly if it has unique properties.
The previous cost estimates for the introduction of a new pesticide over
the last 16 years are distorted by inflation and are better interpreted in
terms of constant (1967) dollars* This is accomplished through the use of a
deflator or price index: 1960, 88.7; and 1976, 167.5. Thus, the estimated
total cost for research, development, testing, and marketing a new pesticide
in constant 1967 dollars is $2.2 million in 1960, and $5.0 million in 1976.
This amounts to a two-fold increase in noninflationary costs over 16 years.
There is no doubt that total costs have risen and that inflationary pres-
sures are only partly to blame. Noninflationary cost increases include at
least the following items:
* An increasing number of chemicals must be synthesized and investigated
for desired pesticidal activity before a successful candidate is found.
* Toxicology, metabolism, efficacy, and environmental testing requirements
have become more sophisticated.
* Marketing costs (distribution, promotion, and pricing decisions) have
increased due to competitive pressures.
* The time lag between discovery and introduction in the market place
has increased, thus requiring a greater expenditure of money, time,
and management efforts. It is now estimated that up to 100 months may
be required from discovery to final registration.il/
* The cost of capital for investment has increased significantly in the
last 4 years.
A pesticide company may research and test between 3,000 and 6,000 chemi-
cals in order to successfully market one new active ingredient ~2' Table 6 pre-
sents estimated costs to research, develop, test, register, and market a new
pesticide in 1976.
20
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Table 6. PESTICIDE DEVELOPMENT COSTS - 1976
9/
Cost (million $) Cost (million $)
Activity 1976 1967 = 100
Research and development 2*5-5.0 1.5-3.0
Synthesis and screening
Field testing and development
Formulation and process de-
velopment
Testing and registration 0.5 - 0.7 0.3 - 0.42
Toxicology, metabolism, and
label requirements
Manufacturing capital 3.0 - 4.0 1.8 - 2.4
investment
Formulating capital investment 0.0-0.4 0.0 - 0.24
Marketing development 0.25 - 0.5 0.15 - 0.30
Total, range 6.3 - 10.6 3.7 - 6.4
Total, average 8.5 5.0
PESTICIDE MARKETING ACTIVITIES FOR THE FRUIT INDUSTRY
The introduction of new pesticides has been rapid, especially since World
War II, which indirectly brought about the development of organophosphate esters
and chlorinated hydrocarbons of which DDT is the most well-known example. How-
ever, beginning about 1970, various factors slowed the growth rate of new pes-
ticides (new active ingredients), and four of these factors were:
1. The tremendous increase in total cost in developing a new pesticide
caused by capital equipment cost, inflation, and, to a lesser extent, by the
degree of sophistication and depth of information required for registration.
2. Adverse economic factors principally from cash flow problems, capital
investment in sophisticated plant and laboratory equipment, and high interest
rates, etc.
3* The effect of governmental legislation and regulation of the pesticide
industry.
21
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4. A slowing of scientific advancement and innovation in the field of
synthetic organic pesticides in the late 1960's and early 1970's.
Previous successes were largely based on pesticide research extending
as far back as World War II• In effect, pesticide research, in about 19/0,
had reached a technological plateau. The "first generation" pesticides
(chlorinated hydrocarbons attacking the central nervous system) and the
"second generation" pesticides (organophosphates and carbamates inhibiting
cholinesterase) resulted in the development of many pesticides differing
basically in the number and kind of substituents attached to a common group-
ing characterizing a class of pesticides (e.g., substituted nitrogenous
compounds or thio- and dithiocarbamates, etc.). These developments led to
many related pesticides being developed from 1944 to the late 1960's. A
technological plateau was reached in approximately 1968 and lasted to 1972
when the "third generation" pesticides (pheromones or insect communication
chemicals and insect and plant growth regulants) were commercially available.
Figure 8 indicates the historical time scale for the development of
modern synthetic organic pesticides. Omitted from this categorization of
synthetic organic pesticides are the well known bacterial pesticides, Bacillus
thuringiensis and jj. popillae. and the first viral pesticide, Elcar®, based
on Heliothis Zea» a nuclear-polyhedrosis virus, registered in 1976«
As an example of the recent decline in marketing activity of pesticides,
Figure 9 presents the number of "new" pesticides available to the fruit
grower from 1968 to 1976J^' The graph indicates total marketing activity
for pesticides as the sum of new (active ingredient) pesticides, new for-
mulations of old pesticides, and old formulations extended to new crops and
pests. The products refer to pesticide applications for fruit and ornamental
trees, berries, nuts, flowers, and vegetables. Beginning in 1968, the total
marketing activity for pesticides of importance to fruit growers rose from
25 products introduced annually to 36 products in 1973. From 1974 to 1976,
however, the number of new pesticide products for fruit growers has been
substantially lower, i.e., only 15 to 20 products per year. The actual num-
ber of new active ingredients introduced each year from 1970 through 1976
was approximately three, which indicates the development activity centered
upon older active ingredients combined into new formulations or extended to
other crops and pests*
The previous quantitative discussion applies only to the American fruit
growing industry. However, it is believed the trend toward fewer new pesti-
cide active ingredients being introduced annually is qualitatively true for
the entire pesticide industry. Figure 10 indicates the number of major pes-
ticides introduced in the United States from 1931 to date. These data are by
Dr. Wendell Mullison of Dow Chemical - USA-i3-"—
22
-------
Nitroani lines —
Chlorinated
Benzoic Acids
Organoarsenicals
Organomercurials
Other Organometollics
Nitrophenols
Chlorinated Hydrocarbons
Aldrin-Toxaphene Types
Warfarin, 1080-
YEAR
--1976-
--1972-
- -1968
I 1964
--I960
- ' 1956
- - 1952
- - 1948
•
-•1944"
••
- - 1940
Pheromones, Growth Regulants
Triazines
f-Quartenary Ammonium Salts
Corbamates, Thiocarbamates,
'Dithiocarba mates
Nitrogenous and Substituted
Ureas and Uracils
•Organophosphorus Types
r"Substituted Amides, Imides
Metal lo-Dithiocarbamates
Phenoxylalkanoic Acids,
'Esters and Salts
Chlorinated Hydrocarbons
DDT Types
Figure 8. Historical development of modern synthetic organic pesticides.
23
-------
40
35
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1 25
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^Active
J Ingredient
1968 1970 1972 1974 1976
Year
Figure 9. Aggregate marketing activity for
pesticides in the fruit industry*
24
-------
20
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UJ
D 15
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y ""
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ill
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1975
Figure 10. Number of major pesticides introduced from 1931 through 1975,
Source: Proceedings of the 30th North Central Weed Control
Conference, Milwaukee, Wisconsin, December 1975.
25
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CONCLUDING REMARKS CHARACTERIZING THE PESTICIDE INDUSTRY
Pesticide manufacturing primarily involves the production of one ac-
tive ingredient at one location, although as many as 28 active ingredients
can be manufactured at one location at present. Some pesticide manufactur-
ing operations are dedicated strictly to pesticide chemical production and
formulation (e.g., Chemagro Agricultural Division, Kansas City, Missouri),
while pesticides produced at other locations represent only a portion of
the total number of products produced (e.g., Dow Chemical Company, Midland,
Michigan; and Union Carbide Chemical Corporation, South Charleston and
Institute, West Virginia).
Active ingredient manufacturing operations are geographically concen-
trated in a few states and 16 states have no manufacturing sites. Alaska
has neither pesticide manufacturing nor formulating operations.
Formulators prefer to blend or otherwise combine various ingredients
to produce one physical type of pesticide formulation with one to three
chemical classes of active ingredient. However, as many as five chemical
classes of active ingredient and three physical types could be formulated
at large facilities.
Formulation operations are geographically dispersed in nearly 5,700
locations in the United States. The facilities are of varying sizes and
may be part of a chemical complex or a dedicated facility. An example of a
large facility is Thompson-Hayward Chemical Company, Kansas City, Kansas,
which principally manufactures 2,4-D and formulates several pesticides.
An example of a small formulator is the PBI - Gordon Corporation of
Kansas City, Kansas, which formulates pesticides on a seasonal basis and
augments their business volume by manufacturing automotive radiator anti-
freeze.
The pesticide industry is difficult to categorize in terms of pro-
cesses and operations. It is not like the steel industry which is composed
of a small number of manufacturers located principally in the Pittsburgh
metropolitan area and utilizing a limited number of processes; nor is it
like other portions of the chemical industry, e.g., the bromine industry
concentrated in Arkansas and Michigan and dominated by six producers and
essentially one process; nor is it like the vinyl chloride industry com-
posed of 11 companies located at 15 sites and utilizing four different
processes. It is possible to describe the vinyl chloride manufacturing op-
eration in terms of a representative facility having measured and/or esti-
mated emission rates. The chemistry of the emitted pollutants from a vinyl
chloride plant is well-known. A threshold limit value (TLV) has been estab-
lished. The pesticide industry cannot be similarly categorized nor have
emissions standards been established for many pesticide active ingredients.
26
-------
One feasible methodology for assessing the pesticides industry is to
take into account the previously described characteristics of the pesticides
industry and to examine the pollution potential of various different active
ingredients by assessing the manufacturers of those active ingredients* This
can be achieved by selecting active ingredients which have a high pollution
potential. Section 4 presents the methodology used in this study to select
the individual pesticides for future detailed source assessment.
27
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REFERENCES TO SECTION 2
1. Mrak, E. M. Report to the Secretary's Commission on Pesticides and Their
Relationship to Environmental Health. U.S. Government Printing Office,
Washington, D.C., December 1969.
2. Lawless, E. W., T. L. Ferguson, and A. F. Meiners. Guidelines for the
Disposal of Snail Quantities of Unused Pesticides. EPA-670/2-75-057,
June 1975.
3. Lawless, E. W., R. von RUmker, and T. L. Ferguson. The Pollution Potential
in Pesticide Manufacturing. NTIS PB-213782/3, June 1972.
4. Honea, F. I., D. Punzak, E. W. Lawless, L. J. Shannon, and D. Wallace.
Pesticides Industry. Environmental Protection Agency, Research Triangle
Park, North Carolina, June 1975.
5. Chemical Information Services. Directory of Chemical Producers -
United States of America. Stanford Research Institute, Menlo Park,
California, 1976.
6. Pesticide Chemical News. June 25, 1975. pp. 15-16.
7. Personal Communication Between Gary Kelso and EPA Representative in
Washington, D.C.
8. Pesticide Enforcement Division. Environmental Protection Agency,
Washington, D.C., February 18, 1976.
9.. MRI Estimate Based on Industry Sources.
10. Ferguson, T. L. Pollution Control Technology for Pesticide Formulators
and Packagers. EPA-660/2-74-094, January 1975.
11. Chemical Marketing Reporter, May 17, 1976. p. 46.
12. Anerican Fruit Grower. (1968 to 1976 inclusive).
13. Mullison, W. Proceedings of the 30th North Central Weed Control Confer-
ence. Milwaukee, Wisconsin, December 1975.
14. Dow Chemical Company - USA. A Closer Look at the Pesticide Question for
Those Who Want the Facts. Midland, Michigan, 1976.
28
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SECTION 3
POLLUTION POTENTIAL IN PESTICIDE MANUFACTURING AND FORMULATION
An EPA document issued in 1972 surveying the potential for pollution aris-
ing from pesticide manufacturing operations outlined in detail hazards arising
from raw materials, active ingredients, production processes, storage, handling,
and shipping..!/ The report also considered the pollution potential arising
from by-products, intermediates, wastes, cleanup and decontamination of equip-
ment, and included a discussion of safety practices* Except for updating of
production volumes, toxicity data, and including effluent discharge permit
information, the general conclusions and recommendations outlined in the re-
port are valid today. Indeed, the continued widespread usage of pesticides,
the general increase in production volume of pesticides, and the overall pollu-
tion potential dangers as recognized by EPA, state, and local officials re-
emphasize the validity of the conclusions and recommendations. Appendices B
and C contain recent information on pesticide production volumes, toxicity
data, and a general updating of the Summary Section contained in the 1972
document.
Briefly, the conclusions contained in the 1972 document can be updated in
terms of air, water, and solid emissions from the manufacturing sites as follows:
1. Air emissions are generally not regularly monitored by any agency or
organization. A limited amount of air emission data for pesticide facilities
is available through some state agencies, e.g., California and Louisiana.
Presumably there have been some air surveys taken by the pesticide manufactur-
ers themselves, but any hard data are held in strict confidence. Existing data
on air emissions that MRI have uncovered are contained in Appendix D.
2. Water discharges to navigable rivers or their tributaries are regu-
lated through the discharge permit system, National Pollutant Discharge Elimi-
nation System (NPDES). Dischargers with NPDES permits are required to file self-
monitoring discharge reports with EPA regional offices or approved state agen-
cies on a regular basis using an NPDES Monitoring Discharge Form. The report
contains actual discharge data from the manufacturing or formulating facilities
and indicates actual quantities of chemicals discharged over a given period
of time, e.g., pounds of active ingredient per day. An excellent discussion
of the national discharge permit system and information regarding compliance
by C. J. Schafer and N. Lailas of EPA is readily available.-2-' Copies of NPDES
Discharge Monitoring Form for the Ciba-Geigy Corporation herbicide plant at
St. Gabriel, Louisiana, and for the Monsanto Company herbicide plant at
Muscatine, Iowa, are reproduced in Appendix D, Tables D-7 and D-8, respec-
tively. Copies of the applications for permits to discharge and the discharge
data are available through EPA.
29
-------
Sophisticated water treatment systems have been installed by many manufac-
turers to comply with existing legislation. However, some manufacturers dispose
of liquid wastes by evaporation ponds, deep well injection, discharge to munic-
ipal sewers or transportation to off-premises disposal sites (e.g., approved
landfills, disposal service companies, etc.). Wastewater discharges could repre-
sent a significant pollution potential, but data in these areas are sparse.
Water discharge data compiled by MRI are contained in Appendix D.
3. Solid waste disposal continues to be an unknown factor. Oftentimes
solid waste is disposed by landfill operations on the manufacturing or formu-
lating site and is not monitored nor regulated. Alternately, contract waste
collectors will remove the solid waste materials with little or no knowledge
of the composition of the wastes being handled. Solid waste discharge data
available to MRI are contained in Appendix D.
THE PESTICIDE FACILITY AS AN INPUT-OUTPUT SYSTEM
A manufacturing or a formulation plant may be viewed as an input-output
system and emission and control points readily identified. Figure 11 presents
such an overview and indicates emission points, control device points, various
discharge routes, and intermedia transfer points.
In a general sense, air emissions from the pesticides industry are anal-
ogous to emissions from conventional chemical manufacture. Emissions, includ-
ing particulates and gases from the manufacturing process,emanate from various
pieces of equipment and enter the atmosphere as raw materials, intermediates,
by-products, and the active ingredient itself. Several air emission control
devices are available such as baghouses, filters, carbon sorption units, cyclon«
separators, electrostatic precipitators, gas scrubbing units, and incinerators
for purposes of trapping, separating, washing and otherwise collecting or com-
busting gases and particulates.
Two facts regarding control devices for air emissions from the pesticide
industry must be noted: (a) except for incinerators, these devices transfer
the highly toxic materials from the gases and particulates in the "gas" phase
to the solid or liquid phase; and (b) unless the air emissions are chemically
transformed or destroyed by the control device, the hazardous materials remain
unchanged. The net result is that the hazardous air emissions are concentrated
into a presumably more convenient form for recycling back through the process,
further treatment, or decontamination if necessary.
Liquid or solution discharges of hazardous materials can include all of
the previous types of raw materials, intermediates, byproducts, active ingre-
dient, etc.., plus those discharges from the air emission control devices which
30
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Air Emissions
Evaporation
i
Chen
Treat
1
ment
Contract
Disposal
of Sludges
Unknown
Routes for
Disposal
Soli<
Wasl
Emis
i
1
e
sions
Ground
Contamination
Runoff
Leaching
Evaporation
Biodegrodation
i
Air Em
Contra
Device
i
itsions
,
Pesticide
Manufacturing
Formulating
Plant
i
Product Warehouse
Protection Devices
I
Liquid and
Emissions
Distributor
— •» and
Consumer
Fires, Explosions
Floods. Vandalism
Multimedia
Contamination
1
Agricultural
Runoff
Leaching
Biodegradation
Container Disposal
Evaporation
Chemical Treatment Discharge to
[Evaporation Pond ~| or NPDES Permit
Pond Lining |
j Leakage '
- . Environment
Ground
Contamination
Runoff
Leaching
Evaporation
Biodegradation
Figure 11. Schematic representation of pesticide manufacturing
and formulation plant emissions
-------
yield liquid concentrates, e.g., solutions from scrubbers. The liquid or solu-
tion discharges should receive a chemical treatment depending on the specific
nature of hazardous material to be destroyed. Generally this would involve
hydrolysis, neutralization, or an oxidation reaction.
Some manufacturing or formulating plants utilize activated sludge waste
treatment to dispose of pesticide wastes. Special chemical pretreatraent may be
required to insure effective and continuous biota performance; otherwise, the
biodegradation process may cease altogether if the organisms become poisoned
with toxic materials, e.g., chlorinated solvents, chlorinated phenols, bis-
phenols, etc.
Oftentimes the liquid wastes go to a holding pond or lagoon after chemical
treatment. In some instances this may be the end of the treatment process for
liquid wastes; e.g., the manufacturers or "forraulators may simply allow evapor-
ation to occur and periodically recover a sludge from the pond or lagoon by
dredging. However, pollution potentials exist during the evaporation or holding
period. For example, evaporation of undestroyed hazardous material could occur,
resulting in transfer to the atmosphere, and thus negating the previous benefits
obtained from the air emissions control device. Leakage through unlined ponds
can also occur whereby hazardous material enters the ground at the plant site
and establishes a potential leaching or runoff problem or a potential ground-
water contamination problem. Some holding ponds may also be subject to overflow
from runoff of surface waters during heavy rains.
If, after chemical treatment and partial evaporation, the manufacturer or
formulator discharges to a navigable stream or river, then the effluent is
regulated by the NPDES permit and the operator is responsible for his actions
at that point.
Liquid and solution discharges may escape detection by regulatory or mon-
itoring agencies if the wastes are discharged to a municipal sewer system.
Only if the discharges are to navigable waters do they come under the jurisdic-
tion of the Clean Water Act.
Solid discharges and solids collected by the air emission control devices
leave the pesticide plant and may or may not have chemical treatment prior to
disposal. These alternatives are chosen at the discretion of the operators.
Oftentimes solid discharges as by-products, off-specification active ingredi-
ent that cannot be reworked, contaminated nonrecoverable materials, empty and
contaminated drums, etc., are simply buried on the property. This practice
can create potential leaching and runoff problems in addition to re-evaporation
of semivolatile materials.
Contract disposal of solid and liquid wastes is a prevalent and a growing
business. Contractors are regulated to some degree, but often they have little
information on the composition of the waste mixtures and may not be able to
determine if the wastes have been rendered harmless.
32
-------
Finally) the product as active ingredient or formulated material is packaged
and enters the warehouse for temporary storage. A pollution potential exists in
the form of fires, explosions, floods, vandalism, neglect, etc. If the contents
of warehouses are not protected against any of the above potential dangers, then
gross environmental insult could occur. Sprinkler systems, smoke and heat detec-
tors, electrical grounding, dikes around the warehouse, fences, security patrols,
etc., are all recommended methods for reducing the danger of pollution.
The various types of emissions from manufacturing and formulating operations
include but are not limited to the following:
Bnission Type Waste Materials
Air Evaporation losses as methanol, hydro-
carbon solvents, and from intermediates,
by-products, active ingredient (Al),
and organic sludges.
Liquid Methanol, hydrocarbon solvents, intermediates,
by-products, AI, aqueous and solvent losses
from cleaning and rinsing operations of
cans, drums, and process equipment.
Solid Intermediates, by-products, AI, NaCl,
NaCN, Na2S04, (NH^SO^ HN03, HC1,
chlorinated phenols, bis-phenols, con-
taminated cans, drums, bags, etc.
Control technology (procedures, devices, apparatus, etc.) is presently
available to alleviate, transform, capture, and otherwise control and/or con-
tain pesticide emissions. Excellent discussions of procedures and control de-
vices appropriate to the pesticide manufacturing and formulating industry are
avail able^ll/
Examples of gross contamination of the environment with resultant risk
to all forms of life from pesticide plants are readily available. During the
short period of this contract, January through April 1976, the following inci-
dents became publicly known:
1. Full disclosure of the events leading up to the Kepone®incident by
Allied Chemical and Life Science Products Company of Hopewell, Virginia, wherein
plant workers allegedly became seriously ill from the manufacture of Kepone®
and the subsequent illegal discharges of tonnage quantities of off-specification
active ingredient into the James River .£'
33
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2. A pesticide warehouse fire at FMC Corporation of Binis, Texas, caused
600 persons to be evacuated from their homes when potentially poisonous fumes
threatened the community. The force of the explosion hurled 55-gal. drums hun-
dreds of feet into the air.2'
3. Caseous emissions as foul-smelling odors from Central International
Chemical Corporation of Liberty, Texas, caused citizen complaints and resulted
in a continuous monitoring program to be set up by the Texas Air Control Board .
The three cases of pollution and environmental contamination previously
described represent a wide range of pesticide emission problems. The emissions
from the Kepone® plant consisted of aqueous and solvent wastes heavily laden
with active ingredient which were ineffectively treated prior to release into
the James River. Further, large quantities of off-specification technical mate-
rial were apparently disposed of as solid material rather than re-worked or
blended with acceptable batches of active ingredient. Inadequacies in control
technology are presumably not at fault in this case.
The pesticide warehouse fire represents a catastrophic situation which
resulted in active ingredient, formulated products, thermally degraded sub-
stances, noxious gases, particulates, etc., being suddenly released into a
community in the form of gases, vapors, particulates, and other debris. While
such events are rare and protection devices are available to protect the con-
tents of the warehouse, situations such as these do occur and represent a very
real danger to workers, the community, and the environment.
The last case involved eases and/or particulates released from a pesticide
facility formulating Imidan^T This phosphorodithioate has a particularly offen-
sive odor and is easily detected by the olfactory nerves. Imidan®raay be form-
ulated as a 20 to 30%, by weight, emulsifiable concentrate or as a 50% wettable
powder.
Anbient air samples taken downwind from the facility and near the plant
property line indicated 0.5 to 1.5 mg/nP of Imidan®. The Central International
Chemical Corporation has subsequently installed carbon filters in the hoods
and ventilating systems to alleviate this nuisance problem.
As stated earlier, manufacturers and femulators must monitor various
plant emissions and report these data as required by the NPDES permit and/or
various state regulatory agencies. They may also monitor the general chemical
operations for their own source of information to determine if the processes
are in control. This would be done by performing material balance calculations
on an input/output basis and would be a matter of good economics and business
sense.
Manufacturers and formulators would prefer to operate with a near 100%
material balance, but as a matter of practicality a small and variable
34
-------
uncertainty, e.g., 2 to 3%, in the material balance study is permitted. The un-
certainty is often related to analytical statistical variation; e.g., an indus-
trial analytical method is rarely better than + 1% and in most cases is between
1 to 2%. Variations in process conditions and operation of equipment can also
introduce uncertainties in the material balance of 1 to 2%. In general, how-
ever, losses of any kind—raw materials, intermediates, and active ingredient
(Al)~represent dollar losses and will be controlled and/or eliminated to some
extent through competitive pressures.
Certain manufacturing and formulating operations such as combining (mixing
or blending) raw materials and/or intermediates can be made highly efficient,
near 99%, with only ** 1% physical handling loss. However, if a grinding opera-
tion is encountered leading to fine particle and/or dust generation, a 96 to
97% recovery may exist. The losses amounting to 3 to 4% are due to escape of
fine particles and moisture. Such losses are difficult to reduce because of
the very nature of the material and/or the process*
As two examples of viewing the pesticide manufacturing or formulating
facility as an input/output system we shall examine the Montrose DDT plant
at Torrance, California, and the Ciba-Geigy herbicide plant at St. Gabriel,
Louisiana. These examples were chosen because the emissions data are reason-
ably complete in contrast to emissions data for other facilities and active
ingredients thus far uncovered. The authors of this report do not intend to
single out these facilities and active ingredients as being representative-
of the pesticide manufacturing industry. Undoubtedly other cases could be ex-
amined in a similar manner if only the appropriate data were available.
9/
DDT Manufacture""
DDT is currently manufactured at only one plant in the United States, the
Montrose Chemical Corporation facility at Torrance, California. The plant also
prepares DDT formulations. The current production capacity is about 85 million
pounds of DDT per year. The 1975 production rate for DDT at this plant is re-
ported to be about two-thirds of capacity. The rate of production is essentially
constant during the year. Montrose produces technical grade DDT for sale to WHO,
AID, and directly to foreign nations in the Northern and Southern Hemispheres.
DDT (dichloro-diphenyl-trichloroethane) is a name that covers a few iso-
mers, the most active of which is l,l,l-trichloro-2,2-bis(|j-chlorophenyl)ethane.
Its manufacture is relatively simple: it is made by condensing monochloroben-
zene and chloral in the presence of concentrated sulfuric acid.
35
-------
Production Chemistry
C.H..OH + Cl, > CC1,CHO.
25 I J ^ 1 u on/
, ff* 4> CC1.CH(C,H,C1)_ + H-0
J\ 2. NaOH 3 642 2
C6H6 + C12 —* C6H5C1
75-80%, p,p'-isomer
15-20%, o,p'-isomer
plus related compounds
including DDD and DOE*
The biggest problems in DDT manufacture are in the recovery of unreacted
ingredients and in steering the reaction toward production of the desired iso-
mer. The reaction is kept below 30°C and takes place at atmospheric pressure
in a stirred batch reactor system.
DDT recovery is by crystallization. Impure DDT is washed with a caustic
solution. The washed DDT is then dried and crystallized into solid material.
A production and waste schematic for DDT is presented in Figure 12. The manu-
facturing process is continuous except for batch input to the first stage of
the reactor. The plant operates on a three shift per day, 7 days a week basis,
except for routine maintenance and lost time caused by breakdown in operating
equipment. The on-stream time each calendar year is reported to be 360 days.
Data for the Montrose DDT operations at Torrance, California, for produc-
tion equipment, raw materials, by-products, and other process wastes and losses
are listed below.
Production Equipment
Process continuity: semibatch Est. annual production: 60 MM Ib/year (1975\
Equipment dedication: DDT only Plant capacity: 85 MM Ib/year
Equipment age: Not available Formulation on site: Yes
Raw Materials
Material Received from Received bv Storage
1. Chloral Henderson, Nevada Tank cars Steel storage tanks on plant
site
2. C6H5C1 Henderson, Nevada Tank cars Steel storage tanks on plant
site
* DDD is 2,2-bis(£-chlorophenyl)-l,l-dichloroethane; DDE is dichlorodiphenyl-
dichloroethylene.
36
-------
CO
NaOH
Vent f
t i
' J , , Liquid Waste _ ,
Scrubber 3
Vent and C0H5CI Recycle
1 t"
L — ^ —
Reactor DPI
""*" (2-Stage) Separator
1
Spent
Acid
Recycle Add We
Acid ^ Plant""' Ac
Liquid
Wastes
t
DDT
Waj
Dili
Cau
Floor and
Surface
H2° Drains
1 • . 1
* Labs and 1
Wash-Up 1 1
""~1 ^-^\
r Crystallizer 1 Technical \^ F<
her -^ Dryer -H DDT r^ p|
Flaker \ /
jte f
|$Hc Package
L_ *
Vent
Baghouse
'
emulation
ant
. ., . Shipment
iste Neutra- r
;id I'ze
ToC
Dum
r
!lass 1
P
Figure 12 - Production and waste schematic for DDT
-------
Raw Materials (Concluded)
Material Received from gecqived bv
Storage
3. Oleum Compton or
Dominques,
California
4. Caustic Henderson, Nevada
Tank trucks Steel storage tanks on plant
site
Tank trucks Steel storage tanks on plant
site
Material
1. None
Material
jfeaction By-Produces
Mount produced
Form flb/lb AI)
Other Process Wastes and Losses
Mount produced
Form Clb/lb AI)
Disposition
1. Active in- Aqueous
gredient
2. Solvents
3. NaSO Aqueous
Unknown
0,87
10-15 cu yard/day
Disposition
Class 1 dump
Holding pond, re-
cycle Class 1
dump
Disposition "? Technif*! and Formulated Products
Shipments
Technical product
Formulated products
Warehouse ...
on site Container TVananoftation Formulation Container Transportation
50-lb bags
Boxcar
WP (757. AI) 100-200 lb Truck for export
lined
fiber
drums and
75-lb
boxes
via Los Angeles;
boxcar for other
destinations
Hoods are located at points having emissions potential and exhaust under
vacuum to six baghouses. Venturi scrubbers are used. Liquid formulations are
no longer being made*
38
-------
Montrose maintains its own quality control laboratory for routine analyses.
Setting point is the major quality control used. To date they have had no off-
specification material that could not be reworked.
General Wastewater Characteristics—
The wastes resulting from the DDT manufacturing process include spent acids
(hydrochloric and sulfuric), sodium monochlorobenzene sulfonate, chloral, NaOH
caustic wastewaters, monochlorobenzene, and sulphonic acid derivatives. The
waste streams may contain DDT in the 1 to 5 rag/liter range with DDE and other
related compounds present in amounts up to four times the DDT level. The pH of
the waste is low and the salt content is high.
The volume of spent acid reported for DDT manufacture ranges from 440 to
550 gal/ton of DDT. This liquid contains 55% acid and 5% other organic sub-
stances and water. The first washwater, about 800 gal/ton of DDT made, contains
from 2 to 6% spent acid. The second washwater, also about 800 gal/ton of DDT
made, contains a very small proportion of spent acid neutralized with sodium
carbonate.
Wastewaters also result from the absorption of the mixed gases from the
manufacture of chloral alcoholate. The gases are first water washed, producing
a 10% by weight solution of hydrochloric acid (2,700 to 2,900 gal/ton of DDT).
The gases are then washed with a caustic soda solution, producing a solution
(220 to 440 gal/ton of DDT) containing sodium hypochlorite equivalent to 2.0%
chlorine, sodium chlorate equivalent to 0.2 to 0.5% chlorine, some sodium chlo-
ride and excess sodium hydroxide.
Wastewater Characteristics - Montrose Chemical Corporation—
The process portion of the DDT plant has no liquid waste outfall. Waste-
water flow is contained within the plant by a closed-loop processing system,
and use of a sealed bottom holding-recycling pond, except for about 30,000 gal/
day of alkaline wastewater and about 10,000 gal/day of acid waste, which are
currently removed by truck and placed in a California-approved Class 1 dump.
There is some decomposition of DDT in the process reactor, and HCl and SO2
are present in the vent gas. The vent from the reactor is scrubbed with caustic
and water. Liquid from off-gas vent scrubbers and surface drainage from the DDT
plant area is collected in a holding pond and recycled to the process. This
pond serves as the surge capacity for the cooling water system and there is
essentially no evaporation of water from this pond.
The holding pond (approximately 75 ft x 50 ft x 15 ft deep) has been used
for about 20 years, but was lined with concrete about 5 years ago to overcome
the necessity of installing test wells to monitor possible leaching. Montrose
indicates that this recycle system has been satisfactory and that no signifi-
cant changes would be made if it had to be constructed today.
39
-------
At present, the segregated alkaline wastewater from the Montrose DDT plant
averages about 30,000 gal/day, but it is estimated that the discharge rate could
range up to about 45,000 gal/day if the plant were operated at the maximum DDT
capacity of about 35 million pounds per year.
Currently, there is one combined source of about 5,000 gal/day of waste-
water which is being discharged into the sewer of the Torrance, California,
plant for DDT production. The breakdown and analysis of this waste stream for
DDT and metabolites (DDD and DDE) are as follows:
DDT + DDD Lb of
Source Gal/dav + DDE (ppm) DDT/dav
Engine room 2,500 0-0.005 0-0.0001
Sanitary waste 2.500 0-0.005 0-0.0001
5,000 0-0.010 0-0.0002
Sources of the principal waste, alkaline wastewater, are neutralized caus-
tic liquor from the DDT-washing operation, tar pot drainings, spills and tank
drainings. In 1975, this effluent discharge rate was 30,000 gal/day and all of
this wastewater was disposed of in a Type 1 landfill. A typical analysis for
1975 of the alkaline wastewater* based on a flow rate of 30,000 gal/day and
pound per day data, is given below.
Concentration
Component Lb/dav (ppm)
Sodium sulfate 21,615 76,883
Sodium salt of 3,670 13,054
monochlorobenzenesulfonic acid
Caustic 50 117.8
DDT (+ DDE, DDD) 119 423.3
Miscellaneous (tars, etc.) 139 494.4
Water 255.550
281,143
The discharge rate and characteristics of this waste are fairly constant
and do not show seasonal fluctuations* The DDT plant is on stream at this level
of two shifts per week and 12 months/year, except for breakdown and routine
maintenance.
40
-------
In-Plant Control - Montrose Chemical Corporation-
All drains and process sewers at the Montrose plant have been isolated
from the city sewer system. Only sanitary waste and boiler blowdown water go
to the city sewers. The restroom lavatory basins, however, discharge to the
holding pond system. Water consumption has been reduced from about 20 million
gallons to about 2 million gallons per month. Water from the holding pond is
also used for cooling water without filtration. This practice has caused no
problem to date. The "recycle" water typically contains 10 to 15 ppm DDT.
Some 10 to 15 cu yards/day of solid waste, bags, empty containers, etc.,
are also taken by a commercial disposal service to a Class 1 dump, which is
approved for wastes of this type in California. Incineration is not approved.
Equipment washdown is not a problem as this is normally done only during
shutdowns. Washwater goes to the recycle pond. Spills and leakers have not
been a major problem. One spill occurred when a truck carrying technical mate-
rial had an accident and spilled DDT. The material was picked up along with
the top 3 in. of soil and disposed of.
According to the company, DDT losses to the sewer were < 1 Ib/day for at
least 2 years before modification of the waste treatment facilities and never
more than 10 to 15 Ib/day since the 1940's. The amounts of DDT entering and
leaving various Los Angeles city and county sewers from all sources are uncer-
tain, but DDT is apparently adsorbed strongly on sewage sediments* the county
sanitation district removed 0.5 million pounds of sediments said to contain
4,500 lb of DDT. This sediment apparently went also to a Class 1 dump.
Two additional pieces of information concerning water and air emissions
from the Montrose DDT plant were obtained from the County Sanitation Districts
of Los Angeles County and California Air Resources Board and are quoted below.
Water emissions have been described as follows:
"In 1970, during the course of a trunk sewer survey aimed at
locating sources of pesticide, a net input to the sewer system of
640 Ibs/dayofDDT was discovered in the vicinity of the Montrose
Chemical Corporation, a DDT manufacturer* Through additional test-
ing it was determined that approximately 600 Ibs/day of this input
was contained in the Chemical plant's discharge, and that the re-
mainder was contributed by DDT-laden sediments previously deposited
in the sewer.
"Shortly after this discovery, the Montrose Chemical Cor-
poration discontinued the discharge of its caustic liquor waste,
which contained the major portion of the DDT discharge, and within
14 months eliminated all but sanitary and boiler blow-down wastes.
During this period, the Sanitation Districts performed extensive
41
-------
sewer cleaning operations downstream of the Montrose discharge and
successfully removed more than 280 tons of sewer sediment.
"By 1972, the input of DDT to the Sanitation Districts system
had been reduced to approximately 8 Ibs/day, and during 1975 averaged
approximately 6 Ibs/day. With the current system flow, this amount
represents less than 2 ppb influent to the Districts' Joint Water
Pollution Control Plant. "IP/
Mr emissions have been characterized as follows:
"Montrose Chemical Company, the only manufacturer of DDT in
Los Angeles County, has been and is presently operating in com-
pliance with all applicable Rules and Regulations of the District.
The company has recently undertaken a program to reduce even small
losses of DDT and has recently upgraded their air pollution scrub-
ber system which controls emissions from the reactors for manufac-
turing DDT. The gaseous effluent from three former Venturi scrubbers
operating in parallel will pass through two caustic Venturi scrub-
bers connected in series. Although the company is controlling DDT
dust from the operations of DDT grinding, screening, air milling,
conveying and bagging, it is adding a sixth baghouse to control
dust from two hoppers and two bagging machines.
"DDT losses to the atmosphere from the series of Venturi scrub-
bers is computed as 0.0008 Ib/hr. DDT loss from each of the five
baghouses is estimated at a maximum of 0.5 Ib/hr. The total DDT
loss to the atmosphere is about 2.5 Ibs/hr from the plant.
"Diffusion calculations using the Bonsanquet-Pearson equation
show a maximum ground level concentration from a single baghouse
of 100,000 nanograms DDT per cubic meter. This maximum ground level
concentration occurs at a distance of 10 times the stack height
and may occur inside or outside the plant depending upon the direc-
tion of the wind. The maximum ground concentration from the air
pollution Venturi scrubber system is only 1,390 nanograms per cubic
meter.
"Obviously, these concentrations are well below the 1,000,000
nanograms per cubic meter (1 rag/cu. meter) for DDT adopted by ACGIH
in 1970 and the present OSHA standard shown in the Federal Register.
"We have investigated seven complaints against the company over
the past five years and have found that the complaints had nothing
to do with DDT dust but were the result of maintenance problems in
which oleum (803), ammonia, and monochlorobenzene escaped from vessels.
42
-------
"DDT dust particles which pass through the baghouse fabric or
through the Venturi scrubbers are expected to be in the micron or
submicron size range. These small particles remain suspended in the
air and can travel considerable distances from the plant. Because
of the complexity and mathematical treatment of meteorological data,
we cannot relate DDT fallout measurements (nanograms per square
meter) cited in your letter to the calculated maximum DDT concentra-
tions (nanograms per cubic meter) present in the atmosphere surround-
ing the plant."!!/
Atrazine Manufacture
Atrazine herbicide is currently manufactured by Ciba-Geigy Corporation
at MeIntosh, Alabama, and St. Gabriel, Louisiana. Estimated total production
of atrazine is 110 million pounds annually.
Atrazine (2-chloro-4-ethylamino-6-iso-propylamino-s-triazine) is made by
combining cyanuric chloride with ethylamine and isopropylamine in a continuous
process.
Production Chemistry
Cl
C2H5NH2 ^ IY^ (CH3)2CHNH2
3HCN + 3C1- > ^_ ^
2 Cl^^N-^Cl Solvent
Cyanuric
chloride
Cl
5HC1 or +
RNH3C* r u HN-^ ^N^—vmrufrv ^
25 NMCH(.CH_;2
Atrazine
The product is a solid, nearly insoluble in water, nonpersistent, and of
relatively low toxicity (oral LD$Q 1,750 mg/kg for rats).
43
-------
A production and waste schematic for atrazine is presented in Figure 13.
Other details of the process and the facilities at St. Gabriel, Louisiana,
are given below.^/ In comparison to the previous DDT discussion (which benefited
from two visits to Montrose Chemical Corporation by MRI staff for previous con-
tracts) much less specific information is known of the atrazine facilities at
St. Gabriel.
Production Equipment
Process continuity: Continuous Est. annual production: 110 MM Ib/year
Equipment dedication: Mostly Plant capacity: > 150 MM Ib/year
atrazine>
some other
triazines
Equipment age: 1970 Formulation on site: Yes
Raw Materials
Material Received from Received bv Storage
1. HCN Memphis, Tennessee Tank cars Tank
2. "Appropri- Taft, Louisiana Tank cars Tank
ate" amines
?* ^nu \ Adjacent plant Pipeline Not stored
*f» NciUH )
Reaction Bv Products
.Amount produced
Material Form (Ib/lb AIL Disposition
1. HC1 0.333 Scrubber, then deep
well or river
Other Process Wastes and Losses
Anount produced
Material Form (Ib/lb Al) Disposition
1. Active ingre-
dient
2. Solvents
3. Solid waste Landfill
4. Liquid River
44
-------
Solvent
C2H5NH2
ll
1
HCN
NaOH
Zyanuric
Ihloride -*-C3N3<
Jnit
HCI
Scrubber
and Filter
f ,
1
_. Amination
CI3-» Unit
*
Solvent
- Recovery
-»- Filter
Filtrate
I
-- — f
— ^~
(Alternate)
j
Atrazine
Formulation
,
Air
Filters
and Scrubbers
Liquid
* Wastes
^
Packaging
V«
1
Product
;nt
Deep Wei I
Disposal
Discharge
to River
Figure 13 - Production and Waste Schematic for Atrazine
-------
Disposition of Technical and Formulated Products
Warehouse
On- Else-
Shipments
Technical product
Formulated products
site where Container Transportation Formulation Container Transportation
None Public
ware-
house-
ing
Rail
% W.P. (80% 5-lb bags
Rail
AI)
Liquid
(4
gal.)
Pollution Control Regulation
(multi-
walled
(10 per
case)
1.5 gal.
plastic
1899 Refuse Disposal Act applies to this manufacture X Yes No
Pollution Control
About 1 lb of effluent is generated per pound of atrazine produced—mostly
NaCl. Liquid wastes from the cyanuric chloride production unit ordinarily go
to a 6*000 ft deep well disposal} after receiving a preliminary polishing (pH
adjustment and filtration). The larger amount of liquid wastes from the remainda ^
of the plant are discharged to the river. Sanitary wastes from the plant are ^
chlorinated before they are discharged. The BOD of the waste going to the river '
is near 500 Ib/day at the 110 million pound per year production rate.
Solid wastes are primarily bag wrappers, car lining material, etc. This
waste is disposed of by a commercial operator by landfill not located on the
plant site* The formulation and packaging areas are controlled by baghouses
and wet scrubbers and atmospheric monitors are used. Losses are said to be
substantially less than 1%.
Breakage and leakers have not been a major problem. Returns have been < !£.
Overall repackaging is < 2%.
Package disposal is a problem. They can be burned, but what happens to the
atrazine is not known.
Air emissions data for the St. Gabriel atrazine plant have been reported
by Ciba-Geigy to the Louisiana Air Control Commission as required by state
regulation. These data are available to the public but only upon personal
visit to the New Orleans office.!£/ Due to time and budgetary restrictions
it was not possible for the MRI team to obtain these data. (MRI became aware
of these data on June 16, 1976.)
46
-------
Aqueous and other liquid discharge information on the atrazine plant was
made available through the NPDES permit and Discharge Monitoring Report from
the EPA Region VI Office in Dallas.il/ The pertinent data for March 1976 are
as follows:
Atrazine, pound per day: Reported 469 minimum
828 average
1,559 maximum
Permit N/A minimum
Condition 1,300 average
1,950 maximum
The above reported data are for a daily, 24 hr composite sample. Other chemical
species reported in the effluent include toluene, carbon tetrachloride, cyanide,
and ammonia, and are given in Table D-7 of Appendix D.
In order to gain a perspective of the amount of atrazine disposed daily,
some 828 Ib/day on the average, it is instructive to recall the average daily
production rate is 300,000 lb based on an estimated annual rate of 110 mil-
lion pounds* Thus, 828 Ib/day disposed as liquid wastes represents 0.3% of
the daily production of atrazine. However, this represents a large physical
quantity of active ingredient which has an estimated intrinsic value of perhaps
$1,700 daily.
FACTORS RELEVANT TO THE POLLUTION POTENTIAL IN PESTICIDE MANUFACTURING
The foregoing sections of this report, particularly the overview of the
pesticides industry and the input-output approach to pesticide manufacturing
and formulating plants, permit a listing of the general factors relevant to
assessing the pollution potential of pesticides. Seven general factors and
the subfactors for each factor are given in Table 7.
These factors are taken into account in the following two sections. The
first section discusses the general methodology required to perform a detailed
pollution potential assessment of a pesticide active ingredient. The second
section discusses the decision criteria based on quantifiable factors required
to evaluate the need for control technology development.
GENERAL METHODOLOGY FOR ASSESSING THE POLLUTION POTENTIAL OF A PESTICIDE
PRODUCTION PROCESS
The method employed to assess the pollution potential of a pesticide pro-
duction process must answer the following questions.
47
-------
Table 7. GENERAL FACTORS RELEVANT TO THE POLLUTION POTENTIAL OF
PESTICIDE ACTIVE INGREDIENTS
Factor
Potential pollutants
Emissions
Pollutant identification/
character!za tion
Source pollutant severity
Environmental pollutant
severity
Subfactors
Process materials, reactants
Process materials, nonreactants
(catalysts, solvents, etc.)
Chemical intermediates
Pesticide active ingredients
Pesticide degradation products
Process by-products
Unit operations
Process equipment
Process techniques
Housekeeping practices
Management philosophy
Control technology
Disposal techniques
Toxicological properties
General toxicity to fish and wildlife
Acute toxicity: oral LD5o - rats
Subacute toxicity
Chronic and subchronic toxicity
Dermal toxicity
Inhalation toxicity
Carcinogenicity, mutagenicity, teratogenicity
Production or use volume
Concentration in air, water, or solids
Toxicological properties (same as above)
Carcinogenicity, mutagenicity, teratogenicity
General health effects
Synergistic effects
Concentration in air, water, or soil
Behavior in air, water, or soil
Persistence
Biodegradabi11ty
Microbial breakdown
Photodecomposition
Translocation characteristics
Volatilization
Leaching
Solubility
Adsorption on soil
Absorption in soil
48
-------
Table 7. (concluded)
Factor
Subfactors
Environmental pollutant
severity (continued)
Population exposed
Pollution emissions'
growth
Biochemical behavior
Mechanism of action
Metabolism in plants and animals
Persistence in plants and animals
Bioaccumulation
Biomagnification
(Also includes all subfactors of source
pollutant severity factor)
Human population exposed
Geographic location of plant
Population distribution
Pollutant medium
Ambient air
Drinking water, water discharge
Solid waste dumps
Wildlife exposure
Geographic location of plant
Population distribution
Pollutant medium
Ambient air
Drinking water, water discharge
Solid waste dumps
Future pesticide production
Pesticide market changes
Government regulations, present and
future, for pesticides
Pollution control technology
implementation
49
-------
What are the potential pollutants?
• What are the emissions?
• Do the emissions contain pollutants?
These questions can be answered by considering the factors in Table 7.
The first factor, potential pollutants, shows that six subfactors must
be considered when identifying the potential pollutants of any pesticide plane,
Any of these materials may be emitted into the air, discharged into water,
and/or become solid residues during the operation of a pesticide plant. The
first step in the assessment methodology is to identify these materials.
The second step in the assessment procedure is to identify and quantify
the plant's emissions. The emissions which arise from each unit operation and
the process equipment must be identified, sampled, analyzed, and quantified.
Other subfactors such as process techniques, housekeeping practice, and manage*
ment philosophy should be observed, and the effect these variables have upon
the type and amounts of emissions should be carefully considered and determined.
The control technology and disposal practices used by the plant must be observe**
and evaluated.
Once the emissions have been qualitatively and quantitatively evaluated,
the third step in the procedure is to determine which constituents of the emis-
sion streams are pollutants. The third factor, pollutant identification/charac-
terization in Table 7 shows that two important subfactors must be considered
when deciding whether a substance is a pollutant or nonpollutant. Each substanc*
must be evaluated using these two subfactors in the manner shown in Figure
14.1» The toxicological properties and genetic effects of each substance can
be obtained from literature sources.
DECISION CRITERIA USED FOR DETERMINING THE NEED FOR POLLUTION CONTROL
TECHNOLOGY DEVELOPMENT
After the detailed pollution assessment of the pesticide active ingredient
has been performed, a decision must be made as to whether or not development
of control technology is required to reduce the pollution emissions of the
plant to acceptable levels. This decision can be made by using a set of criteri^
for air emissions, water emissions, and solid residues.
ffrjteria foy Air Emissions
Decision criteria as developed by Monsanto Research Corporation (MRC) are
generally useful for any industrial source. It must be recognized that pesticide
production and formulation processes are in a class by themselves. Pesticides
50
-------
Does Substance have an Oral LD5Q
for Rats <50
i
No
Does Substance have an Inhalation
Toxicity <200 ppm as Gas or Mist ?
LC50 <2 mg/LAS Dust ?
No
Does Substance have Dermal Penetration
Toxicity LDso <200
No
Does Substance have Aquatic
96 Hr. TLm <1000 mg/l ?
No
Is Substance Carcinogenic, Mutagenic,
or Teratogenic ?
No
Nonpollutant
Yes
Yes
Yes
Yes
Yes
Pollutant
Figure 14. Decision process for determining the nature
of an emission constituent
51
-------
are designed to be poisonous to organisms, in effect they are biocides. Thus,
one must be especially concerned with the possibility of nontarget organisms
being adversely affected. The authors of this report offer a number of consider-
ations which should be used to modify the MRC-developed decision criteria in
order to address more fully the toxic character of pesticides.
The additional decision criteria to be considered are derived from the
last four factors in Table 7. When the factors are quantified or given limits
of acceptability wherever possible from literature data, they may properly be
termed decision criteria. Those factors are source pollutant severity, ambient
pollutant severity, population exposed, and pollutant emissions growth. The
first two factors are combined into one factor in this discussion so that three
factors (similar to those used by MRC) are considered.
Source and Anbient Pollutant Severity—
The severity of a pollutant depends upon several important criteria. The
discussion presented here considers only the criteria that are the most impor-
tant and those that have been examined in the past and have been qualitatively
and quantitatively determined and reported in published literature. Table 7
gives numerous criteria which we limit to the following.
• Pollutant concentration (measured).
• Pollutant carcinogenicity, mutagenicity, teratogenicity (proven or
suspected).
• Pollutant persistence (proven or implied).
• Pollutant bioaccumulation and biomagnification (proven or implied).
Pollutant degradation products (physically and chemically characterized)
Source and ambient pollutant severity is determined in two steps. The
first step involves comparing the measured concentration of the pollutant in
the air to acceptable levels established by government standards. No national
air standards for pesticides have been established for source emissions by EPA,
but Threshold Limit Values (TLVs) have been established in many cases. Simi-
larly, many of the uncommon input chemicals, intermediates, and by-products
have no air emission standards, but do have established or provisional TLVs.
Therefore, the measured concentrations of these pollutants will be compared
to the primary ambient air quality standard (if one exists) or to the TLV of
the pollutant.
The comparison is made using the same equations and criteria that MRC
uses in their model. That is, source severity, S , is defined as:
52
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X
-------
Example
Case 1
Original
S
value
S * 1.0
Pollutant
flagged
Yes
Case 2
Case 3
Case 4
S * 1.0
S < 1.0
S < 1.0
No
Yes
No
New
S
value
Unchanged from original value. Pol-
lutant was already a candidate
for pollution control technology
development.
Severity value unchanged.
Raise S to 1.0. Pollutant is now a
candidate for pollution control
technology development.
Severity value unchanged
Persistence--
If the pollutant has a persistence equal to or greater than 6 months (i.e..
£ 25% of the pollutant degrades in that period), the value of S is raised to
1.0 in the manner previously described. If the persistence is less than 6 months
the value of S remains unchanged, except in the case in which the degradation
products have a more severe impact on man and the environment than the original
pollutant. (See discussion below on degradation products.)
Bioaccumulation and Biomagnification—•
If the pollutant is known to biomagnify or bioaccumulate, the value of
S increases, it is raised to 1.0, and the pollutant becomes a candidate for
pollution control technology development.
Degradation Products-
Degradation products must be evaluated with respect to the above three
criteria and compared to the original pollutant. If the degradation products
are more toxic than the original pollutant, and/or are carcinogenic, mutagenic
or teratogenic while the original pollutant is not, then the complexity of the
problem increases. An example would be the formation of nitrosamines from atra-
zine in the Mississippi River.
The relative importance of these criteria are as follows:
Human Effects > Wildlife Effects
Carcinogenicity
Mutagenicity
Teratogenicity
Persistence > Bioaccumulation and Biomagnification
54
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Note that each of the above criteria is qualitative (yes or no) and each
may affect S by increasing its value but not decreasing its value. At present
none of these criteria can be quantitatively evaluated with confidence but are
subjective criteria. However, they are important in comparing the relative
need for pollution control technology development among various pollutants
which have the same S value.
Population Exposed--
The various subfactors of population exposed (human and wildlife) are given
in Table 7 and do not modify the original MRC model. The listing in Table 7 only
serves to underscore the importance of human population and wildlife exposure to
the pollution potential of pesticides and the need for assessment. Obviously, a
knowledge of affected population is important to deciding which source problems
will be approached first, since resources are limited.
Pollution Bnission Growth--
If a pesticide is a viable substitute for other pesticides that have been
(or may be) restricted by government regulations, then the production volume .
of that pesticide will most probably increase in the future. For example, toxa-
phene production has increased dramatically in the past few years since restric-
tions have been placed on chlordane, aldrin, heptachlor, and endrin. If the use
of a pesticide such as those just mentioned is restricted then the production
volume may drop substantially unless an export market exists, e.g., the World
Health Organization malaria program utilizing DDT. When considering the fu-
ture production volume of a pesticide, government regulations, substitutability
for other pesticides and other market factors should be considered.
Pesticide plants may have working plans to implement control technology
in the future, or anticipated government regulations for the pesticide industry
may necessitate control implementation in the future. For example, Montrose
Chemical Corporation of Torrance, California, the sole producer of DDT, is
conducting extensive research in control technology for their plant. It is
important to consider the future production volume and control technologies
of a pesticide plant when evaluating the need for control technology develop-
ment. The future, in this case, should be limited to the next 5 years. These
considerations do not affect the MRC model.
In summary, any pesticide active ingredient which has an S value of 1.0
or more is a candidate for pollution control technology implementation, and
if no suitable technology exists in practice elsewhere, the technology must
be developed. Pesticide active ingredients that are known or suspected carcino-
gens, mutagens or teratogens should be considered as prime candidates for con-
trol technology development, particularly if the pollutants are persistent and
biomagnify and bioaccumulate. These pollutants could exist in the environment
for years in the air, water, soil or living organisms and cause considerable
long-term damages. The same is true for nonpersistent pollutants which degrade
into compounds which are toxic carcinogens, mutagens, teratogens, or which
55
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are persistent in the environment. Unfortunately, no strict guidelines (other
than the S value) can be given in the decision process to determine whether
or not a given active ingredient is a candidate for control technology develop-
ment.
Pesticide Standard for Air—
At present, no standards have been set for pesticide content of ambient
air resulting from pesticide manufacture and formulation, or from agricultural
uses and other operations. In order to set standards for pesticides in air to
cover these operations, monitoring and data collection and interpretation are
badly needed.
Recommendations for maximum permissible levels of pesticides in workroom
air have been established by the American Conference of Governmental Industrial
Hygienists (ACGIH).ll/The permissible levels represent concentrations to which
a worker would be exposed for 8 hr, 5 days/week without harmful effect. In
reality, the permissible levels are threshold limit values. Table 8 presents
threshold limit values of various pesticides.^i1?/
Table 8 contains nearly 80 threshold limit values (TLV) for pesticides.
However, there are approximately 300 active ingredients listed in the SRI
Directory of Chemical Producers of commercial importance which means that recom-
mendations or standards have been set for only 25% of the more important pesti-
cides. Clearly, a much greater effort needs to be expended. The American Con-
ference of Governmental Industrial Hygienists is aware of this monumental task
and is actively working on the problem. As a first step the authors of this
report suggest those pesticides produced in large quantities, e.g., i 10 million
pounds annually, be investigated and a TLV established. Those pesticides pro-
duced in the largest quantities for which TLV's have not yet been established
include the following:
Estimated 1974
Production
Pesticide Active Ingredient (million Ib)
Atrazine 110
Propachlor 45
Alachlor 40
Trichlorophenols 25
Trifluralin 25
Dichloropropene 24
Chloramben 22
DBCP 20
Propanil 15
Simazine 15
Sodium TCA 15
Bromacil 12
Butachlor 10
Bux® 10
Propazine - 10
-------
Table 8. THRESHOLD LIMIT VALUES OF VARIOUS PESTIGIBES16i17/
Substance
TLV
(UK/in?!-/
Abate 10
Aldrin °-25b/
Antimony and compounds (as Sb) ^ x/
Arsenic and compounds (as As) (0.5)—'
Azinphos - methyl - skin 0.2
Baygon® (Propoxur) 0.5
Calcium arsenate, as As 1
Captan *
Captafol (Difolatan®) - skin 0.1-
Carbaryl (Sevin®) 5
Carbofuran 0.1
Chlordane 0.5
Chlorinated camphene - skin 0.5
Chloropicrin °'7b/
Chlorpyrifos (Dursban®) - skin 0.2-'
Clopidol (Coyden®) 10^'
Cra^ Herbicide 15
Crufornate (Ruelene®) 5QE'
2,4-D 10
DDT 1
DDVP (Dichlorvos) - skin 1
Demeton® (Systox) - skin 0.1
Diazinon - skin 0.1
Dibrom® 3 .
Dicrotofos (Bidrin®) - skin 0.252'
Dieldrin - skin °-25
Dinitro-o-cresol - skin °'2>,/
3,5-Dinitro-o-toluamide (Zoalene®) 5 b/
Dioxathion (Delna^ 0.2-
Diquat °'5
Disyston - skin 0.1
Disulfiram 2,
Diuron
Dyfonate °*1
Endosulfan (Thiodan®) - skin 0.1
Endrin - skin O-1
EPN - skin °*5
Ethion (Nialate®) - skin 0-^
Ferbam 10
57
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Table 8 (Continued)
Substance
Fensulfothion (Dasanit®)
Heptachlor - skin
Lead arsenate
Lindane (gamma isomer) - skin
Ma lathion - skin
Manganese and compounds, as Mn
Mercury (alkyl compounds) - skin, as Hg
Mercury (all forms except alkyl), as Hg
Methorny1 (Lannate®) - skin
Methoxychlor
Methyl bromide - skin
Methyl demeton - skin
Methyl parathion - skin
Monocrotophos (Azodrin®)
Nicotine - skin
Nitrapyrin (2-chloro-6(trichloromethyl)pyridine)
Paraquat - skin
Parathion - skin
Pentachlorophenol - skin
Phorate (Thimet®) - skin
Phosdrin (Mevinphos®) - skin
Phosphorus pentasulfide
Picloram (Tordon®)
Picric acid - skin
Pival® (2-Pivalyl-l,3-indandione)
Plictran® (Tricyclohexyltin hydroxide)
Pyrethrum
Ronnel (Fenchlorphos)
Rotenone (commercial)
Sevin® (see Carbaryl)
Sodium fluoroacetate (1080) - skin
Systox (see Demeton)
2,4,5-T (2,4,5-Trichlorophenol)
TEDP - skin
TEPP - skin
Thiram®
Tin (organic compounds) - skin
Toxaphene (see chlorinated camphene)
Warfarin
TLV
(mg/m3)^/
,1
,5
0.
0,
0.15
0.5
10
5
0.01
0.05
10
60
0.5
0.2
0.25^
0.5
IQb/
0.5
0.1
0.5
0.05
0.1
1
lot/
0.1
5
10
5
0.05
10
0.2
0.05
5
0.1
0.1
a/ Approximate milligrams of substance per cubic meter of air,
b/ 1975 revision or addition.
-------
The term threshold limit value (TLV) is an expression describing per-
missible toxic levels of different compounds, formerly known as maximum allow-
able concentrations (MAC). In contrast to the statistically derived function,
LD5o (lethal dosage for 50% of an infinitely large population of a particular
species), the TLV is based on limited experimental and other available data.
The TLV is obviously more appropriate for human industrial and occupational
exposure restrictions.
Threshold limit values for toxic chemicals are time weighted average con-
centrations or represent a safe upper limit (ceiling)JLZ' Temporary overexposure
may be permitted provided that compensation is allowed by an equivalent under-
exposure during the normal workday. Thus, the TLV refers to levels at which
minimum detectable biochemical disturbances occur from which the body functions
can reversibly recover. At the TLV, a small percentage of workers may experience
some discomfort, and a yet smaller fraction may be affected more seriously (i.e.,
may require a physician's aid).
At present, the practical unit for assessing potential hazards arising
from pesticide manufacturing and formulating operations and determining ex-
posure to the immediate environment surrounding a pesticide plant is the
threshold limit value. Table 8 indicates a wide range of permissible levels
depending on the specific nature of the pesticide. The absolute range as
milligrams of pesticide active ingredient per cubic meter of ambient air
covers at least two orders of magnitude from 0.1 rag/m^ for parathion to 15
mg/nH for malathion. Any pollution assessment of the pesticide industry or
the examination of air emissions from a particular manufacturing or formulat-
ing plant must be based on hard analytical data and referenced to threshold
limit values if possible.
Sampling of pesticides emissions in air is a difficult and tedious problem.
Generally speaking, traps, screens or impingers must be employed to capture
and/or concentrate the pesticide species in order to obtain a statistically
reliable sample for subsequent determination. Special devices to perform this
important step in source assessment have been devised as early as 1967 at
MRI.lo|19/ The MRI impingers have been successfully used by the University of
Miami School of Medicine since 1973 in an ongoing pesticide air monitoring
program in south Florida*20-227 Details of this study may be obtained by con-
sulting the original literature and are briefly summarized in Appendix H under
the Florida entry.
The current approach to source assessment of assessing the pollution po-
tential of a toxic product or process does not rely on ambient air sampling.
Stack concentrations are determined by sampling with an evacuated heated probe
and auxiliary devices such as screens and traps. Plume dispersion model calcu-
lations are then employed to determine concentrations of pollutant at varying
distances from the source.
59
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Criteria for Water Emissions
Water is generated or used for a number of purposes in pesticide manufac-
turing and formulating plants. Water generated in the production process is
usually contaminated by various concentrations of pollutants. Water usage,
consisting of cooling water, boiler water, sanitary wastes, building washdown,
air pollution control devices (such as scrubbers), drum and equipment washing,
and other uses often generate pollutant contaminated wastewater that must be
disposed of.
A pesticide plant can handle contaminated wastewater in a variety of ways.
First, the wastewater can be discharged into nearby rivers and streams. Second,
the wastewater can be discharged into municipal sewer systems. Third, the waste-
water can be handled without discharge by containment, landfilling or contract
disposal. The manner in which a pesticide plant handles its wastewater is of
the utmost importance in determining the need for control technology development.
Each method for wastewater disposal is examined separately below and the
decision criteria for assessing the pollution problem are given in each case.
Discharge into Waterways-
Plants which discharge wastewater into streams and rivers are regulated
by law. Before a plant can discharge wastewater into waterways, the plant oper-
ators must submit an application for a permit to discharge into navigable waters
They are then given an NFOES permit which specifies the maximum concentrations
and maximum daily amounts of pollutants which the plant can legally discharge.
Plants operating under a permit must monitor the operation and efficiency of
all control and treatment facilities, sample the wastewater discharge for pol-
lutants, and report their findings periodically. Each plant must implement
controls to meet the specifications of the permit or they cannot operate.
In general the need for control technology development for wastewater
discharged into waterways is not urgent since control technology is already
in operation to prevent pollution of the waterways. However, specifications
for discharge into waterways may well dramatically change in the future. Re-
quirements for pretreatment before discharge are a very real possibility.
Discharge into Municipal Sewers—
Plants which discharge wastewater into municipal sewers do not need a
permit and are not regulated by law. Most of these plants do not monitor or
analyze the wastewater effluent, so that many of them may be discharging waste-
water contaminated with high concentrations of pollutants* Thus, the need for
control technology development at these plants may exist.
60
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It should be noted that when pesticide residues or other toxic substances
inactivate the biota in an activated sludge treatment facility, the operation
ceases to be effective and raw, untreated sewage may accumulate posing an addi
tional hazard. Such an event apparently happened at Hopewell, Virginia, during
the Kepone tragedy.
In order to determine if the need for control technology development
exists, the pollutant concentrations (measured in the detailed source assess-
ment) in the wastewater must be compared to the Proposed Criteria for Water
Quality or the Proposed Toxic Pollutant Effluent Standards now in existence.
The criterion given here is called the sewer wastewater severity, S , and
is defined as:
G
_ measured
sw ~ C
std
Where ^neasured is the rcax*10"111 concentration of each pollutant measured in
a 24-hr period, and Cgtd is the least allowable concentration permitted by
one of the two above standards.
When Ssw is greater than 1.0 for one or more of the pollutants in the
wastewater, the process is definitely a candidate for control technology de-
velopment. If no pollutants in the stream discharged to the sewer have an
Ssw greater than 1.0, then the need for pollution control technology develop-
ment does not exist.
Zero Discharge—
Wastewater which is not discharged into waterways or sewers is usually
handled in one of three ways: (a) placed in evaporation ponds; (b) placed
in landfills; or (c) disposed of by contract disposal firms. TLe contents of
wastewater handled by these methods are usually unknown, and in many cases
the wastewater contains one or more pollutants which may cause environmental
damage.
Pollutants discharged into a lined evaporation pond may evaporate into
the air causing an air emissions problem, or are eventually removed from the
pond as sludge causing a solid residue problem. If the pond is not lined, the
pollutants may leach into the soil and become transported away from the pond
into the surrounding environment. Any process which uses an evaporative pond
operation must be subjected to examination for pollution problems.
The concentration of pollutants in the ambient air above and around the
pond should be sampled and analyzed. The measured concentrations of pollutants
in the air should then be subjected to the criteria for air emissions given
previously to determine if the need for control technology development exists.
61
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Sludge from the pond should be properly disposed of to prevent contamination
of the air, groundwaters, and nearby waterways. Where possible, the air above
and around sludge dumps, the water in nearby waterways, and groundwater should
be sampled and analyzed. The pollutant should then be subjected to the criterio
for water emissions for discharge into municipal sewers, and criterion tor air
emissions, given previously, to determine if the need for control technology
development exists. Similarly, the air, the nearby waterways, and the ground-
water around unlined evaporation ponds should be sampled and analyzed where
possible, and the pollutants from these sources should be subjected to the
criterion given previously for wastewater discharge into municipal sewers
(Ssw) and for air emissions.
Pollutants discharged into landfills should be subjected to the same anal*.
yses and criteria as pollutants discharged into unlined evaporation ponds.
Soil samples should be taken in landfills to determine the concentration of
pollutants in the soil. No strict guidelines have been developed for pollutant
concentrations in soil; comparison to pollutant concentrations normally found
in agricultural areas treated with the same pesticide might be used as a rough
guideline for determining whether or not the landfill soil concentration is
too high.
Pollutants that are disposed of by contract disposal firms fall outside
the scope of this study, but the methods these firms use to ultimately dis-
pose of the wastewater should be examined and analyzed for possible environ-
mental insult.
Criteria^for Solid Residues
Solid residues are generated at pesticide manufacturing and formulating
plants in a variety of ways. Some of the more common sources are:
• By-products of the production or formulating process;
• Contaminated drums, packaging materials, and other containers;
• Sludge from evaporation ponds;
Ashes and other residues from incinerators; and
* Off-specification batches of solid product.
These solid residues are usually highly contaminated with pesticide active
ingredients, pesticide degradation products, and other process pollutants.
Escape of these residues into the environment could cause significant damage.
62
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Solid residues are usually handled in one of four ways: (a) landfillingj
(b) incineration; (c) chemical treatment; or (d) contract disposal. The pollu-
tion potential of each of these methods is examined separately below, and the
decision criteria for assessing the pollution problem are given in each case.
Landfilling--
Sol id residues placed in a landfill are subject to transport away from
the site through such mechanisms as vaporization, runoff, and leaching. When
considering the pollution potential of toxic solid residues disposed of in
landfills, the following properties of the pollutants are important.
1* Persistence
2. Ultimate fate in terms of biological and physical transformation
products
a. Toxicity
b. Garcinogenicity, mutagenicity, teratogenicity
3. Transport characteristics
a. Volatility
b. Leachability
c. Solubility
d. Adsorption on and absorption in soil
Solid residues which are persistent or degrade into persistent hazardous
substances can remain a potential threat to the environment for many years.
If the landfill does not properly contain these substances, they may be slowly
released into the environment through leaching and volatilization or they may
be catastrophically released in large amounts with the occurrence of a flood,
earthquake or other natural event.
The air, nearby waterways, groundwater1, local soil, and the landfill deposits
themselves should be subjected to analyses to determine the nature and concen-
trations of pollutants in and around solid waste landfills. The properties of the
pollutants described above should be noted for each pollutant detected so that
the magnitude of the pollution potential can be evaluated. Those pollutants which
are persistent or degrade into persistent hazardous substances and are readily
subject to transport away from the landfill must be considered threats to the
environment both in the short term and the long term.
No strict guidelines have been developed for concentrations of pollutants
that represent an imminent threat to man and the environment through the de-
positing of solid residues in landfills. However, if the criteria above are
taken into consideration and the concentrations of pollutants are measured,
63
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a reasonable assessment can be made as to the potential for present and future
environmental insult. When this potential seems unreasonably high or threatenin
the need for control technology development may be foreseen.
Incineration--
The effluent gases from incinerators which dispose of solid wastes from
pesticide plants should be analyzed for the nature and concentrations of the
effluents' constituents. The measured concentrations of any pollutant detected
should be subjected to the criteria for air emissions given previously. The
incinerator ash should also be sampled for pollutants, and the method of ash
disposal should be evaluated.
If any pollutants are emitted from the incinerator that have a source
severity, S , greater than 1.0, then the incinerator operation is a definite
candidate for pollution control technology development. If S is less than
1.0 for all air pollutants emitted, then those pollutants should be subjected
to further examination as previously defined in the criteria for air emissions
section.
Chemical Treatment~
Chemical treatment facilities for the detoxification of toxic solid resi-
dues should be analyzed and evaluated for their effectiveness in rendering the
toxic solids nonhazardous. If the treatment process is ineffective or only
partially effective in transforming the pollutants into nonpollutants, then
the need for control technology development exists.
Contract Disposal--
Solid residues disposed of by contract disposal firms fall outside the
scope of this study, but the methods these firms use to ultimately dispose
of the solid wastes should be examined and analyzed for possible environmental
insult. Determining the disposal firms1 awareness as to the nature and compo-
sition of the solid wastes is an important aspect of this analysis since those
firms that are not aware of the type of solid wastes they handle for pesticide
plants may be negligent in properly handling those wastes.
64
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REFERENCES TO SECTION 3
1. Lawless, E. W., R. von Rumker, and T. L. Ferguson* The Pollution Potential
in Pesticide Manufacturing. NTIS No. PB-213782/3, U.S. Environmental
Protection Agency, 1972.
2. Schafer, C. J., and N. Lailas. Environ. Sci. Technol., 8:903, 1974.
3. Pollutant Removal Handbook. M. Sittig, Noyes Data Corporation, Park Ridge,
New Jersey, 1973.
4. Air Pollution Engineering Manual. 2nd Ed., J. A. Danielson, Ed., Publica-
tion AP-40, U.S. Environmental Protection Agency, Office of Air and Water
Programs, Research Triangle Park, North Carolina, May 1973.
5. Industrial Pollution. N. Irving Sax, Ed., Chapter 14, Technological Sources
of Air Pollution. C. E. Billings, Van Nostrand Reinhold Company, New York,
1974.
6. Chemical and Engineering News. February 2, 1976.
7. Kansas City Star. March 6, 1976.
8. Letter to R. Wilkinson from G. Speller, Texas Air Control Board, Bellaire,
Texas, April 8, 1976.
9. Wastewater Treatment Technology Documentation for DDT Manufacture and
Formulation. Contract No. 68-01-3524. MRI Project No. 4127-C. U.S. Environ-
mental Protection Agency, Washington, D.C., February 6, 1976.
10. Letter to R. Wilkinson from F. Dryden, Head, Technical Services Department,
County Sanitation Districts of Los Angeles County, June 7, 1976.
11. Letter to W. Simons, Executive Officer, Air Resources Board, Sacremento,
California, from R. Lunche, Air Pollution Control Officer, May 13, 1975.
12. V. Parker, Chief, Air Quality Section, Louisiana Air Control Commission,
State Division of Health, New Orleans, Louisiana. Telephone contact of
June 22, 1976.
13. Letter and EPA Discharge Monitoring Report from F. Woods, Chief Admini-
strative Section, U.S. Environmental Protection Agency, Region VI, Dallas,
Texas, June 16, 1976.
65
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14. Kohan, A. M. A Summary of Hazardous Substance Classification Systems.
EPA 530/SW-171, U.S. Environmental Protection Agency, December 1975.
15. Industrial Pollution. N. I. Sax, Ed., Chapter 1, Toxicology of Environ-
mental Pollutants. W. B. Durham, Van Nostrand Reinhold Company, New York,
1974.
16. Threshold Limit Values for Chemical Substances in Workroom Air Adopted by
ACGIH for 1975. Anerican Conference of Governmental Industrial Hygienists
Cincinnati, Ohio.
17. Registry of Toxic Effects of Chemical Substances. H. E. Christensen, Ed.,
T. T. Luginbyhl, Ed., U.S. Department of Health, Education and Welfare,
Public Health Service, National Institute for Occupational Safety and
Health, Rockville, Maryland, June 1975.
18. Stanley, C. W. Study to Determine the Atmospheric Contamination by Pesti-
cides. MRI Report for the Food and Drug Administration, Pesticides Program
National Communicable Disease Center, Atlanta, Georgia, Public Health
Service Contract No. PH-21-2006, October 1968.
19. Stanley, C. W., J. E. Barney, M. R. Helton, and A. R. Yobs. Environ. Sci.
Technol., 5:431, 1971.
20. Davies, J. E. Pesticides Epidemiological Field Studies. National Technical
Information Service, Contract No. PB-237347, June 1974.
21. Davies, J. E. Occupational and Environmental Pesticide Exposure Study in
South Florida. U.S. Environmental Protection Agency, EPA-650/1-75-002,
March 1975.
22. Sherroa, J., and T. M. Shafik. Arch. Environ. Contain. Toxicol.,3:55, 1975.
66
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SECTION 4
SELECTION OF INDIVIDUAL PESTICIDES FOR FUTURE DETAILED
SOURCE ASSESSMENT
This section of the report presents the methodologies and information
bases which were used to select six candidate pesticides active ingredients
for detailed source assessment.* The methodologies used began by limiting
the pesticides considered to 82 major pesticides whose 1974 production vol-
umes were estimated and for which the needed quantitative data were available.
Next, a priority rating system was developed to rank numerically the 82
pesticides in the order of their importance as candidates for assessment. The
priority rating system was composed of six separate criteria which affect the
pollution potential of a pesticide.
The priority ratings for the 82 major pesticides were then used to se-
lect candidate pesticides utilizing three alternate selection methods.
Selection Method No. 1 consisted of ranking the 82 pesticides in a numeri-
cal priority order using the priority rating system, and selecting the top
six pesticides on the list as the best candidates for detailed source assess-
ment. The six pesticides selected by this method in order of priority rating
were DDT, chlordane, heptachlor, MSMA, endrin, and PCF (and sodium salts).
Five of the six pesticides are organochlorine compounds; these six pesticides
therefore were not representative of pesticides in general.
Selection Method No. 2 consisted of ranking the pesticides in a numerical
priority order using the priority rating system, but with the pesticides segre-
gated into their 10 chemical classes or groups instead of considering them all
together. This type of segregation was considered in order to insure better re-
presentation of all chemical classes of pesticides. Candidate pesticides were
selected by this method representing all 10 chemical groups. The 10 candidate
pesticides selected in order of priority rating were DDT, chlordane, MSMA, dino-
seb, parathion or methyl parathion, carbaryl, captan, atrazine or simazine,
monuron, and alachlor.
An alternative methodology and associated information base for selecting
the "best" plant sites for assessment is given in Appendix K.
67
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Selection Method No. 3 consisted of selecting pesticides based not only
on high priority rankings by chemical classes, but also on the characteristics
of the plant sites involved. Pesticides, which were manufactured by plant(s)
manufacturing other pesticides with high priority ratings, and pesticides
which were manufactured by fewer plants than alternative pesticides with
equal or similar priority ratings were selected. The pesticides were segre-
gated by chemical groups in this method, and the list of 27 candidate pesti-
cides was developed.
Table 9 contains a summary of candidate pesticide active ingredients
as selected by the three alternate methods and is given for purposes of com-
parison on an individual pesticide basis by methodology, chemical classifi-
cation, and priority rating. Two pesticides, DDT and MSMA, are common to all
three methodologies and five highly rated pesticides, parathion, carbaryl,
chlordane, heptachlor, and endrin, are common to two methodologies all of
which reinforces their importance in any final selection of pesticides. Two
pesticides, PGP (and salts) and dinoseb appear only once in the tri-selection
process but are defensible on the basis of total priority rating values. Other
pesticides appearing one or two times are relatively unimportant due to their
low priority ratings.
Utilizing the composite results from all three methodologies, the follow-
ing six pesticides are suggested as candidates for detailed source assess-
ment: DDT, chlordane, MSMA, POP and salts, parathion, and carbaryl.
The three selection methodologies and their application in selecting
these six pesticides are discussed in detail in the following paragraphs.
This discussion is divided into four sections.
• The Limited List of Pesticides and Pesticide Groups
• Estimated 1974 Production Volumes of Synthetic Organic Pesticides;
• Pesticide Priority Rating System,* and
Selection of the Six Candidate Pesticides.
THE LIMITED LIST OF PESTICIDES AND PESTICIDE GROUPS
The selection of individual pesticides as candidates for detailed source
assessment involved limiting the number of pesticides to be considered at
the outset, since about 1,200 active pesticidal ingredients are currently
being manufactured, and the objective was to select only six pesticides from
the entire pesticides industry. The initial compilation included only syn-
thetic organic pesticides of an estimated 1974 production volume which equaled
68
-------
Table 9. SUMMARY OF CANDIDATE PESTICIDES AS SELECTED BY
THREE ALTERNATE METHODS
Pesticide
chemical
classi'
H
Method No. l
/DDT (21)
/PCP and sales (15)
•MSMA (16)
/Chlordane (18)
Hepeachlor (17)
Endrin (IS)
Method No.
/DDT (21)
i/Parathion (12), or
Methyl parathion (12)
(Tie)
/Carbaryl (11)
Atrazine (8), or
Simazine (8)
(Tie)
Alachlor (6)
V MSMA (16)
Capcan (9)
/Chlordane (18)
Monuron (8)
Dinoseb (12)
10
Method No.
/DDT (21)
,/Par at hi on (12)
Methyl paration (12)
Disulfoton (10)
Fensulfothion (10)
/Carbaryl (11)
Aldicarb (9)
Atrazine (3)
Simazine (8)
Propazine (7)
Alachlor (6)
Propaehlor (5)
Butachlor (4)
/MSMA (16)
DSMA (13)
Oacodylic acid (10)
Captan (9)
Folpet (5)
CDAA (4)
Heptacfalor (17)
Endrin (15)
Monuron (8)
Diuron (7)
Bromacil (6)
Terbacil (3)
Trlfluralin (10)
Bentfin (4)
27
Total candidate 6
pesticides
a,/ A » Chlorinated hydrocarbons; B « organophosphorus compounds; C » carbamates
D * triazines; B « anilides; F « organoarsenicals and organometallies;
G " Other nitrogenous compounds; H - Diene-bas«d compounds; I » ureas and
uracils; J " nitrated hydrocarbons,
b_/ Method No. 1 ranks pesticides by priority rating. Rating values are given
in parentheses.
£/ Method No. 2 ranks pesticides by priority rating within the 10 chemical classes.
£/ Method No. 3 ranks pesticides by priority rating, by chemical class, and by
manufacturing plant site considerations.
Notet Checkmarks (/) Indicate the six final pesticides selected for detailed
source assessment.
69
-------
or exceeded 2 million pounds (hereafter called the major pesticides). This
limitation was made for four primary reasons: (a) a list of some 1,200 pesti-
cides included many pesticides for which no quantitative data are available*
(b) many pesticidal chemicals, e.g., inorganics and natural organics, had
many other nonpesticidal uses, and the pesticidal usage was small in rela-
tionship to the nonpesticidal usage of these chemicals, so they we re ex-
cluded from consideration; (c) most of the pesticides for which quantitative
and qualitative data exist were those pesticides produced in large quantities
and as a matter of practicality the production cutoff point was set at 2
million pounds in 1974; and (d) the major pesticides represent the vast ma-
jority of pesticides produced by the pesticides industry, and examination
of those pesticides to the exclusion of the smaller volume pesticides should
not materially affect a valid selection of six candidates for detailed source
assessment.
Next, the major pesticides were segregated into 10 chemical groups (plus
a miscellaneous group) composed of pesticides that are similar in chemical
composition, and that are manufactured by similar production techniques. This
was done to select six pesticides that were dissimilar in chemical composi-
tion and were manufactured with different production techniques in the event
that the priority rating system developed for this study selected six similar
pesticides that would represent a narrow segment of the entire pesticides
industry. The chemical groups used in this study were:
A. Chlorinated hydrocarbons, e.g., DDT, PGP;
B. Organophosphorus compounds, e.g., parathionj
C. Carbamates, e.g., carbaryl;
D. Triazines, e.g., atrazine;
E. Anilides, e.g., alachlor;
F. Organoarsenicals and organometallics, e.g., MSMAj
G. Other nitrogenous compounds, e.g., captan;
H. Diene-based, e.g., chlordane;
I. Ureas and uracils, e.g., monuron;
J. Nitrated hydrocarbons, e.g., dinoseb; and
K. All others, e.g., methyl bromide.
70
-------
Pesticides which were placed within a group are chemically similar to other
members of that group with the exception of the all others group. Pesticides
within a group are manufactured by production techniques similar to other
members of that group with the exception of the chlorinated hydrocarbon,
other nitrogenous compounds, and all others groups. Thus, each member of a
chemical group is somewhat representative of the other members, at least
chemically and in production technique, with the exceptions just noted.
The limited list of synthetic organic pesticides, by chemical group,
is given in the next section, which discusses the 1974 production volume of
those synthetic organic pesticides*
ESTIMATED 1974 PRODUCTION VOLUMES OF SYNTHETIC ORGANIC PESTICIDES
The 1974 production volumes of the major synthetic organic pesticides
were estimated for this study both to develop a limited list of pesticides
and to provide part of the necessary data for ranking the pesticides in a
priority rating system (discussed in the next section). The estimates were
both difficult and tedious to make, since data on the production volumes of
pesticides were almost completely unavailable on an individual compound basis
and those which were available left much to be desired.
The basic source of pesticide data for years has been the U.S. Tariff
Commission's (now the U.S. International Trade Commission) "Synthetic Organic
Chemicals, United States Production and Sales," which contains a two-page
tabular summary on "Pesticides and Related Products." This report, issued
annually but 2 years after the subject year, is preceded by a preliminary
issue of the "Pesticides and Related Products" section of about 10 pages
which lists the manufacturing companies who reported production of each syn-
thetic organic pesticidal compound, in addition to the tabular summary. The
tabular data are categorized under cyclic and acyclic with subdividions of
(a) fungicides, (b) herbicides and plant hormones, (c) insecticides, rodenti-
cides, and fumigants and soil conditions, plus general totals for benzenoid
and nonbenzenoid chemicals*
Table 10 shows the U.S. production of synthetic organic pesticides, by
category, in 1974 as reported by the U.S. International Trade Commission!/
and is the basic data from which the production estimates were developed in
this study. This table, however, is obviously insufficient for estimating
the production volumes of individual pesticides, so the next step was to esti-
mage the 1974 U.S. production of synthetic organic pesticides by chemical
group as shown in Table 11. The estimates shown in this table are based upon
the data in Table 10, MRI pesticide production estimates, and current knowl-
edge regarding various segments of the pesticides industry based in part on
confidential sources* The estimates shown in Table 11 are believed to be ac-
curate to within + 10%.
71
-------
Table 10. U.S. PRODUCTION OF SYNTHETIC ORGANIC PESTICIDES,
BY USAGE CATEGORY, IN 1974
1974 Production
Pesticide usage categories (millions of pounds)
Fungicides
PGP and sodium salts 52.4
Naphthenic acid, copper salt 2.0
Other cyclic fungicides 70.1
Dithiocarbamic acid salts 35.4
Other acyclic fungicides 2.8
Total fungicides 162.7
Herbicides and plant hormones
Maleic hydrazide 5.8
2,4-D acid, dimethylamine salt 14.5
Other cyclic compounds 467.4
All acyclic compounds 116.5
Total herbicides and plant hormones 604.2
Insecticides, rodenticides, soil conditioners
and fumigants
Aldrin-toxaphene group 141.7
Methyl parathion 51.4
Other cyclic organophosphorus insecticides 56.4
Methoxychlor 3.2
Other cyclic insecticides and rodenticides 160.5
Methyl bromide 30.5
Acyclic organophosphorus insecticides 78.8
Chloropicrin 4.8
Other acyclic insecticides, rodenticides, soil 123.0
conditioners, and fumigants
Total 650.3
Total synthetic organic pesticide 1,417.2
production, 1974 •
Source: U.S. International Trade Commission (1975).
72
-------
Table 11. U.S. PRODUCTION OF SYNTHETIC ORGANIC PESTICIDES,
BY CHEMICAL GROUPS, IN 1974
Estimated percentage
Estimated 1974 production of total production
Chemical group (millions of pounds) (rounded)
Chlorinated hydrocarbons 460 33
Organophosphorus compounds 200 14
Carbamates 150 10
Triazines 150 10
Anilides 110 8
Other nitrogenous compounds 70 5
Organoarsenicals and 55 4
organometallics
Diene-based compounds 40 3
Ureas and uracils 40 3
Nitrated hydrocarbons 40 3
All others 102 7
Total 1,417 100
Source: MRI estimates (February 1976).
73
-------
Next, the 1974 production volumes of individual pesticides within each
chemical group were estimated and are shown in Table 12. These estimates
were obtained from limited information on a few pesticides from published
sources (shown at the end of the table), from an update of 1972 production
estimates made previously by MRI,_/ and from information obtained from other
studies performed at MRI. The authors believe these estimates hav3 the fol-
lowing accuracies depending on the volume range.
Volume Range Accuracy
> 20 million pounds + 10%
10-20 million pounds + 10-20%
< 10 million pounds + 20-30%
The pesticides listed in Table 12 formed the limited list which was sub-
jected to evaluation in this study, and all subsequent selections of candi-
date pesticides for detailed source assessment consider only those pesticides
shown in Table 12 (for reasons previously given)* The production estimates
shown in the table were used in this study to assign the numerical value to
the 1974 production volume criteria in the pesticide priority rating system
described in the next section.
PESTICIDE PRIORITY RATING SYSTEM
The pesticide priority rating system developed for this study involved
making assumptions about the relative pollution potential of one pesticide
in comparison to other pesticides as certain criteria are applied to each
pesticide. The only pesticide criteria considered in the rating system de-
veloped here were those for which quantitative (or qualitative) data were
currently available. Those criteria were: (a) estimated 1974 production
volume, (b) acute mammalian toxicity (oral LD^Q-rats), (c) suspected carcino-
genicity, mutagenicity, and/or teratogenicity, (d) toxicity to fish, birds,
and invertebrates, (e) persistence, and (f) biomagnification, bioaccuaulation,
and environmental mobility.
Each criterion was assumed to be equally important in affecting the pol-
lution potential of a pesticide since there was no quantitative method avail-
able for weighing the importance of each of these criteria against one another.
The numerical values assigned to each criterion were assumed to be additive
to arrive at a total rating for each pesticide, and each criterion was eval-
uated on a numerical scale of zero to four. Each criterion is discussed below,
regarding the numerical rating scale for each criterion, the assumptions made
to develop each rating scale, and the information sources used to determine
the numerical value of each criterion for each of the pesticides given a
priority rating.
74
-------
Table 12. ESTIMATED U.S. PRODUCTION AND TOXICITY RATINGS OF MAJOR
INDIVIDUAL SYNTHETIC ORGANIC PESTICIDES, BY CHEMICAL
GROUP, IN 1974
Group
desig-
fl^tion Chemical group Pesticide
A Chlorinated Toxaphene
hydrocarbons DDT
2,4-D acid, esters, salts
POP and sodium salts
Trichl oropheno 1 s
Dichloropropene
Chloramben
DBCP
Sodium TCA
Dalapon
Si 1 vex
Dicamba
Dicofol
Methoxychlor
DCPA
Endothall
Undane and BHC
2,3,6-TBA
All others
B Organophosphorus Methyl parathion
compounds Malathion
Parathion
Diazinon
Disulfoton
Phorate
Monocrotophos
Fensulfothion
Merphos
DBF®
Guthion® .
Dyfonate
Ethion
Ronnel
Naled
Dimethoate
DDVP
Garb of enthion
All others
75
Estimated 1974
production
(million Ib)
110 .
60s'
53*
52*'
25
24
22
20
15
5
5
5
4
3
3
3
2
2
45
460
51£/
30
17
12
10
10
7
6
5
5
5
3
3
3
3
3
2
2
-22
200
Acute
mammalian
toxicity
ratine
2
2
2
3
1
2
1
2
1
1
1
1
1
1
1
2
2
1
•M
4
1
4
2
3
4
3
4
2
2
3
4
3
1
2
2
2
3
-
-------
Table 12. (Continued)
Group
desig-
nation
C
D
E
F
G
Chemical group Pesticide
Carbamates Carbaryl
Maneb
Bux®
Carbofuran
Met homy 1
Butylate
Zineb
EPTC
Nab am
Vernolate
Aldicarb
Benomyl
Polyram
All others
Triazines Atrazine
Simazine
Propazine
All others
Anilides Propachlor
Alachlor
Prop anil
Butachlor
Organoarsenicals M5MA
and organo- DSMA
metallics Cacodylic acid
Copper naphthenates
All others
Other nitrogenous Cap tan
compounds CDAA
Maleic hydr aside
Nitralin
Picloram
Captafol
Folpet
All others
Estimated 1974
production
(million Ib)
58
12
10
10
10
3
7
6
5
5
5
4
3
—I
150
110
15
10
JL5
150
45
40
15
10
110
35
10
3
2£/
-5
55
20
"7 /
fir*
3
3
3
3
25
Acute
mammalian
toxicity
rating ^
2
1
2
3
3
1
1
1
2
1
4
0
0
-
1
1
0
-
1
1
1
1
3
1
1
1
-
2
1
1
1
1
1
0
•
76
70
-------
Table 12. (Concluded)
Group
desig-
nation Chemical group Pesticide
H Diene-based Chlordane
compounds Aldrin
Endrin
Heptachlor
Endosulfan
All others
I Ureas and uracils Bromacil
Diuron
Fluometuron
LLnuron
Terbacil
Menu r on
All others
j Nitrated Trifluralin
hydrocarbons Chloropicrin
Dinoseb
Benefin
All others
K All others Methyl bromide
Miscellaneous
Estimated 1974
production
(million Ib)
I3d/
10s
3_,/
d/
3r'
3
6
40
12
10
5
3
3
3
4
40
25 *
Sr
3
3
4
40
31£/
JUL
102
Acute
mammalian
toxicity
ratine
2
3
4
3
3
-
1
2
2
1
0
1
-
2
2
3
1
-
-
-
Total all synthetic organic pesticides
1,417s7
Source: MRI estimates (February 1976).
£/ Based upon DDT exports of 56.4 million pounds (100% basis) in 1974 as reported
in The Pesticide Review. 1974 (1975) (Ref. 3).
b/ Based upon report in Chemical Marketing Reporter* January 5, 1976. (Ref. 4)
£/ Based upon data published by U.S. International Trade Commission (1975). (Ref. 1)
"d/ Based upon report in Chemical Marketing Reporter. July 14, 1975. (Ref. 5)
^/ Based upon report in Chemical Marketing Reporter. April 14, 1975. (Ref. 6)
77
-------
Criterion of Estimated 1974 Production Volume
The numerical rating system for the estimated 1974 annual production
volume assigns a value of 0 to 4 to each pesticide based upon the produc-
tion estimates given in Table 12. The scale used to assign these numerical
values was:
Estimated 1974 production
Rating volume (millions of pounds)
0 < 1
1 1-5
2 6-9
3 10-24
4 25 or more
This scale was developed for this study and is based upon two important
assumptions. First, the pollution potential of a pesticide increases as the
quantity of that pesticide produced increases. And second, the pollution
potential of a pesticide does not increase in direct proportion to the quan-
tity produced. It is assumed that the greater the amount of a given pesticide
a plant produces, the greater is its potential revenue, and, therefore, the
greater the financial capability of the plant operators for installing pol-
lution control devices to mitigate the pollution caused by the manufacture
of the pesticide. (This assumption should not be construed to mean that this
is the actual case, but merely that larger plants will have a greater pro-
pensity to install pollution control technology.)
Criterion of Acute Mammalian Toxicity
The numerical rating scale used for the acute mammalian toxicity of
pesticides was one that is recongnized by various authors on the subject,!/
and wast
Oral LDjQ-rats
Classification (mg/kg)
0 Insignificantly toxic > 5,000
1 Slightly toxic 500-5,000
2 Moderately toxic 50-499
3 Highly toxic 5-49
4 Extremely toxic < 5
The acute mammalian toxicity for individual pesticides is shown in
Appendix C. These data were used to assign each pesticide listed in Table
12 a numerical value for acute mammalian toxicity according to the above
scale.
78
-------
Criterion of Special Toxicity
The term special toxicity was used here to designate carcinogenicity,
mutagenicity, and teratogenicity. A pesticide which was suspected to have
any of these properties was given a rating of 4; all other pesticides were
given a rating of zero.
Each pesticide evaluated was determined to have, or not have, special
toxicity based on the information presented in Appendices C and I.
Criterion o£ Wildlife Toxicity
A numerical rating scale of 0 to 4 was used to account for the degree
of toxicity a pesticide had toward fish, birds, and invertebrates. The
greater the toxicity to and the greater the number of different species of
wildlife affected, the higher the numerical toxicity rating assigned to the
subject pesticide.
The numerical values assigned to each pesticide are the same values de-
veloped in a 1974 MRI report by von RMmker, Lawless, and Meiners^S.' and the
appropriate pages of that report from which the data were taken are shown
in Appendix J. This information base is dated but was the best source of data
available.
Criterion of Persistence
Pesticide persistence varies with environmental conditions, and some-
times the variation is substantial. Data on pesticide persistence were some-
times unavailable or given in a wide range, and had to be estimated. The fol-
lowing scale was used and is taken from the 1974 MRI report cited above:
Time (in months) for
Rating 75-100% disappearance
0 < 1
1 1-3
2 4-10
3 11-18
4 > 18
The source of information used to assign each pesticide a persistence
rating is shown in Appendix J and was also taken from the 1974 MRI report.
Criterion of Bioaccumulation, Biomagnification, and Mobility
Pesticides are more detrimental to the environment if they biomagnify,
bioaccumulate, and move throughout the environment. A rating scale of 0 to
79
-------
4 was used Co indicate the degree to which pesticides display these proper-
ties in the environment. A zero rating indicated that the pesticide bio-
magnifies or bioaccunulates to only a limited extent, or not at all, and
was relatively immobile in the environment. A rating of 4 indicated that
numerous species of wildlife and plants biomagnify and/or bioaccumulate the
pesticide, and that the pesticide was subject to transport throughout the
environment. Ratings of 1 to 3 simply indicated a matter of degree.
The source of information used to assign each pesticide a rating for
this criterion is shown in Appendix J, which was taken from the 1974 MRI
report.
SELECTION OF THE FINAL SIX CANDIDATE PESTICIDES
The priority rating system described above was used in the selection
of six candidate pesticides for detailed source assessment by ranking all
of the pesticides (except methyl bromide in the miscellaneous group) in the
limited list (Table 12). Three alternate methods of selection were used to
show which pesticides were candidates for detailed source assessment, depend-
ing upon the selection methodology and approach used. Each alternate method
and the pesticide candidates chosen by each method are discussed as follows.
Alternate Selection Method No. 1
The first selection method consisted of ranking all of the pesticides
in a numerical priority order using the priority rating system, and select-
ing the first six pesticides on the list as the best candidates for detailed
source assessment. Table 13 shows the priority ranking of the individual syn-
thetic organic pesticides evaluated in this study. The sources of informa-
tion used to provide the numerical values given in the table were previously
described.
The top six pesticides in the table are DDT, chlordane, heptachlor, MSMA,
endrin, and PGP (and sodium salts). Aldrin was excluded from consideration
because it is no longer produced in the United States.2' These six pesticides
are the candidates for source assessment selected by this method. Note that
DDT and PGP (and salts) are chemically similar and that chlordane, heptachlor,
and endrin are likewise chemically similar.
Alternate Selection Method No. 2
The second selection method consisted of ranking all of the pesticides
in a numerical priority order using the priority rating system, but with the
additional stipulation that the pesticides were segregated into the 10 chemi-
cal groups. The pesticides were segregated by chemical group so that the highest
rated pesticide from each group could be selected. This method was chosen to
avoid selecting six pesticides which were similar in chemical composition and
manufactured in a similar manner.
80
-------
Table 13. PRIORITY RANKING OF INDIVIDUAL SYNTHETIC ORGANIC PESTICIDES FOR
DETAILED SOURCE ASSESSMENTS/
oo
Criteria and numerical
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
13.
14.
15.
16.
17.
18.
19.
20.
21.
22.
23.
24.
25.
Rank- Order
Pesticide
DDT
Chlordane
Heptachlor
Aldrink/
MSMA
Endrin
PCP and Sodium
DSMA
Toxaphene
Lindane and BHC
Par at hi on
Methyl parathion
Dinoseb
Trichlorophenols
Phorate
Carbaryl
Diazinon
Disulfoton
Fensulfothlon
Carbofuran
Cacodylic acid
Trifluralin
Dyfonate®
Captan
Maneb
Total
1974
production
4
3
1
3
4
1
4
3
4
1
3
4
1
4
3
4
3
3
2
3
1
4
1
3
3
Acute
mammalian
toxicitv
2
2
3
3
3
4
3
1
2
2
4
4
3
1
4
2
2
3
4
3
1
2
4
2
1
Special
toxicitv
4
4
4
0
4
0
4
4
0
0
0
0
4
4
0
4
0
0
0
0
4
0
0
4
4
Wildlife
to^ici^v
3
1
1
2
0
3
1
0
2
1
4
3
3
0
3
0
3
3
3
3
0
3
3
0
0
ratine
Persistence
4
4
4
4
3
3
3
3
2
4
0
0
1
2
1
0
1
1
1
0
3
1
1
0
1
Bioaccumulation
biomagnif ication,
and mobility
4
4
4
4
2
4
0
2
2
4
1
1
0
0
0
1
1
0
0
I
1
0
0
0
0
Total
priority
ratine
21
18
17
16
16
15
15
13
12
12
12
12
12
11
11
11
10
10
10
10
10
10
9
9
9
-------
Table 13. (Continued)
Criteria and numerical ratine
Rank-Order
Total
1974
Pesticide production
26.
27.
28.
29.
30.
31.
32.
33.
34.
8 35.
36.
37.
38.
39.
40.
41.
42.
43.
44.
45.
46.
47.
48.
49.
50.
51.
52.
Methomyl
Aldicarb
Monocrotophos
Atrazine
Simazine
Endosulfan
Monuron
Si 1 vex
Malathion
Merphos
Garbofenthion
Ronnel
Dimethoate
Maleic hydrazide
Diuron
Zineb
Nabara
Propazine
Ficloram
Captafol
Nitralin
Bromacil
2,4-D, acids*
esters* and salts
Methoxychlor
DDVP
Gutbion®
Alachlor
3
1
2
4
3
1
1
1
4
1
1
1
1
2
3
2
1
3
1
1
1
3
4
1
1
1
4
Acute
manna 1 i an
toxicitv
3
4
3
1
1
3
1
1
1
2
3
1
2
1
2
1
2
0
1
1
1
1
2
1
2
3
1
Special
toxicitv
0
0
0
0
0
0
4
4
0
4
0
4
4
4
0
4
4
0
0
4
0
0
0
0
0
0
0
Wildlife
toxicitv
3
4
3
0
0
1
0
0
1
0
3
1
0
0
0
0
0
0
0
0
3
0
0
1
3
1
0
Persistence
0
0
0
2
3
2
2
1
0
0
0
0
0
0
2
0
0
4
4
0
1
2
0
1
0
1
1
Bioaccumulation
biomagnif ication,
and mobility
0
0
0
1
1
1
0
0
1
0
0
0
0
0
0
0
0
0
0
0
0
0
0
2
0
0
0
Total
priority
ratine
9
9
8
8
8
8
8
7
7
7
7
7
7
7
7
7
7
7
6
6
6
6
6
6
6
6
6
-------
Table 13. (Continued)
00
Criteria and
53.
54.
55.
56.
57.
58.
59.
60.
61.
62.
63.
64.
65.
66.
67.
68.
69.
70.
71.
72.
73.
74.
75.
76.
77.
78.
79.
Rank- Order
Pesticide
Dichloropropene
Chloramben
DBCP
Sodium TCA
Dicofol
Folpet
Fluometron
Chloropicrin
Bux®
Poly ram
Propachlor
Propanil
DCPA
2,3,6-TBA
Ethion
Naled
Butylate
EPTC
Butachlor
CDAA
Linuron
Benefin
Dalapon
Endothall
Dlcaroba
/s*
DBF®
Vernolate
Total
1974
production
3
3
3
3
1
1
1
1
3
1
4
3
1
1
1
1
2
2
3
2
1
1
1
1
1
1
1
Acute
mammalian
toxicitv
2
1
2
I
1
0
2
2
2
0
1
1
1
1
3
2
1
1
1
1
1
1
1
2
1
2
1
Special
toxicitv
0
0
0
0
0
4
0
0
0
4
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Wildlife
toxicitv
0
0
0
0
0
0
0
1
0
0
0
0
0
0
0
1
0
0
0
0
, 0
0
0
0
0
0
0
Persistence
0
1
0
1
2
0
2
1
0
0
0
0
2
2
0
0
1
1
0
1
2
2
1
0
1
0
1
Bioaccumulation
biomagnif ication,
and mobilitv
0
0
0
0
1
0
0
0
0
0
0
1
0
0
0
0
0
0
0
0
0
, 0
0
0
0
0
0
Total
priority
ratine
5
5
5
5
5
5
5
5
5
5
5
5
4
4
4
4
4
4
4
4
4
4
3
3
3
3
3
-------
Table 13. (Concluded)
Criteria and numerical ratine
80.
81.
82.
Rank-Order
Pesticide
Copper
naphthenates
Terbacil
Benontyl
Total
1974
product fog
1
1
1
Acute
mammalian
toxicitv
1
0
0
Special
toxicitv
0
0
0
Wildlife
toxicitv
0
0
1
Persistence
1
2
0
Bioaccumul ation
biomagnification,
and mobilitv
0
0
0
Total
priority
ratine
3
3
2
.§/ Those pesticides which have the same total priority rating (for example, aldrin and MSMA) are not arranged
in any particular order.
Aldrin is no longer produced in the United States.
-------
Table 14 shows the priority ranking of the individual synthetic organic
pesticides by chemical group. The highest ranked pesticide(s) in each group
was then selected as a candidate for detailed source assessment so that the
entire pesticides industry was represented by pesticides of dissimilar chemi-
cal compositions and dissimilar manufacturing techniques. The 10 pesticides
selected in this manner were DDT, parathion or methyl parathion, carbaryl,
atrazine or simazine, alachlor, MSMA, captan, chlordane, monuron, and dinoseb.
These pesticides were further reduced to six in number by dropping atrazine,
alachlor, captan, and monuron from the list since these four pesticides had
a lower priority rating than the other six pesticides, and since each of the
four pesticides eliminated represented the four chemical groups with the
lowest overall priority rating. (Methyl parathion and simazine were previously
eliminated since they are equivalent in priority rating to parathion and
atrazine, respectively.) Thus, the six pesticides selected by this method were
DDT, parathion, carbaryl, MSMA, chlordane, and dinoseb.
Alternate Selection Method No. 3
This method departs from the first two methods in that it not only con-
siders the priority rating of the pesticides but also takes into account the
plants which manufacture the pesticides. This approach was taken as an al-
ternative to the other two methods since any source assessment must necessarily
involve the plants which manufacture the pesticides and some useful insights
might be gained by an approach which took the manufacturing sites into consid-
eration as well as the pesticides themselves.
This approach showed that some of the plants which manufacture high
priority pesticides also manufacture pesticides with lower priorities. If
the source assessment of a particular pesticide involved assessing plants
which also produce other major pesticides, it may be useful to know that this
was the case. In fact, we assumed that this condition was desirable in this
selection method, and chose pesticides for detailed assessment which were
manufactured at the same plant(s) to allow greater flexibility in the source
assessment procedure, and, at the same time, retained the high priority pesti-
cides in the select list. The select list in this case is not limited to six
pesticides.
.Table 15 shows the pesticides with the highest priority ratings and the
plants which manufacture them. The table also includes several pesticides
with lower priority ratings that are manufactured by the same plant(s) which
produce the high priority rating pesticides listed. Several points regarding
Table 15 require further explanation to show why some pesticides are excluded,
while others are included.
85
-------
Table 14. PRIORITY RANKING OF INDIVIDUAL SYNTHETIC ORGANIC PESTICIDES FOR
DETAILED SOURCE ASSESSMENT, BY CHEMICAL GROUP
Numerical ratine
Pesticide
Group A
DDT
PGP and sodium salts
Toxaphene
Lindane and BHC
Trichlorophenols
Silvex
" 2,4-D, acids, esters
salts
Methoxychlor
Dichloropropene
Ghloramben
DBCP
Sodium TCA
Dicofol
DCPA
2,3,6-TBA
Dalapon
Endothall
Dicamba
Group B
Parathion
Methyl parathion
PhoraCe
Diazinon
Disulfoeon
Total
1974
production
4
4
4
1
4
1
4
1
3
3
3
3
1
1
1
1
1
1
3
4
3
3
3
Acute
mammalian
toxicitv
2
3
2
2
1
1
2
1
2
1
2
1
1
1
1
1
2
1
4
4
4
2
3
Special
toxicitv
4
4
0
0
4
4
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Wildlife
toxicitv
3
1
2
1
0
0
0
1
0
0
0
0
0
0
0
0
0
0
4
3
3
3
3
Persistence
4
3
2
4
2
1
0
1
0
1
0
1
2
2
2
1
0
1
0
0
1
1
1
Bioaccumulation
biomagnification,
and mobility
4
0
2
4
0
0
0
2
0
0
0
0
1
0
0
0
0
0
1
1
0
1
0
Total
priority
rating
21
15
12
12
11
7
6
6
5
5
5
5
5
4
4
3
3
3
12
12
11
10
10
-------
Table 14. (Continued)
Pesticide
Group B (continued)
Fensulfothion
Dyfonate®
Monocrotophos
Malathion
Merphos
Carbof enthion
x> Ronnel
,j
Dime t ho ate
DDVP
Gut hi on®
Ethion
Naled
DBF®
Group C
Carbaryl
Carbofuran
Maneb
Met homy 1
Aldicarb
Zineb
Nabam
Bux®
Poly ram
Butylate
EPTC
Vernolate
Benomyl
Numerical ratine
Total
1974
production
2
1
2
4
1
1
1
1
1
1
1
1
1
4
3
3
3
1
2
1
3
1
2
2
1
1
Acute
mammalian
toxicitv
4
4
3
1
2
3
1
2
2
3
3
2
2
2
3
1
3
4
i
2
2
0
1
1
1
0
Special
toxicitv
0
0
0
0
4
0
4
4
0
0
0
0
0
4
0
4
0
0
4
4
0
4
0
0
0
0
Wildlife
toxicitv
3
3
3
1
0
3
1
0
3
1
0
1
0
0
3
0
3
4
0
0
0
0
0
0
0
1
Persistence
1
1
0
0
0
0
0
0
0
1
0
0
0
0
0
1
0
0
0
0
0
0
1
1
1
0
Bio accumulation
biomagnif ication,
and mobility
0
\J
0
0
1
0
0
0
0
0
0
0
o
0
1
1
0
0
0
0
0
0
0
0
0
0
0
Total
priority
rating
in
LU
9
8
7
7
7
7
7
6
6
4
A
*T
3
11
10
9
9
9
7
7
5
5
4
4
3
2
-------
Table 14. (Continued)
oo
oo
— ' Numerical ratlm»
Total
1974
Pesticide production
Group 0
Atrazine
Simazine
Propazine
Group E
Alachlor
Propachlor
Propanil
Butachlor
Group F
MSMA
DSMA
Cacodylic acid
Copper naphthenates
Group G
Cap tan
Maleic hydrazide
Picloram
Captafol
Nitralin
Folpet
COAA
4
3
3
4
4
3
3
4
3
1
1
3
2
1
1
1
1
2
Acute
mammalian
toxicitv
1
1
0
1
1
1
1
3
1
1
1
2
1
1
1
1
0
1
Special
toxicitv
0
0
0
0
0
0
0
4
4
4
0
4
4
0
4
0
4
0
Wildlife
toxicitv
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
3
0
0
Persistence
2
3
4
1
0
0
0
3
3
3
1
0
0
4
0
1
0
1
Bioaccumulation, Total
bioraagnification, priority
and mobility ran no
1
M.
1
&
0
o
\J
o
\J
I
J.
0
2
2
fm
1
0
o
o
o
0
o
0
0
7
4
if.
10
in
AU
3
4
-------
Table 14. (Concluded)
Numerical ratine —
Pesticide
Group H
Chlordane
Heptachlor
Aldrin
End r in
Endosulf an
Group I
vo Monuron
Diuron
Bromacil
Fluometron
Linuron
Terbacil
Group J
Dinoseb
Trif luralln
Chloropicrin
Benef in
Total
1974
production
3
1
3
1
1
1
3
3
1
1
1
1
4
1
1
Acute
mammalian
toxicitv
2
3
3
4
3
1
2
1
2
1
0
3
2
2
1
Special
toxicitv
4
4
0
0
0
4
0
0
0
0
0
4
0
0
0
Wildlife
toxicitv
1
1
2
3
1
0
0
0
0
0
0
3
3
1
0
Persistence
4
4
4
3
2
2
2
2
2
2
2
1
1
1
2
Bioaccumulation,
biomagnif ication,
and mobility
4
4
4
4
1
0
0
0
0
0
0
0
0
0
0
Total
priority
rating
18
17
16
15
8
8
7
6
5
4
3
12
10
5
4
-------
Table 15. PRIORITY RANKING OF SYNTHETIC ORGANIC PESTICIDES FOR
DETAILED SOURCE ASSESSMENT BY CHEMICAL GROUP
AND MANUFACTURER
Croup
B
Pesticide
DDT
PCP and sodium
salts
Toxaphene
Parathion
Methyl parathion
Phorate
Bisulfoton
Fensulfothion
Carbaryl
Carbofuran
Aldicarb
Atrazine
Simazine
Propazine
Alachlor
Propachlor
Butachlor
Priority
rating
21
15
12
12
12
11
10
10
11
10
9
8
8
7
6
5
4
Manufacturer^ >~
Montrose, Torranee, CA
Monsanto, Sauget, IL
Vulcan, Wichita, KS
Dow, Midland, MI
Dover, Dover, OH
n~i —i_i 1 ~i m_
jjover, uover, un
Reichhold, Tacoma, WA
Hercules, Brunswick, C
Vicksburg, Vicksburg, MS
Tenneco, Fords, NJ
D4 w*A^ ft 4 J y« /^*»/*«»^v 0
Hercules, Brunswick, i
Vicksburg, Vicksburg,
Tenneco, Fords, NJ
Riverside, Groves, TX
Monsanto, Anniston, AL
Stauffer, Mt. Pleasant, TN
Monsanto, Anniston, AL
Stauffer, Mt. Pleasant, TN
Kerr-McGee, Hamilton, MS
American Cyanamid, Linden, NJ
Chemagro, Kansas City, MO
Chemagro, Kansas City, MO
Union Carbide, Institute and South
Charleston, WV
FMC, Middleport, NY
FMC, Vancouver, WA
Union Carbide, Institute and South
Charleston, WV
Ciba-Geigy, St. Gabriel, LA
Monsanto, Muscatine, IA
90
-------
Table 15. (Concluded)
Group Pesticide
F MSMA
DSMA
Cacodylic acid
G Captan
Maleic hydrazide
Folpet
CDAA
H Chlordane
Heptachlor
Endrin
I Monuron
Diuron
Bromacil
Terbacil
J Dinoseb
Trifluralin
Benefin
Priority
rating
16
13
10
5
4
18
17
15
8
7
6
3
12
10
4
Manufacturer(s V*
Vineland, Vineland, NJ
Diamond Shamrock, Greens Bayou, TX
Ansul, Marinette, WI
W. A. Cleary, Somerset, NJ
Vineland, Vineland, NJ
Diamond Shamrock, Greens Bayou, TX
Ansul, Marinette, WI
Vineland, Vineland, NJ
Ansul, Marinette, WI
R.T. Vanderbilt, Bethel, CT
Chevron, Perry, OH
Stauffer, Perry, OH
Uniroyal, Geismar, LA
Fairmount, Newark, NJ
Ansul, Marinette, WI
Chemical Formulators, Nitro, W
Chevron, Perry, OH
Stauffer, Perry, OH
Monsanto, Muscatine, IA
Northwest Industries, Marshall, IL
Prentiss Drug, Newark, NJ
Northwest Industries, Memphis, TN
Du Pont, La Porte, TX
Dow, Midland, MI
Vicksburg, Vicksburg, MS
Blue Spruce, Edison, NJ
Eli Lilly, Lafayette, IN
al Source: SRI (1976). (Ref. 10)
91
-------
In Group A, DDT and POP (and sodium salts) were selected due to their
high priority rating. Toxaphene was chosen over lindane and BHC (rating of
12, also) since toxaphene is produced in a far larger annual volume than
lindane and BHC (about 110 million pounds versus about 4 million pounds) and
toxaphene is the subject of increasing regulatory and environmental concern*
In Group B, all of the pesticides shown in the table were selected on
the basis of a high priority rating* Diazinon, with a rating of 10, was ex-
cluded since two plants manufacture this pesticide, and both fensulfothion
and disulfoton, with ratings of 10, are manufactured by the same single plant,
In Group C, aldicarb was chosen over maneb and methorny1, since each is
produced at three plants and two plants, respectively, whereas aldicarb is
produced at only one plant, and that plant is the sole producer of carbaryl,
also.
The selections in Groups D, E, and F are obvious, and the selection of
captan and maleic hydrazide in Group G are based on the high priority ratings.
In Group G, folpet was added since it is produced at the same plants as is
captan, and CDAA was added since it is produced at the same plant which pro-
duces the anilides in Group E.
The selections in Group H and I are obvious except for the fact that
aldrin (rating of 16) was excluded in Group H. Aldrin is no longer being manu-
factured by Shell Chemical Company in Denver, Colorado, who was the sole pro-
ducer of this pesticide in 1974.
In Group J, dinoseb and trifluralin were selected on the basis of high
priority ratings and benefin was added since it is manufactured by the same
plant which manufactures trifluralin.
The pesticides listed in Table 15 were reduced to a smaller number by
making one further assumption; namely that it would be more economical and
efficient to assess pesticides produced at the same plant(s) and those pesti-
cides produced at the fewest plants, when the priority ratings were the same
or nearly the same for alternate pesticides. This assumption led to the final
select list of pesticides shown in Table 16. The 27 major pesticides in that
table represent the highest priority pesticides in each chemical group ex-
cept chlordane (Group H) and dinoseb (Group J). Detailed source assessments
of 27 major pesticides could be made by visiting 18 plant sites. The listing
of 27 candidate pesticides can be reduced to six by comparison with the pesti-
cide selections from the other two alternate methods.
SUMMARY AND INTERCOMPARISON OF PESTICIDE SELECTIONS BY THE THREE ALTERNATE
METHODS
As indicated in Table 9 (p. 69) the total number of pesticide candidates
selected by the three alternate methods are:
92
-------
Table 16. CANDIDATE PESTICIDES SELECTED BY PRIORITY AND MANUFACTURER
Chemical
group
A
B
D
E
H
I
Pesticide
DDT
Parathion and methyl parathion
Disulfoton and fensulfothion
Carbaryl and aldicarb
Atrazine, simazine, and propazine
Alachlor, propachlor, and
butachlor
MSMA, DSMA, and cacodylic acid
Captan and folpet
CDAA
Heptachlor and endrin
Monuron, diuron, bromacil, and
terbacil
Trifluralin and benefin
Manufacturer
Montrose, Torrance, CA
Monsanto, Anniston, AL
Stauffer, Mt. Pleasant, TN
Kerr-McGee, Hamilton, MS
Chemagro, Kansas City, MO
Union Carbide, Institute and South
Charleston, W
Ciba-Geigy, St. Gabriel, LA
Monsanto, Muscatine, IA
Vineland, Vineland, NJ
Ansul, Marinette, WI
Diamond Shamrock, Greens Bayou, TX
W. A. Cleary, Somerset, NJ
Chevron, Perry, OH
Stauffer, Perry, OH
R. T. Vanderbilt, Bethel, CT
Monsanto, Muscatine, IA
Northwest Industries, Memphis, TN
Du Pont, La Porte, TX
Eli Lilly, Layfayette, IN
93
-------
Method No. 1 6
Method No. 2 10
Method No. 3 27
The problem before us is to select six final candidate pesticides for detailed
source assessment utilizing as much as possible the advantages of all three
methodologies. Method No* 1 rank-orders the pesticides by a total priority
rating system ignoring other considerations such as chemical class, manufac-
turer, location, and other pesticides jointly manufactured. Methods Nos. 2
and 3 take these factors into consideration as was previously developed. The
authors believe each methodology has merit, that none is "perfect," and that
none is unique among other possible methodologies. Indeed, there may be
another set of methodologies possible to perform the selection, e.g., one
based on a "weighted" priority rating system using the same criteria (produc-
tion volume, toxicity, etc.) but individually weighted differently.
Utilizing the results from the three methodologies the final selection
of six pesticide candidates for detailed source assessment is made as follows:
. Select common pesticide candidates from the three lists.
. Select candidates from as many different chemical classes as possible
(maximum of six).
. Select candidates having higher priority ratings as opposed to those
of lower priority ratings.
These guidelines suggest the final six pesticide candidates for the following
reasons:
DDT and MSMA - common to all three methodologies, two different chemical
classes, high priority ratings.
Parathion (or methyl parathion which is numerically equivalent), carbaryl,
and chlordane (or heptachlor or endrin which are numerically equiva-
lent) - common to two methodologies, three different chemical classes,
high priority ratings.
PGP (and salts) - high priority rating.
Thus, six final candidate pesticides have been selected encompassing five chemi.
cal classes, individually having high total priority ratings (ratings of 21
to 11) and having indicated the manufacturer and the geographic location. The
report also indicates which alternate pesticides are manufactured at these
locations for possible assessment in addition to the final selected candidate
pesticide.
94
-------
The basic data in this section are developed in a manner to allow re-
assessment of any pesticide relative to other pesticides if an alternate
methodology is preferred.
95
-------
REFERENCES TO SECTION 4
1. Synthetic Organic Chemicals. United States Production and Sales of Pesti-
cides and Related Products, United States International Trade Commission.
Washington, D.C., 1975.
2. Honea, F. I., D. Punzak, E. W. Lawless, L. J. Shannon, and 0. Wallace.
Pesticides Industry: Task Report. EPA Contract No. 68-02-1324, Tasks
Nos. 28 and 38, June 25, 1975.
3. Fowler, D. L., and J. N. Mahan. The Pesticide Review 1974. United
States Department of Agriculture, Agricultural Stabilization and Con-
servation Service,Washington, B.C., September 1975.
4. Chemical Marketing Reporter, January 5, 1976.
5. Chemical Marketing Reporter, July 14, 1975.
6. Chemical Marketing Reporter, April 14, 1975.
7. Kohan, A. M. A Summary of Hazardous Substance Classification Systems.
EPA 530/SW-171, U.S. Environmental Protection Agency, December 1975.
8. von RUmker, R., E. W. Lawless, and A. F. Meiners. Production, Dls-
tion, Use, and Environmental Impact Potential of Selected Pesticides.
EPA 540/1-74-001, for the Council on Environmental Quality, 1974.
9. Meiners, A. F., C. E. Mumma, T. L. Ferguson, and G. L. Kelso. Wastewater
Treatment Technology Documentation for Aldrin/Dleldrin Manufacture and
Formulation. EPA Contract No. 68-01-3524, February 6, 1976.
10. Stanford Research Institute. Directory of Chemical Producers—United
States of America, Chemical Information Service, Menlo Park, California,
1976.
96
-------
SECTION 5
PRESENT AND ANTICIPATED REGULATORY CLIMATE FACING
PESTICIDE MANUFACTURERS
INTRODUCTION
The pesticide manufacturing industry will continue to face direct regu-
lation from EPA and the Occupational Safety and Health Administration (OSHA),
the two independent agencies having the greatest interest in pesticide manu-
facturing activities* EPA will continue to have major responsibility for
enforcement of pollution standards (air, water, and solid waste) and registra-
tion of pesticides. OSHA will continue its concern with worker health and
safety. In addition, some indirect regulation may come from the Consumer
Product Safety Commission (CFSC), but it is not considered to have a major
impact on pesticides at this time.
GOVERNMENT GROUPS AT INTEREST
A complete listing of governmental groups at interest in pesticide manu-
facturing is unavailable at this time. A partial listing of federal groups
and individuals is shown in Table 17. Most of the discussion of anticipated
regulation was conducted with these individuals. They represent the range
of government agencies and groups interested in pesticide manufacture and
registration. While they cannot be construed as spokesmen for their respec-
tive groups, these are the appropriate individuals for further discussion of
the regulatory pressures facing pesticide manufacturers.
EXECUTIVE AGENCIES
Two cabinet-level agencies, the Department of Agriculture and the Depart-
ment of Commerce, have the major responsibility for pesticide manufacture
and use. They, in conjunction with the Office of Management and Budget (OMB),
serve as a counterbalance to the interests of other executive agencies con-
cerned with pesticides. Traditionally, they represent farmers and business,
respectively. As noted earlier, EPA and OSHA are concerned with the regula-
tion of the production and environmental use of pesticides.
97
-------
Table 17. INDIVIDUALS CONTACTED TO DISCUSS ANTICIPATED REGULATORY
PRESSURES FACING PESTICIDE MANUFACTURERS
EPA
Mr. Fred Talcott
Mr. Jeff Jones
Mr. William Wymer
Mr. Bob Wahlen
Senate
Mr. Bill Taggert
Mr. Mike Brownlee
Mr. Steve Quarles
Mr. Richard Hellman
House
Mr. Nick Ashmore
Ms. Sue Nelson
Mr. Dave Nix
Mr. Rod Byerly
Mr. Lynch
OSHA
Mr. Phil Beck
CEQ
Dr. Warren Muir
CUB
Mr. Tozzi
Library of Congress
Dr. John Blodgett
Office of Pesticide Programs
Operations Division
Federal Working Group on Pest Management
Congressional Liaison Office
Committee on
Committee on
Subcommittee
Committee on
Subcommittee
Resources
Committee on
Subcommittee
Committee on
Committee on
Subcommittee
and Health
Committee on
Subcommittee
Committee on
Committee on
Subcommittee
Agriculture and Forestry
Commerce
on the Environment
Interior and Insular Affairs
on Environment and Land
Public Works
on Environmental Pollution
Agriculture
Education and Labor
on Manpower, Compensation,
Safety
Interior and Insular Affairs
on Energy and Environment
Science and Technology
Small Business
on Regulatory Agencies
Environmental Policy Research Division
98
-------
LEGISLATIVE AGENCIES
The Senate has four committees with interest (although not necessarily
jurisdiction) in pesticides manufacturing and use—Agriculture and Forestry,
Commerce, Interior and Insular Affairs, and Public Works. Of the four, only
Interior and Insular Affairs feels it does not have jurisdiction.
The House of Representatives has five committees with interest in pes-
ticides manufacturing and use—-Agriculture and Forestry, Education and Labor,
Interior and Insular Affairs, Science and Technology, and Small Business. Once
again, Interior and Insular Affairs claims no jurisdiction. Small Business
and Science and Technology have not focused a great deal of their attention
on pesticide matters.
The Library of Congress, through the Congressional Research Services,
provides information services and data analyses to congressional committees.
The Environmental Policy Research Division is responsible for analytical
research work in the area of pesticides.
AREAS OF REGULATORY INTEREST
Existing Regulations
According to all sources, there will be little or no change in existing
regulations. All existing standards, tolerances, and exposure limits will con-
tinue in force. Most important, whatever changes do occur, they will not re-
sult in a loosening of existing regulations.
Anticipated Regulations
Eighteen areas of anticipated regulatory interest were suggested. These
areas were grouped into eight major categories on the basis of the major con-
cern, e.g., testing, exposures, etc., and are shown in Table 18 and discussed
below.
Table 18. MAJOR ANTICIPATED AREAS OF REGULATORY INTEREST
1. Testing
2. Inspection
3. Exposure
4. Disposal
5. Insurance/Indemnity
6. Control Technology for Biological Pesticides
7. Economic Impact Statement
8. Public Pressure
99
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Testing--
Two additional testing requirements are anticipated. The first is large-
scale long-term testing for the effects of low level exposure. The second is
a requirement for some testing to be done by independent laboratories. The
emphasis in all testing will be on mutagenic and teratogenic effects.
Inspection--
It is anticipated that both EPA and OSHA will conduct on-site inspections
to determine if pollution levels (EPA) and exposure levels (OSHA) are within
the established limits.
Exposure-
There appear to be two concerns here. The first is preventive; the second
relates to already exposed workers. The preventive concern is to establish
procedures, devise clothing, etc., that will safeguard those workers involved
in formulating chemical or biological pesticides. The second concern seeks to
assist those workers who have been exposed to excessive levels of harmful mate-
rials with adequate medical attention and follow-up.
Waste Disposal—
The current procedures for waste disposal may prove harmful or inadequate.
Other methods of waste disposal may be required, especially in the solid waste
area.
Insurance/Indemnity—
A number of suggestions have been offered to create an insurance/indemnity
program to protect the worker and the company. In some cases an argument is
made to increase company liability in workman's compensation. Others argue for
some other risk-sharing arrangement, e.g., an indemnity tax on purchase price.
Control Technology for Biological Pesticides—
Despite the benefits of biological control of pest infestation, the costs
of preventing their unrestricted release to the atmosphere and land may be
prohibitive. Without adequate control mechanisms, severe restrictions on the
use of biological pesticides may exist.
Economic Impact Statement—
The need for a given chemical pesticide may outweigh its potential danger.
This usually is determined by an economic impact statement. Consequently, de-
spite some risk, a given chemical pesticide may continue to be manufactured
and used.
Public Pressure—
This is virtually an unknown factor affecting all pesticide manufacturers.
Public pressure on officials and the government can cause arbitrary and capri-
cious decisions to be hastily made. There is little time to anticipate what
100
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practice, if any, will cause a public outcry. Hence, manufacturers (and EPA)
will have little "a priori" opportunity to anticipate this regulatory pressure.
101
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APPENDIX A
INDUSTRIAL CHEMICALS ALSO USEFUL AS PESTICIDES
A-l
-------
Caswell Pesticide
Pesticides, General Listing Accession No. Type
Acrolein 9 H
Acrylonitrile 10 Fu
Allyl Alcohol 26 H
Ammonium Thiocyanate — H
Anthraquinone 52A R
Arsenic Acid 56 H
Biphenyl 87 F
Bis(diethylthiocarbamoyl)disulfide — F
Bis(dimethylthiocarbamoyl)disulfide — F,R
Bis(dimethylthiocarbamoyl)sulfide — F
Borascu
Borax Sodium Borates 108 H,I
Boro-Spray
Calcium Arsenate 137 I
Carbon Disulfide 162 Fu
Carbon Tetrachloride 164 Fu
Copper Acetoarsenite (Paris Green) 638 I
Copper Carbonate 235 F
Copper Naphthenate 245 F
Copper Oleate 248 F
Copper Oxychloride Sulfate 250 F
Copper Sulfate 256 F
DMA (dehydroacetic acid) 278 F
DMP (dimethyl phthalate) 380 R
Dichlorobenzene (ortho and para isomers) 623, 632 I
Diraethyldithiocarbamic acid, K salt — F
Dimethyldithiocarbamic acid, Na salt « F
Dimethyldithiocarbamic acid, Zn salt — F,R
Diphenylamine 398 I
Ethylene 436 PGR
Ethylene Dibromide 439 I,N
Ethylene Dichloride 440 Fu
Ethylene Oxide 443 Fu
Ethyl Formate 443A Fu
Formaldehyde, formalin 465 Fu
HCB (hexachlorobenzene) 477 F
HCN (hydrocyanic acid) 483 Fu
A-2
-------
Pesticides, General Listing
Lead Arsenate
Mercuric Chloride
OPP (£-phenylphenol)
Sodium Arsenite
Sodium Chlorate
Sodium Fluoride
Sulfur
Thiram
Caswell Pesticide
Accession No, Type
524 I
544
658
744
753
769
812
F
F
H,I
H
R
F,M
856
F,R
Total 46 Compounds
Source: Stanford Directory of Chemical Producers - USA, Stanford Research
Institute, Meno Park, California, 1976.
A-3
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APPENDIX B
SUMMARY UPDATE TO THE POLLUTION POTENTIAL IN
PESTICIDE MANUFACTURING - 1972""
B-l
-------
The use of pesticides has become an extremely important factor in the
United States and indeed throughout the world in determining man's quality
of life. The benefits which have been obtained from this usage—increased
production of food and fiber and increased freedom from disease and obnox-
ious plant and animal life—have not beep without some undesirable side ef-
fects, such as direct effects on nontarget organisms, the indirect unbalanc-
ing of delicate ecosystems, and the environmental contamination by persistent
pesticides which may tend to be biologically accumulated in food chains. In
addition, the possible long-term effects of low levels of pesticides on man
himself are the cause of serious concern. Hence, the entire subject of pesti-
cide production and use is under intensive study by government and nongovern-
ment scientists in the United States and in many other countries.
The production and use of pesticides is not new or even of recent origin.
From ancient times man has investigated the minerals, and the plant and animal
life around him for their value as medicinals, in the production of his food,
in warding off the attacks of obnoxious or dangerous insects, and against
his fellow man. A tremendous growth has occurred, however, during the past
40 years in the number of pesticides available, the variety of applications,
and the volumes of production of the active ingredients and their formulated
products. A broad definition of "pesticides" is used here which includes:
rodenticides, insecticides, larvacides, miticides (acaricides), molluscicides,
nematocides, repellents, synergists, fumigants, soil conditioners, fungicides,
algicides, herbicides, defoliants, desiccants, plant growth regulators, and
sterilants.
EPA's Office of Pesticide Programs (OPP) has estimated that in 1975 there
were 1,200 pesticide active ingredients registered for use in pesticide pro-
ducts. This estimate is based on the assumption that some active ingredients
have multiple uses, so that the 1,200 estimate counts each active ingredient
only once.
These active ingredients are formulated into 23,633 different pesticide
products (as of October 23, 1975) at 5,353 registered formulating plants (as
of July 9, 1975) throughout the United States. These plants are registered
as follows: 4,111, interstate; 1,023, intrastate; and 218, foreign.
The objective of this study was to survey and evaluate the environmental
pollution potential associated with the manufacture, formulation, and market-
ing of pesticides, including such related activities as packaging, transporta-
tion, and warehousing, i.e., all of the operations up to the point at which
a pesticide is placed in the hands of the consumer.
B-2
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PESTICIDE PRODUCTION VOLUMES
In order to evaluate the pollution potential of pesticide manufacture,
knowledge of current production volumes was needed. A serious handicap here
was the unavailability of data on how much of each pesticide is produced or
even on which ones are produced in the largest quantities in the United States.
Most of this information is in the hands of the U.S.' International Trade Com-
mission, but it is not disclosed in a useful manner. The International Trade
Commission publishes partial production data for synthetic organic compounds.
A section on pesticides is included, but the data are categorized and grouped;
no data are disclosed for specific compounds unless there are three or more
producers (and not even then if one producer is dominant) because these data
are considered proprietary by the companies and are revealed in confidence
to the Commission. Under this policy, production data are not now available
on the most widely used insecticide (toxaphene) or herbicide (atrazine). We
strongly recommend that public disclosure of production data for pesticides
and all hazardous materials be made mandatory, so that scientists, regulatory
officials, legislators, and other concerned citizens can make use of these
data for an intelligent assessment of environmental impacts and of areas which
require further research, new regulations or legislation. Furthermore, a
sizable percentage of the pesticide industry may be in favor of the uniform
disclosure of these data because under the present situation most companies
must maintain an expensive staff of market researchers to develop many of
these data anyway.
The 1974 production volumes of all synthetic organic pesticides have been
estimated on this program. The results for the major synthetic organic pesti-
cide groups and individual pesticides are shown in Tables B-l to B-3 and show
that the 1.42 billion pounds of active pesticide ingredients produced in 1974
consisted of about 37 major pesticides (those produced in volumes of 10 mil-
lion pounds or more). This accounted for a combined production of 1.04 billion
pounds or 74% of the market while the remaining 26% is divided among 300 other
pesticides. A total of 140 to 150 synthetic organic pesticides are estimated
to have had production volumes in excess of 1 million pounds in 1974.
STUDY APPROACH
The approach used in this survey and evaluation has been to select pes-
ticides, producers, femulators, and packagers which would be representative
of the industry,
A system was developed in which pesticides were rated on the basis of
production volume (present and projected), chemical class and production
technology, use pattern (biological activity and major crops), toxicity in-
cluding human (acute and public health) and nontarget, persistence and bio-
magnification, and public or legislative concern.
B-3
-------
Table B-l. U.S. PRODUCTION OF SYNTHETIC ORGANIC PESTICIDES,
BY CATEGORY, IN 1974
1974 Production
PESTICIDE CATEGORIES (Millions of pounds)
Fungicides
PCP and sodium salts 52.4
Naphthenic acid, copper salt 2.0
Other cyclic fungicides 70.1
Dithiocarbamic acid salts 35.4
Other acyclic fungicides 2.8
Total fungicides 162.7
Herbicides and plant hormones
Maleic hydrazide 5.8
2,4-D acid, dimethylamine salt 14.5
Other cyclic compounds 467.4
All acyclic compounds H6.5
Total herbicides and plant hormones 604.2
Insecticides, rodenticides, soil conditioners and fumigants
Aldrin-toxaphene group 141.7
Methyl parathion 51.4
Other cyclic organophosphorus insecticides 56.4
Methoxychlor 3.2
Other cyclic insecticides and rodenticides 160.5
Methyl bromide 30.5
Acyclic organophosphorus insecticides 78.8
Chloropicrin 4.8
Other acyclic insecticides, rodenticides, soil con- 123.0
ditioners, and fumigants
Total
Total synthetic organic pesticide production, 1974
Source: U.S. International Trade Commission (1975).
B-4
-------
Table B-2. U.S. PRODUCTION OF SYNTHETIC ORGANIC PESTICIDES,
BY CHEMICAL GROUP, IN 1974
Chemical group
Chlorinated hydrocarbons
Organophosphorus
Carbamates
Triazines
Anilides
Other nitrogenous compounds
Organoarsenicals and organometallies
Diene-based
Ureas and uracils
Nitrated hydrocarbons
All others
Total
Estimated 1974 production
(Millions of pounds)
1,417
Estimated percentage
of total production
(Rounded)
33
14
10
10
8
5
4
3
3
3
7
100
Source: MRI estimates (February 1976)
B-5
-------
Table B-3. ESTIMATED U.S. PRODUCTION OF MAJOR INDIVIDUAL SYNTHETIC ORGANIC PESTICIDES, BY CATEGORY, IN 1974
Chemical group
Chlorinated hydrocarbons
OrganophosphaCes
Carbamates
Triazines
Anilides
Organoarsenicals and organomecallics
Pesticide
Toxaphene
DDT
2,4-D acid, esters, salts
PCP and sodium salts
Trichlorophenols
Dichloropropene
Chloramben
DBCP
Sodium TCA
All others
Methyl pa rath ion
Malathion
Parachion
Dlazinon
Disulfoton
Phorate
MonocroCophos
Fensulfothion
Merphos
All others
Carbaryl
Maneb
Metalkamate
Carbofuran
Butylatt
Zineb
EPTC
Nabam
Vernolate
Aldicarb
All others
Atrazine-
Simazine
Propazine
All others
Propachlor
Alachlor
Propanil
Butachlor
KSMA
DSMA
Cacodylic acid
Copper naphthenates
All others
B-6
Estimated 1974 production
(Millions of pounds)
Approximate percentage
of production
in each group
24
13
12
11
6
6
5
4
3
16
100
25
15
9
6
5
5
4
3
2
26
100
39
8
7
7
5
5
4
3
3
3
16
100
73
10
7
10
100
41
36
14
9
100
64
18
5
3
10
100
-------
Table B-3. (Concluded)
Chemical group
Other nitrogenous compounds
Pesticide
Captan
Methooyl
CDAA
Maleic hydrazide
Benooyl
Nitralin
Picloram
Captafol
Folpec
All others
Estimated 1974 production
(Millions of pounds)
Approximate percentage
of production
in each group
29
14
10
9
6
4
4
4
4
16
100
Diene-based
Ureas and uracils
Chlordane
Aldrin
Endrin
Heptachlor
Eodosulfan
All others
Bromacil
Diuron
Fluometuron
Linuron
Terbacil
All others
38
25
7
7
7
16
100
30
25
13
7
7
18
100
Nitrated hydrocarbons
Trifluralin
Chloropicrin
Dinoseb
Benefin
All others
63
13
7
7
10
100
All others
Methyl bromide
Miscellaneous
Total all synthetic organic pesticides
30
7.0
100
Source: MR I estimates (February 1976)
a/ Based upon DDT exports of 56.4 million pounds (1007. basis) in 1974, as reported in The Pesticide Review.
1974 (1975).
b/ Based upon report in Chemical Marketing Reporter, January 5, 1976.
"/ Based upon data published by U.S. Internation Trade Coonisaion (1975).
d/ Based upon report in Chemical Marketing Reporter (July 14, 1975).
e"/ B«s*d uP°n reP°rt in Chemical Marketing Reporter (April 14, 1975).
B-7
-------
On the basis of these ratings, 22 representative pesticides were selected for
intensive study of the pollutional aspects of the manufacturing process.
These 22 pesticides are listed in Table B-4 along with their use, chemical
class, estimated production, mammalian toxicity and relative environmental
persistence. The production sites of these pesticides are shown in Figure B-
1.
Personal contacts and visits were made with the producers of the 22 se-
lected pesticides and also with 15 formulators and packagers and these were
supplemented by review of the literature on production, formulation, packaging,
and marketing practices.
SPECIAL NOTES FROM THE CASE STUDIES OF MANUFACTURERS
The case studies developed a considerable amount of information on the
practices of the pesticide manufacturers which is related to the overall pol-
lution potential. Because of the diversity of processes used for the different
pesticides and the different pollution control practices employed, comparison
is difficult, but several aspects are worthy of discussion.
Raw Materials
The raw materials used for the synthesis of many pesticides are hazardous
materials, and some pollution potential is inherent in the transportation and
handling of materials of this nature. Some of these materials are flammable,
some are corrosive and poisonous, and some may be exceptionally toxic to fish
if spilled into waters. However, the transportation of these materials is sub-
ject to close governmental regulation, and the handling practices of the pes-
ticide manufacturers are as good as or better than those of industry in general,
The raw material which is common to the most pesticides is elemental
chlorine, which is used directly on-site in the production of chlordane, toxa-
phene, 2,4-D, 2,4,5-T, atrazine, captan, carbaryl, and mercuric chloride and
is used to prepare raw materials brought in for the production of DDT, aldrin-
dieldrin, and perhaps also trifluralin and alachlor. The production of this
chlorine formerly involved extensive use of the mercury cells which led to
the well publicized mercury losses. Now, however, these cells are being better
controlled and are being displaced by the mercury free diaphragm cells. Only
two of the pesticide producers studied here use on-site chlorine generation,
while the other chlorine users receive it in tank car quantities by rail, with
the exception of one plant which receives it by pipeline*
Other materials of unusually hazardous nature which are transported by
rail, barge or truck include hydrogen cyanide (of which over 10 million pounds
are required for atrazine), carbon disulfide, various amines, and the concen-
trated acids and caustic. The V2$5 used in all the organophosphorus pesticides,
B-8
-------
Table B-4. USES, CLASSES AND PRODUCTION VOLUMES OF SELECTED PESTICIDES
Selected Peatlcldea
Alachlor (Lasso)
Aldlcarb (Temlk)
Aldrln
Atrazlne
B. thuringlensla
Captan
Carbaryl (Sevln)
Chlordane
2,4-D
OUT
Dleldrln
Dlsulfoton
Malathlon
Mercury fungicidea
Methyl bromide
04 Methyl parathlon
' Parathlon
vO
Phorate (Thlmet)
Pyrethrlns
2,4, 5-T
Toxaphene (including
Strobane-T)
Trlfluralln (Treflan)
• *a c ^ o i t*
• ••SSI.! S : o S 5J3-3
•OU*OU(«U«I1J M 41 -^ .C *4 M U
•H 0-*4 ~4 M« a 4*~* »* * WO. C O *r4
U • 0 u T< " •* 8 ("• 0 J3 • O « 5 -H Ml
*4«>* • oh * •£ -" "• aau C S -. •
0 H M • •H-D jl 144 fsO -^ Jo 5 0 3 0 .3
3 S • o ft *, C ai Iji ** C 3 a o -rt «3
(M H. B r-l U J3 H O S5 X 0. ^OO. M ID m O
H X
I X
1 X
H X
I X
F X
I X
I X
H X
I X
I X
I X
1 X
F X
Fu X
I X
1 X
I X
I X
H X
I X
__!!_-_-_ - - ___!
Estimated annual
production 1974
(MM Ib/year)
40
5
10
110
2
20
58
IS
55
60
0.5
10
30
0.2
31
51
17
10
0.3
5
110
25
Oral
mammalian toxiclty
LD50 (mg/kg)
1,200
0.6
40
1,750
Nontoxlc
480
89
283
375
113
46
10
600 «
30-200
21 mgH
4
2
1
1,500
300
60
500
Environmental
persistence
Low
Low
High
Low
Low
Medium
Low
High
Low
High
High
Low
Lou
Low
Lou
Low
Medium
Medium
Lou
Low
Medium
Low
Total* (22 pesticides)
14
12
11
665.0
-------
bd
i
Figure B-l. Production distribution for 22 major pesticides
-------
the 05015 used for aldrin, and numerous other materials also pose some
hazard.
The raw materials may be stored on-site in bulk storage facilities, but
in many cases are drawn directly from the shipping container (e.g., tank car
or tote bin) and used in the production processes* The handling of materials
such as chlorine are apparently in conformity with good industrial practice
codes. Accidental spills of raw materials occasionally occur which require
special clean-up and disposal procedures. In many cases, scrubbers or dust
collection equipment are used in the raw material unloading areas.
Production Processes
The manufacturing processes for pesticides vary considerably from pro-
duct to product, but two characteristics are generally present which may
differentiate the pesticide industry from many, if not all, of the large in-
dustries which are of environmental pollution concern: (a) the ingredients
handled or produced can have high toxicity to some animals (e.g., man or fish)
or plant life; and (b) the production processes normally require only low or
moderate temperatures, compared for example to industries producing ore- or
rock-derived products. Because of the toxicity of the materials handled,
production facilities were designed to include a great many safety features
to minimize occupational hazards* Because of the moderate temperature, air
pollution control of good efficiency could be largely adapted from existing
technology. Water pollution control, as discussed in a subsequent section,
poses a much more difficult problem than air pollution in the pesticide in-
dustry.
The production plants for the 22 key pesticides studied range from ca-
pacities of less than 1 million pounds per year to about 100 million pounds
per year, and the plant equipment ranges from 1 year old to over 20 years old,
and in at least two cases the plant buildings are over 50 years old* In general,
the more toxic materials such as the organophosphorus and carbamate insecti-
cides and some of the herbicides which have undergone rapid growth recently
(such as atrazine) are produced in new plants, while many of the older chlo-
rinated hydrocarbons and other products are produced in somewhat older equip-
ment* However, almost none of the plants have been designed since the advent
of the recent increased consciousness of environmental concern, and most of
the companies interviewed have recently completed, are building, or are de-
signing new pollution control equipment to bring their plants into conform-
ity with local standards.
The production equipment is used in almost every case, either for only
one product or for two very similar products, i.e., two products of the same
chemical family and with similar pesticidal applications. Cleanup of equip-
ment is therefore minimal, especially when compared to that required in a
B-ll
-------
formulation plant where many products are processed through the same equip-
ment. In cases in which solvent cleanup of process equipment is required, the
used solvent is generally reused as a matter of economics by recycling to
the process, or it may be used in formulation or combusted for fuel.
Most of the companies interviewed have fairly extensive contingency plans.
Many of them maintain a company fire department; and others state that they
work closely with local fire departments, but this cooperation could probably
be improved in nearly all cases.
Good practice dictates that production facilities be diked and that run-
off from malfunction, spills, fire extinguishment, etc., be contained in a
holding pond or pit until treated, so that overloading of the conventional
waste treatment plant is avoided. This procedure is in effect in many plants.
All the manufacturers of the 22 key pesticides have on-site quality con-
trol laboratory facilities and frequently monitor the raw materials and reac-
tion intermediates as well as the final product. In almost no case, it would
seem, is a production run of such poor quality or so far "off spec" that it
cannot be used--either blended off with a higher quality batch or reworked
to remove objectionable impurities.
The efficiency of the synthesis reactions as commercially conducted is
generally regarded as proprietary information. Similarly, the efficiencies
of recovery of products, by-products, and unreacted starting materials are
not available. The efficiency of recovery in the past has often depended on
the price of the product balanced against the difficulty of recovery, and
hence a widely and easily produced material like DDT was previously discharged
in sizable quantities. The present trend is toward better recovery and water
economy in order to minimize treatment or disposal costs.
Storage, Handling* and Shipping
The use of most pesticidal products is seasonal with the major applica-
tion occurring during the spring or summer season. Therefore, production and
formulation also tend to be seasonal in order to avoid building up undesir-
ably large inventories* Among the manufacturers of the key pesticides studied,
several noted that their production peaked in late winter or early spring and
some stated that they did not produce during the summer months. On the other
hand, most companies do produce the year around and also may formulate on-site
so that extensive storage facilities are required* Production site storage
in bulk or tank car quantities is sometimes practiced, but long-term storage
appears to be more often in drums.
B-12
-------
Good storage practices dictate that different pesticides be stored sep-
arately or at least in well marked locations within a warehouse. In cases in
which a company handles more than one pesticide at a given location, special
care is usually taken to keep herbicides well segregated from fungicides and
insecticides, but pesticides which are similar chemically and in activity
may be produced in the same equipment and stored in the same area*
The storage facilities of the major producers appear to be generally
well regulated to prevent accidental losses of pesticides during handling
and storage and well equipped with fire protection. These facilities, however,
are not as frequently diked as are the production areas. Similarly, most com-
panies appear to specify such fire protection equipment as automatic sprin-
kler when they use public warehouses, but few of these warehouses are diked.
Thus, warehouse fires which require the use of large amounts of water are a
serious potential source of pesticide pollution. The further the warehouse
is from the control of the primary producer, the greater the potential in an
estimated majority of cases.
The mode of transporting pesticides from the production sites to the
customer, distant storage facility, or formulator varies widely because of
the variations in location of production sites and use areas. The products
are shipped by various combinations of rail and truck, depending on the nature
of the material, packaging practices, and the marketing structure. Shipping
containers range in size from gallon cans and small bags to 6,000-gal. tanks.
The packaging and transportation practices generate different pollu-
tion potentials for different products. Most of the highly toxic organophos-
phates such as disulfoton and the parathions are never shipped in tanks—only
drums. Similarly, the toxic carbamates are shipped as 50-lb bags in the case
of carbaryl, and in two specially modified tank trucks in the. case of the ex-
tremely toxic aldicarb. The shipment of liquid pesticides (and particularly
toxic organophosphates) in drums reduces the potential for a large spill of
hazardous material, but the handling and disposal of the emptied drums is a
serious problem. On the other hand, most of the toxaphene is shipped in tank
cars and trucks and transferred directly into company owned bulk storage tanks
at the formulators' location, and no used drums are generated in this step.
A significant difference in pollution potential exists between transport
in tank cars and tank trucks. Tank cars are either company owned or leased
by the company from the railroad and are used over and over for the same or
a similar product. If the tank car requires cleaning between shipments or
before return to the railroad (as during the slack season), cleanup is done
at the production site and wastes go to the company's detoxification or dis-
posal system. Tank trucks, on the other hand, normally are received from the
trucking firm in a clean and dry condition, are filled, then transported to
the destination and unloaded by the trucker who then has the responsibility
B-13
-------
for cleanup before the truck goes to another customer. The trucking firm,
however, normally does not have the detoxification and decontamination equip-
ment nor the technical expertise available at the manufacturer. Washings are
probably most often disposed in the most convenient manner.
Pesticides which are packaged in cans, drums, and bags are very often
shipped from the manufacturers only in truckload or carload lots. In many
cases, however, as the distribution system fans out, consignment becomes less
than carload or truckload lots and the pesticides become part of 'mixed lot
shipments. In such cases, the manufacturer loses some control over the product,
and it may be shipped together with flammable solvents or other material which
might increase the pollution potential.
By-Products and Wastes
The production of virtually every pesticide produces aqueous or gaseous
streams and frequently solid wastes which contain unreacted ingredients, un-
recovered products and solvents, and unavoidable or undesirable by-products.
Extensive efforts are usually made to minimize by-products and to recover,
recycle or otherwise prevent these process losses from occurring. For each
process, however, a balance point is eventually reached between the expense
of recovery and the value of the recovered product. In the past, the economic
considerations were frequently dominant and process losses were included as
unavoidable costs. Under the recent emphasis on environmental contamination,
further efforts have been made to recover many previously lost materials—even
when economics indicated that it was more expensive to do so—and most pesti-
cide manufacturers have invested in or are in the process of building exten-
sive waste treatment facilities wherein those wastes which cannot be recovered
are degraded to acceptable levels or disposed by state approved methods. A
summary of the principal wastes generated and the disposal methods employed
by the producers of the key pesticides is shown in Table B-5.
While most of the companies interviewed indicated that they are presently
in conformity with local standards, a quantitative picture of the overall pol-
lution potential could not be developed during this program. Under the 1899
Refuse Act Permit Program, those companies which discharge to navigable water
have been filing discharge data with the Corps of Engineers, but unfortunately,
these data became available only very late in our study. Those data which we
have seen, however, indicate that production processes as presently employed
for several product lines lead to surprisingly large losses of active ingredi-
ents and toxic raw materials or by-products.
B-14
-------
Table B-5. SUMMARY OF MANUFACTURING WASTES AND DISPOSAL
W
!-•
in
Liquid wastes
Pesticide
DDT
Aldrin
Dleldrln
Chlordane
Toxaphene
Disulfoton
Ma la th Ion
Phorate
Parathlons
Carbaryl
A1
-------
The producers of the persistent chlorinated hydrocarbons use an evapora-
tive basin in part* for DDT, an evaporative basin for aldrin and dieidrin,
and deep well disposal for chlordane. Therefore, these plants have no dis-
charges subject to the 1899 Act. The evaporative basins require a word of
further comment--evaporative and wind blown losses from these facilities re-
quire evaluation and the long-term future of the basin should be considered,
e.g., what happens if the production site is closed 25 years from now and con-
verted to other uses?
Deep well disposal is used by several pesticide producers in states
where that practice is permitted, and deep sea disposal is practiced by a
number of producers in the eastern seaboard area.
The air pollution aspects of pesticide production are essentially with-
out quantitative data. A small amount of information on levels of certain pes-
ticides in ambient air samples has been reported, but almost no emissions data
on specific pesticides from a given plant have been published. These data are
much needed.
A number of minor sources of pesticide losses were noted during the in-
terviews. One receiving the attention of a few companies is the small amount
which collects on workers' clothing, wipe cloths, etc. Good data on losses
on shoes, etc., are simply unavailable, although one company noted that they
had reduced miscellaneous losses from 150 to 2 Ib/day by increased attention
to small details. Some -companies furnish all production workers with clothing
which is then collected and washed or prewashed in a company-run laundry from
which the wastewater goes to detoxification treatment* On the other hand,
some pesticide producers utilize commercial laundries which may wash the com-
pany's materials separately from all others, but do not use any special de-
toxification treatment. The use of disposable clothing and cloths also requires
special attention to see that these materials are incinerated rather than go-
ing to a landfill if the contaminant is a persistent pesticide.
Another potential pollution source is contaminated solvents which might
be sent to a solvent reclamation service. None of the major manufacturers
appear to do this but small producers or femulators may (particularly with
solvents used for cleanup purposes). The pesticide content of the solvents
may be concentrated in still bottoms or on filter media which are not de-
toxified.
For some plants, the pollution caused by loss of active ingredients is
apparently less significant than that caused by unrecovered by-products such
DDT-containing liquids to go to an approved county Class 1 dump.
B-16
-------
as l^S, which is flared to S02, or particulates from fuel combustion* A
plant which produces 10 million pounds per year of most thioorganophosphates
could emit over 2 million pounds of S02» which would compare with that emitted
from a small electric power plant. Depending on the fuel used for process heat
and the air pollution controls installed, such a plant might also produce 5 to
10 million pounds per year of particulate pollutants (fly ash, etc.). By com-
parison, the amount of active ingredient discharged through the waste treat-
ment plant would probably be less than 10,000 Ib/year.
The by-product which is common to many pesticide production processes
(including chlorinated hydrocarbons, organophosphates, triazines, carbamates,
captan, and others) is salt. A large production plant may generate several
million pounds per year of salt which with few exceptions is not recovered
and is discharged to the river or through waste treatment plants. The effects
of these discharges are probably small, but may require further evaluation.
Cleanup and Decontamination of Equipment
Equipment cleanup is an integral part of pesticide manufacture. This
operation is both time consuming and expensive, and therefore, is kept to an
absolute minimum. Equipment cleanup is generally required for one of two rea-
sons: (a) for equipment maintenance or (b) for quality control purposes.
Repair and preventive maintenance of production equipment is a continuing
process not only because -of the types of equipment used, but also in many
cases because of the age of the production facility. Corporate philosophy on
maintenance varies from scheduled shutdowns of the complete production unit
to only unscheduled shutdowns of specific items of equipment for needed re-
pair. Generally, continuous processes require a scheduled shutdown whereas
batch operation can be maintained on a less rigid schedule. In either case,
the equipment must be emptied of toxic material before it cau be opened for
inspection or repair.
Quality control necessitates the cleanup of production equipment when
the same facility is used for production of different active ingredients to
prevent possible cross-contamination. Production scheduling that minimizes
the number of product changes is used to reduce this type of cleanup as much
as possible. Product changeover usually involves cleanup of only that portion
of the process that would contain potential contaminants. Cleanout procedures
generally involve flushing the production system with a solvent or in some
cases with steam. Wastes from these cleaning operations normally go into the
plant's process/waste system.
The pollution potential associated with equipment decontamination and
cleanup is not particularly significant. First of all, only a small quantity
of active material is involved in this operation, much less than 1% of the
equipment capacity. Of more importance is the fact that wastes generated by
B-17
-------
equipment cleanup in most cases go to the plant waste treatment system or in
some cases can be recycled to the production unit. Thus, the pollution that
could result from discharge of these wastes is primarily dependent on the ef-
ficiency of the waste handling system.
Safety Practices
Safety practices in the pesticide production industry are designed for
both the protection of the workers and the containment of highly toxic or
dangerous chemicals. The degree and sophistication to which safety measures
are used are primarily dependent on the hazard involved.
Two types of pesticides require special environmental control: (a) the
organophosphates and N-alkyl carbamate because of their anticholinesterase
activity, and (b) the chlorinated hydrocarbons and inorganics such as mercury
because of their stability and persistence. Effects from these, as well as
other toxic pesticides, may be produced by swallowing, breathing or absorp-
tion through the skin. Personnel protection measures and devices are designed
to minimize exposure.
Coveralls, boots, gloves, goggles, and a variety of respiratory de-
vices are used to protect production workers* In addition, exhaust ventila-
tion systems are used where there is a potential for atmospheric vapor,
spray or dust containing active ingredients for a hazardous raw material or
intermediate. These devices seem to protect personnel from respiratory and
dermal routes of intoxication* Protection against ingestion of toxic mate-
rials is dependent on demanding high standards of personal hygiene of the
individual worker.
The facility for manufacturing aldicarb, one of the most toxic pesticides
made in the United States, utilizes highly refined precautions, including air
suits for maintenance and decontamination and glove-cabinets at toxic sample
points. Respirators are issued to all personnel who come on the plant site.
Less toxic pesticides, such as carbaryl, only require the use of standard per-
sonnel safety equipment.
The containment practices and equipment used are also commensurate with
the hazard involved. Fire, explosion, and toxicity risks are considered. Con-
trol devices commonly used for containment include diking the production area,
vacuum operation of process vessels, and caustic scrubbing of process vents.
Medical facilities are a part of the overall safety program found at pes-
ticide plants. Both preventive medicine and first aid services are provided.
Typical medical services include a periodic physical examination, first aid
for minor cuts or burns, and periodic cholinesterase tests for employees
potentially exposed to anticholinesterase pesticides (organophosphates and
carbamates).
B-18
-------
The potential for environmental damage resulting from inadequate safety
equipment and procedures apparently does exist for some facilities. Better
contingency plans specifically designed to handle emergency situations—fires,
explosions or vandalism--are needed for some pesticide production plants.
GENERAL CONCLUSIONS
The major pesticide producers have, on the whole, extensive wastewater
treatment facilities. Many of these are new or newly modified and many are
under construction or in design, but some still have little or no effective
treatment procedures at some facilities. The disposal of liquid wastes from
pesticide manufacture varies widely with different companies, different prod-
ucts, and different geographical locations. Methods being used include: many
varieties of neutralization, oxidation, settling, and holding ponds and also
secondary and biological waste treatment plants (all of which are followed
by discharge to a stream or lake); evaporation basins (which have no outfall);
deep well disposal; deep ocean disposal; and incineration. Unfortunately,
data on the discharge of effluents to navigable waters are only beginning to
be made available under the "1899 Refuse Act" for disposal of materials into
navigable waters. Pesticide producers were scheduled to submit discharge data
to the Corps of Engineers at a time when this study was nearing completion,
and very few data were available in time to be evaluated. Preliminary review,
however, indicates that production processes as presently employed for several
product lines do lead to sizable losses of active ingredient, toxic raw mate-
rials, by-products, etc., and that these are often not detoxified by the waste
treatment facilities, e.g., discharges of active ingredients range from a few
pounds per day to over 1,000 Ib/day for some products. These data clearly show
the need for a systematic study of the scope and effects of these discharges
for all producers. On the other hand, four of the major persistent chlorinated
hydrocarbon insecticides are now produced in facilities which do not discharge
liquid wastes to a river, i.e., they are using evaporative basins, deep well,
etc. The evaporative basins pose two problems on which we recommend receive
further study: (a) what are the long-term losses of persistent pesticides by
evaporation and wind? and (b) what is the disposition of the slowly accumulating
sediment or sludge (which is probably highly contaminated with pesticides) in
the event of periodic cleanout over the years or in the event that the pesti-
cide production is discontinued and the area used for other purposes? In the
case of one major chlorinated hydrocarbon, toxaphene, better analytical tech-
niques are needed to establish whether it is persistent because wastes from
this production plant are discharged.
The production processes have numerous potential sources of pollution in
addition to the primary liquid waste streams, including air emissions, solid
wastes, and miscellaneous liquid wastes. The major producers appear to be
cognizant of these sources and exercise controls to satisfy local requirements.
B-19
-------
In a number of cases, solid or liquid wastes containing active ingredients
go to approved landfills or other burial sites without detoxification, e.g.,
a liquid waste which apparently contains DDT goes to an approved Class 1
dump in California. At a few facilities high efficiency incinerators are used
to dispose of such wastes and we recommend this practice.
Data on air emissions of pesticides are not yet available from production
plants and are much in need. The major producers have expended much effort
to install baghouses, scrubbers, and other air pollution controls, but data
on loss of active ingredients through these devices are needed.
Some of the biggest sources of pollution from the major manufacturers
are not from the active ingredient (i.e., the pesticide) but from unre-
covered by-products such as I^S (which may be flared to S02). Particulate
or gaseous pollutants from incomplete combustion of fossil fuel may be bigger
sources of pollution than loss of active ingredient for some plants.
Nearly all of the basic facilities and equipment now in use for pesti-
cide manufacture and formulation were designed and built prior to the present
age of intense concern about environmental quality. Even in the case of one
large completely new facility additional pollution control procedures and sys-
tems had to be added on after the basic plant was designed in an attempt to
meet new and higher standards. This situation is not unique to the pesticide
industry, but prevails with most manufacturing facilities and processes cur-
rently in use. However, this problem is of special importance in the pesticide
industry because this industry produces biologically active chemicals which
are apt to have higher potential for causing environmental damage than do the
effluents discharged from most manufacturing processes.
Numerous examples were noted wherein companies have recently modified
their production and waste disposal facilities to decrease the amounts of
wastes generated or lost, e.g., improved recycle, recovery, and decontamination
of by-products, use of lined settling basins to avoid seepage, etc.
Most of the production equipment is dedicated to one product or to two
very similar products so that cleaning wastes are minimal.
A host of smaller potential pollution sources were noted, some of which
have received attention by some producers, but not by others. Garryout of
pesticides on shoes and clothes is prevented by sending company provided work-
wear along with wipe cloths, etc., to special laundries, followed by recycle
or detoxification of the wash liquid. Wash basin or lavatory washwater is sent
to the waste treatment plant rather than discharged with sanitary wastes, and
the proper disposal of "bottoms" from solvent recovery operations.
B-20
-------
The formulation of pesticides is probably a larger source of environmental
pollution than is the initial production. The formulation is done in some cases
by the manufacturer at the production site, but in most cases, it is not.
Formulators process hundreds of pesticides into thousands of finished products.
By the nature of this arrangement many of the formulators have relatively
small facilities, and many of the formulation runs are relatively short. The
combined result is that formulators with few exceptions have less extensive
waste treatment facilities than do the manufacturers, but they generate con-
siderably more wastes from equipment cleanup. However, the majority of the
formulators probably send liquid wastes to municipal sewer systems so that no
data are available on the amounts discharged. These smaller businesses are
also more apt to send pesticide containing solvents to commercial solvent recla-
mation services (where the fate of the pesticide is uncertain) than is the
manufacturer.
One problem faced by pesticide formulators wishing to improve their pol-
lution abatement systems and procedures is the lack of authoritative, practi-
cal information on how to accomplish this. Several formulating companies whom
we interviewed expressed disappointment and dissatisfaction with engineering
firms to whom they had turned for help in developing practical systems and
procedures which would meet the environmental quality standards set by local,
state and/or federal regulatory and enforcement agencies.
A closely related problem is that of dealing with catastrophes. While
most basic pesticide manufacturers (especially those where the pesticide produc-
tion is integrated into a larger chemical manufacturing complex) have emergency
procedures, contingency plans on how to handle emergencies such as fires, ex-
plosions, floods, etc., were inadequate or absent in most independent pesticide
formulating plants and also in many public warehouses which handle concentrated
pesticides. Recent history indicates, however, that emergencies in which large
quantities of toxic materials are suddenly released into the environment can
and do occur.
We therefore conclude that there is an urgent need for the development
of principles and procedures by which pesticide formulating and warehousing
enterprises can minimize or completely eliminate the release of toxic chemi-
cals into the environment, especially into waterways. Such information is
needed (a) for their normal operations, and (b) for emergencies. We recommend
that steps be taken early to develop this type of information and furnish it
to the pesticide formulating industry and to those involved in warehousing
large quantities of pesticides.
The transportation of pesticides, as with many other products, causes
increased chances of accidental breakage, spills, and losses. The potential
is probably higher in the case of the concentrated active ingredient than it
B-21
-------
is with more dilute formulated products, but varies with the packaging and
shipping practices. Overall, the pesticide industry has had relatively few
major spills, but the potential remains inherent in the transportation of
hazardous materials*
Of smaller scope, but of importance we believe, is the increased pollution
potential of tank trucks over railroad tank cars in regard to cleanout proc-
dures. Cars are frequently dedicated, require only occasional cleanout, and
this is done at the manufacturer's site with wastes going to treatment. The
trucks are most often leased one way and are cleaned by the operator at a
point remote from detoxification facilities*
Another important pollution point related to the need to transport pes-
ticides is the inability to empty the standard 5- and 55-gal. metal drums com-
pletely. These drums may often be reused for formulated products, etc., and
losses at the manufacturer/formulator/packager level are not nearly so large
as those at the consumer level, but new designs are needed which permit com-
plete drainage.
The warehousing of finished pesticidal products and the marketing of pes-
ticides are smaller sources of pollution, but losses in this area are frequently
disposed to the nearest sewer or trash can.
Overall, the environmental impacts from pesticide manufacturing/formulat-
ing/packaging/marketing activities appear to be small compared to those result-
ing from consumer use of these products, but those negative impacts of the
former activities have zero benefit/cost ratios and should be minimized. On
the other hand, the costs of reducing all pollutants to zero are very large.
Regulations and legislation in this area must consider that unrealistic stan-
dards will drive many small producers from the industry and preclude the entry
of others who would previously have entered. The large producers, who generally
already have a very large investment in pollution control equipment, will be
best able to meet the most stringent control regulations and will probably do
so (with added costs passed on to the buyer) if the product involved is much
in demand by the public.
B-22
-------
APPENDIX C
PESTICIDE TQXICITY DATA
C-l
-------
Appendix C lists acute oral, dermal, and inhalation toxicities
of pesticides on test subjects together with additional pertinent informa-
tion, e.g., U.S. Occupational Standards. In general the toxicity data refer
to rats but references to other species including humans are also given.
The compilation of common and chemical names of pesticides is
taken from Caswelll/ and the corresponding toxicity data are taken from the
2/
NIOSH Registry of Toxic Effects of Chemical Substances.- In particular,
the appendix connects the Caswell Accession Number for a pesticide to the
NIOSH Registry Number (Cross-Reference Number). This permits ready access
to toxicity data for a given pesticide listed by Caswell and provides the
opportunity for immediate confirmation and source identification from the
NIOSH Registry.
In some cases pesticide toxicity data are not indicated in the
NIOSH Registry. This does not mean that a substance is not toxic but rather
the Registry selection has primarily been made on the basis of a lethal
single dose, represented by a 11)50* LC5Q or similar data types. In these
cases the pesticide toxicity manufacturers' technical data sheets should be
consulted.
The appendix also indicates those pesticides which are suspected
chemical carcinogens or which cause neoplastic (tumor) toxic effects. Those
pesticides which are known or suspected carcinogens or having neoplastic
3/
effects are also given in the NIOSH Suspected Carcinogens Subfile.-' The
NIOSH Registry numbers in the subfile are identical to those in the NIOSH
Registry.
C-2
-------
Various abbreviations appear in the NIOSH Registry and have been
utilized in preparing Appendix C. A complete listing of abbreviations
follows:
BDW - Wild bird species
CL - Ceiling concentration
CAR - Carcinogenic effects
CAT - Cat
CKN - Chicken
D - Day
DOG - Dog
fb - Fibers
gm - Gram
GPG - Guinea pig
H - Hour
HAM - Hamster
HMN - Human
IHL - Inhalation
IMP - Implant
IMS - Intramuscular
IPL - Intrapleural
IPR - Intraperitoneal
ITR - Intratracheal
IVN - Intravenous
C-3
-------
IVG - Intravaginal
Kg - Kilogram
LC50 - Lethal concentration 507. kill
LCLo - Lowest published lethal concentration
LD50 - Lethal dose 507. kill
LDLo - Lowest published lethal dose
MAM - Mammal (species unspecified)
MAN - Man
M - Minute
m3 . Cubic meter
ml - Milliliter
mg - Milligram
MUS - Mouse
NEO - Neoplastic effects
ORL - Oral
PAR - Parenteral
ppb - Parts per billion (v/v)
ppm - Parts per million (V/V)
RAT - Rat
RBT - Rabbit
SOU - Subcutaneous
SKIN - Skin effects
SKN - Skin
C-A
-------
TCLo - Lowest published toxic concentration
TDLo - Lowest published toxic dose
TLjj, 96 -Aquatic lethal concentration 50% kill, 96 hr
TLV - Threshold limit value
TRK - Turkey
TWA - Time weighted average
Ug - Microgram
UNK - Unreported
USOS - U.S. Occupational Health Standard
W - Week
WMN - Woman
Y - Year
C-5
-------
REFERENCES
1. Caswell, R. L., M. L. Alexander, H. Boyd, Acceptable Common Names and
Chemical Names for the Ingredient Statement on Pesticide Labels,
3rd Edition, Environmental Protection Agency, Office of Pesticide
Programs, Washington, D.C., December 1975.
2. Registry of Toxic Effects of Chemical Substances, H. E. Christensen,
ed., T. T. Luginbuyhl, ed., U.S. Department of Health, Education, and
Welfare, Public Health Service, National Institute for Occupational
Safety and Health, Rockville, Maryland, June 1975.
3. Suspected Carcinogens, A Subfile of the NIOSH Toxic Substances List,
H. E. Christensen, ed., T. T. Luginbyhl, ed., U.S. Department of
Health, Education, and Welfare, Public Health Service National
Institute for Occupational Safety and Health, Rockville, Maryland,
June 1975.
C-6
-------
NIOSH-Toxic
Caswell Acute Acute
Accession Suspected Oral-LD50 Dennal-LD50 Inhalation-LD50
No Carcinogen (mg/kg) (mg/kg) (ma/kg)
1
2
2A - 866
3 - 3,310
3A - 1,780 - LDLQ
1,000 ppm/4H
o
i
VJ
3B
4 - 5,300 RBT
4A - 900
5
5A - 400 MAM
6
7
8 - TDLQ 50 MUS 14
Substances List
Cross-Reference
Other No.
-
— —
TB47600
USOS-Air AF12250
TWA 10 ppm
USOS-Air AK19250
TWA 5 ppm
USOS-Air AF31500
TWA 1,000 ppm
GN48300
-
GN48600
^
~ ""
AR96250
SCU-MUS
-------
Caswel1 Acute Acute
Accession Suspected Oral-LD5Q Dennal-LD50
No. Carcinogen (mg/kg) (mg/kg)
9 - 46 562 RBT
10 - 93 280 RBT
11 - 1,200
1UA - 6,300 RBT 8,285 MUS
Cj
oo
11A - i 25
12 NEO 67 98
12A
13 - 500
13B
14
15
Inhalation-LD50
(mg/kft) Other
LCLo USOS-Air
8 ppm/4H TWA 0.1 ppm
LCLq USOS-Air
500 ppm/4H TWA 20 ppm
(skin)
~
USOS-Air
1,000 ppm
™
USOS-Air
TWA 0.25 mg/
(skin)
— _
™
LDL0 200 mg/kg
UNK-MUS
_
NIOSH-Toxic
Substances List
Cross -Reference
M^>
NO .
AS10500
ATS 25 00
AE12250
KQ63000
UE22750
1021000
m3
BO 25000
RG43750
-------
NICSH-Toxic
o
I
Caswell
Accession
No.
16C
16V
17
18A
18H
18K
19AA
20
21
22
23 E
24
25
26
Acute Acute
Suspected Oral-LD5Q Dermal-LD50 Inhalation-LD50
Carcinogen (mg/kg) (mg/kg) (mg/kg) Other
400 - -
4,000 - - -
-
730 - -
730 - -
500 - -
300 - -
_
_ ~
230 -
410 125 -
SCU-RBT
_
LDLQ 680 -
LDLQ 69 LDLQ 53 LC50 1" ppm/4H USOS-Air
(skin)
Substances List
Cross-Reference
No.
B031500
B070000
-
B032000
BP64800
BQ54250
B033250
~
-
NX52500
BQ78750
-
GZ19250
BA50750
-------
o
I
Caswe11 Acute Acute
Accession Suspected Oral-LD50 Dennal-LD50
No. Carcinogen (mg/kg) (mg/kg)
27 - 148
27A - -
28 - A
o _
28A
29 - 3,700
29A
30 -..
31 -..
31A
32 - 1,100
33 - 600
33A - - 50
SCU-MUS
33B - 2,850 MIS
*L — - — - . wj.usn-j.oxic
Substances Lis
Inhalation- LD5Q Cross-Referenc
(rag /kg) Other No
NX82250
.
USOS-Air YT92750
TWA 0.5 mg/m3
— _
BD05250
— _
~ — —
LCLQ 1 ppm - BD14000
270 BD17000
IPR-MUS
XY91000
TE15750
AR73000
DG14000
-------
Caswell
Accession
Mr>
no«
33C
33E
36
37
37A
38
40
41
Acute
Suspected Oral-LD50
Carcinogen (rag /kg)
2,200
1,210
IVN-MUS
-
10
21
NEO 1,100
CAR
350
Toxicity Data
Acute
Dermal-LD50 Inhalation-LD50
(rag/kg) (rag/kg)
_
_
_
.
48
5
SCU-MUS
TDLQ 54
SCU
LCLQ
2,000 ppm/4H
NlUotl- M.OXIC
Substances List
Cross-Reference
Other No.
-
XZ29900
TY29000
-
TA14000
US17500
TLD0 113 g/kg XZ38500
ORL-MIJS
USOS-Air B008750
TWA 50 ppm
41A
41B
41C
42
LD5Q 96 mg/kg
IVN-MUS
BP19250
-------
o
I
Caswell Acute Acute
Accession Suspected Oral-LD5Q Dermal-ID Inhalation-LD,n
No. Carcinogen (mg/kg) (mg/ke)5° (mg/kj>) nth**
43 - LDL0 100 -
44 - 350
44A
44AB -
44B
44C
45 - - . _
45A
45B
45C
46
47 - L600 - - USOS-Air
TWA 15 mg/m3
48 - 58
48A
IIJAJOII— J-UAJ-i-
Substances List
Cross-Re ference
No.
GQ94500
BQ96250
-
—
^
BR90500
-
_
_
_
-
W061250
BS45000
-------
o
!-•
LO
Caswell
Accession
No.
49
49A
49 B
50
50A
SOB
51
51A
51B
51C
Acute
Suspected Oral-LD5Q
Carcinogen (mR/kg)
7,400 RBT
-
3,080
_
-
LDLQ 10
_
2,090
440
Toxicity Data
Acute
Dermal-LD50 Inhalation-LD50
(mg/kg) (rag /kg)
_
LCL0
5,200 ppm
LCLQ
2,000 ppm/4H
2,000 RBT
_
_
_
-
-
1,400 LCL0
250 ppm/4H
Other
MW»<^W
USOS -Air
TWA 100 ppn
-
-
—
—
—
—
-
USOS-Air
TWA 5 ppm
(skin)
51D
52
NIOSH-Toxic
Substances List
Cross-Reference
No.
AJ19250
SA31500
SM68250
BV43750
BZ89250
BW66500
NEO
TDL0 3,300
SCU
CA93500
-------
o
I
Caswell
Accession
No.
52A
52B
53
54
55
— — — — — _ ____
Acute
Suspected Oral-LD50
Carcinogen (mg/ke )
NEO TDL0 90
LDL0 30
115
-
••.v-**..*. *•.!.)
Acute
Derma 1-LD5Q
(mg/ke)
-
21
SCU-MIJS
55
SCU-MUS
LVijaca
Inhalation-LD50
(me/ke^
56
57
58
59
8
20
LDLQ 15
SCU
Other
USOS-Air
TWA
0.5 rag (Sb)/m3
USOS-Air
TWA 500 ppm
USOS-Air
TWA
500 ug (As)/m3
USOS-Air
TWA
500 jig (As)/m3
USOS-Air
TWA
0.5 mg (As)/m3
NIOSH-Toxic
Substances List
Cross-Reference
No_.
CB47250
CD03500
CC68250
SE75250
CG07000
CG22750
CG33250
-------
NIOSH-Toxic
Caswell
Accession
No.
60
Suspected
Carcinogen
Acute
Oral-LD50
(ing/kg)
Acute
Dermal-LDijQ
(rag/kg)
-
Inhalation-LD5o
(rag/kg)
800 ug/kg
IVN-RBT
Substances List
Cross-Reference
Other No.
CH81000
60A
61
61A
62
62A
62B
63
63A
63B
64
CAR
CAR
NEO
20
1,750
TDL0 37 g/kg
1,800 RBT
1,000
LDLQ 15
SCU
TDL0 2,625
TDLQ 17 g/kg
SCU
12 mg/m3 NIOSH Rec'd STD
TWA 2fb/ml
LDsn 5,000 rag/kg
UNK-MUS
CG33250
CI6A750
CI99000
FD11900
XY56000
BY35000
XY32800
CN14000
65
-------
o
I
(-•
o\
Toxic ity Data
Casvell Acute Acute
Accession Suspected Oral-LD50 Dertnal-LD50 Inhalation- LDSO
No. Carcinogen (mg/kK) (mE/ke) Ong/ke)
66 ...
66A - 25 MUS LDL 1,300
SCU-MUS
66B
68 •- 600
69 - LDLQ 630 -
70 175
71
71AA - 950 UNK
71A
72
73
Other
73A
74
75A
LDLQ 200 mg/kg
ORL-HMN
NIOSH-Toxic
Substances List
Cross-Reference
No.
CP01750
FD77000
CQ86000
CR05250
GZ15000
GL88300
100 BWD
DD64750
-------
NIOSH-Toxic
r>
i
Caswell
Accession
Nr»
ril) «
75BA
75C
75D
76
77
78
79
79AA
79A
80
81
SLA
Acute
Suspected Oral-LD50
r.arcinogen (nig/kg)
1 , 100
_
-
1,300
CAR 3,800
CAR 88
CAR 500
_
-
56 BDW
3,040
NED 13°
Acute
Dermal-LD50 Inhalation-LD50
(mg/kg) (rag/kg)
2,500
_ -
-
LDLQ 5,000
TDL0 1,232 LC50
MUS 10,000 ppm/7H
500
_
_ —
-
-
_
TDLQ-2,000
MUS
Substances List
Cross-Reference
Other No.
DK99000
"
"• ~
CU43750
USOS-Air CY14000
TWA 10 ppm
USOS-Air GV49000
500 ug/m
(skin)
GV35000
™ *
DG24500
DG08750
USOS-Air DK26250
TWA 0.1 ppm
-------
o
I
CD
Caswell Acute Acute
Accession Suspected Oral-LD Dennal-LD50 Inhalation-LD^
No. Carcinogen (mg/kgl (mg/kK) fme/kfi) other
8UB 100
81B
81C - 1,280 -
81D - 70
81E
81EA -..
81F * L230 - 1,000 ppm/8H
82 - 1,700 ...
82A
83 - 1,700
83A
83B
83BB -
«3C - 400 - -
NIOSH- Toxic
Substances List
Cross-Reference
DH61250
DL58600
FB47250
DN31500
DG42000
G071750
•**^ f\ m ^ *»^*
B031500
-------
NIOSH-Toxic
o
i
Ca swell
Accession
Mrv
IMU .
83D
83E
84
85
85A
86
87
V f
87A
88
88A
89
89A
91
91A
Acute
Suspected Oral-LD5Q
Carcinogen (nog /kg)
100
1,500
90
500
-
58
3,280
-
_
-
2,500
-
-
4
Acute Substances List
Denaal-LD,0 Inhalation-LD50 Cross-Re ference
(mg/kg)
-------
n
i
Caswell
Accession Suspected
No. Carcinogen
91B
92
92A
93
93A
94
94AA
94A
94B
95
95A
98
98A
98B -
Acute
Gng/kg)
-
-
475
575
265
-
345
535
1,830
-
-
1,400
-
Acute Substances List
Dermal-LD50 Inhalation-LD50 Cross-Reference
(mg/kg) (rag/kg) Other No
•• —
IN36750
100 ' - DC84000
480 - - J010500
_
UU25920
XY38500
XY40250
USOS-Air TI03500
TWA 5 mg/m3
- - _ _
XY43950
"• •• —
-------
NIOSH- Toxic
Caswell Acute Acute
Accession Suspected Oral-LD50 Dermal-LD50 lnhalation-LD50
No Carcinogen (rag/kg) (rap/kg) (ms/kg)
99
99A
100 - • ~
101 - 194 LDLQ 1,170 RBT
102
102A -
i
N)
M 102B
102C -
103
104
105 - ""
106
106A -
107 - ^ 80°
Substances List
Cross-Reference
Other No.
_
™
•• ™
JN87500
™
*
^ , .
CI99000
"
ED07800
-------
o
I
Caswell
Accession
No.
108
109
111
111A
112
112A
113
114
114A
114C
114D
114E
115
Acute Acute
Suspected Oral-LD50 Dermal-LD
Carcinogen (rag/kg) dug/kg)
2,660
2,660 1,740
SCU-MUS
3,400
~
"
100 MUS
-
664 813 RBT
~
-
200 1,000
1,600 720 RBT
_ _
* IMlllXH-rnvIr
Substances List
Inhalation-LD50 Cross-Reference
(me /kg) other Nn
VZ22750
ED45500
YQ92750
—
LCLQ RBT USOS-Air EF91000
180 ppm/7H TWA 0.1 ppm
AF59500
_
UA74000
_
TE70000
TE71750
-------
Toxic ity Data
Caswell Acute Acute
Accession Suspected Oral-LD50 Dermal-LD50 Inhalation-LD50
/ l\ \ fjn& /\C & i t flM? / KK )
No Carcinogen ^rag/Kg; \.u'R/r-6/ — »-» — «"-
116 - 12>500
116A -
116B -
116C - 5'000
118 - ""
119 . 190 -
119A -
17n - 400 RBT
119AB - 17°
119B
119BA -
119C - LDLo
Other
USOS-A
TWA 150
NIOSH-Toxic
Substances List
Cross-Reference
No_.
RB80500
DD21000
DI31500
FC35100
E017500
6,000 RBT
119 D
120
-------
Caswell
Accession
No.
121
121AA
12 1A
121B
121C
i
N>
^ 122
123
123A
124
124A
Toxicity Data Niosh- Toxic
Acute Acute Substances List
Suspected Oral-LD Dermal-LD50 Inhalation-LD50 Cross- Reference
Carcinogen (mg/kg) (mg/kg) (mg/kK) other NO
1,480 560 RBT LCLQ USOS-Air KJ85750
500 ppm/4H TWA 50 ppm
(skin)
~
~ — — — — —
90 25° - - XK84000
-
~
-
-
800 MUS - - . AD98000
3,500 - - USOS-Air BnlQ3"in
125
125A
125CA
TWA 100 ppm
380
483
B033250
XY50200
-------
NIOSH-Toxic
Caswell
Accession
No
I.YV •
126
127A
127AB
128
128A
o 128B
i
to
01 128BB
128EA
128EB
128F
128FA
128G
128H
Acute Acute
Suspected Oral-LD50 Dennal-LD50 Inhalation-LD5Q
Carcinogen (mg/kg) (mg/kg) (mg/kg)
820 -
-
5,400 RBT
2,350
_
.. •" ~
.
_
50 LDL0 1,500
_
_
4,000
Substances List
Cross- Reference.
Other No .
-
TB49000
-
UP70000
UW60250
™
~ ™
-
FF91000
• ~
— ~
UV73500
1281
-------
o
I
o*
Caswell
Accession
No.
129
130
130AA
130A
130B
130D
130E
130F
130G
131
131A
132
133
133A
CAR
790
5,000 MUS
406
3»250
3,900
1,100
1,350
2,600
790
500 ppm/4H
2,520 RBT
NIOSH-Toxic
Substances List
Cross-Reference
No.
XU45500
DH19800
EQ49000
SJ89250
WT29750
ET01750
CH75250
CH77000
-------
0
1
•13
Caswell Acute
Accession Suspected Oral-LD5Q
No. Carcinogen (mg/kg)
134
134A
135 NEO 88
136
136AA CAR 72
136A
136B - 66°
136C CAR
Toxic ity Data
Acute
Dermal-LD50 Inhalation- LD5Q
(rag /kg) (mR/kg)
_
-
TDL0 5
scu
_
TDLQ 90
SCU
-
TDL0 2
SCU
Other
-
-
-
USOS-Air
TWA 0.1 m
-
-
136D
137
NEO
30
LDL0 15 tog/kg
HMN
USOS-Air
TWA 1 mg/m3
NIOSH-Toxic
Substances List
Cross-Reference
No.
EV01750
EV19250
WM56000
EV27000
PA17500
CG08300
138
139
EV95800
-------
Caswell Acute ZcTite ~
Accession ^^ ^^O Der*al-LD50 Inhalation-LD50
!39A - LDLQ 4,500
139B - 1,000
140 - 1,400 RBT
141
142 - 39 -
o W3
i - -
N>
°° 144
"
145 - ._
"" —
145A -
146 .__
146A -
147
147A
NIOSH- Toxic
Substances List
Cross-Reference
Mrt.
No .
FN98000
EV98000
6S60000
EW07000
-
EW28000
NH34850
USOS-Air
TWA 5 mg/m3
EW31000
148
-------
NIOSH- Toxic
o
NJ
vO
Caswell
Accession
Mr>
nw •
149
150
151
152
153
154
155
156
/
156A
157
Acute Acute
Suspected Oral-LD50 Dermal-LD50 Inhalation-LD50
Carcinogen (mg/kg) (mg/kg) (rag/kg)
355
_
-
_
LDL0 344 -
IVN
210 - -
LDLQ 900
IPR
LDL0 2,000
RBT
_
CAR - TDLQ 25
MUS
Substances List
Cross-Reference;
Other No.
TX28000
™
— ""
EW41500
XN64300
OV87500
USOS-Air EX12250
TWA 2 ppm
EX14900
"
RN85750
158
LDLQ 1.6 mg/kg
IVN-CAT
RA85250
158A
2,500
GW49000
-------
Toxicity Data
^aswen
Accession Suspected
159
160 CAR
160AA
160A
o
J> 160B
o
Acute Acute
Oral-LDjQ Derroal-LD50
480
89
1,200 MUS
5 120
4 4
" _
Inhalation-LDcQ
(me/ke) ru-hor-
TLV
TWA 5 mg/m3
USOS-Air
TWA 5 mg/m3
—
LD50 85 mg/m3 TLV
TWA 50 ug/m3
T f\ __ _ 1/1 *>«WX*« / 1 ¥» »» *M XV A •
NIOSH- Toxic
Substances List
Cross -Reference
No.
GW50750
FC59500
FD05250
FB94500
161
161A
162
164
TDL0 6
LDLo 300
SCU-RBT
v *-r*~r i^ *fc*»fc
TWA 400 jjg/m3
USOS-Air
TWA 4 mg/m3
LD50 440
IVN-MUS
USOS-Air
TWA 5,000 ppm
USOS-Air
20 ppm
1'77°
4,000 ppm/4H
USOS-Air
TWA 10 ppm
GQ52500
FF52500
FF64000
FF66500
FG49000
-------
o
I
Caswell
Accession
No.
165
165A
165AB
165B
165C
165D
165E
165F
166
166A
167
Toxicity Data
Acute Acute
Suspected Oral-LD50 Dermal-LD50 Inhalation- LD50
Carcinogen (wg/kg) (mg/kg) (mg/kg)
10 27
3,200
-
-
-
LD50 2,600
SKN-RBT
500
-
-
200 250 SCU
410 125
SCU-RBT
Other
-
-
-
-
-
-
"
-
-
-
167A
168
168A
NED
285
3,500
620 SCU
N10SH-Toxic
Substances List
Cross-Reference
No.
TD52500
RP45500
FI41000
MM02250
BQ54250
UU49000
BQ78750
FM87500
DG19250
-------
Ca swell
Accession
No.
169
170
171
172
o
i - 173A
to
174
174A
174B
175
176
177A
Acute Acute
Suspected Oral-LD Dennal-LD^ Inhalation-LD^
Carcinogen (mg/ke) (rag/kg ) fmef/\rn\
•* _ _
~ _ _
4,000
1,950
2,000
4,287
283 700
250
295
140 2,100 RBT LC
1,000 ppm/4H
LDLQ 2,150
^
Other
LDL0 500 mg/kg
IPR
USOS-Air
TWA 0.5 mg/m3
(skin)
NIOSH-Toxic
Substances List
Gross-Reference:
No.
DK68250
XY50750
WQ29750
YS28000
PB98000
LQ43750
LQ45500
TX98000
XB26250
-------
o
I
CO
Caswell
Accession
No.
179
179A
179B
179C
179 D
180
181
182
, _-
182A
182B
183
183A
Acute
Suspected Oral-LD^Q
Carcinogen (rag /kg)
-
-
76
-
-
850
500
300
.
-
-
-
2,910
Toxicity Data NIOSH- Toxic
Acute Substances List
Dennal-LD50 Inhalation-LD5Q Cross-Reference
(rag/kg) (rag/kg) Other No.
LC50 USOS-Air F021000
293 ppm/lH TWA 1 ppm
LCL0 USOS-Air F026250
500 ppm/15M TWA 0.1 ppm
5 SCU - - AF85750
USOS-Air AM63000
CL 0.05 ppm
-
EZ50750
XX84500
LDLo 36 - - BX07000
RBT
- ~ ~
-
LDL0 4,000 - USOS-Air CZ01750
SCU TWA 75 ppm
-------
I
Co
Caswell
Accession
No.
183AB
183B
183RA
183C
185A
186
186AA
186AB
187
187A
187B
Suspected
Carcinoen
213
RBT
Acute
Oral-LD5o
(mg/k^)
560 MUS
Toxicit
LDL0 420
LDL0 4,000
10
146
Acute
Dennal-LD50 Inhalation-LD50
(me/kg)
400 SCU
850 RBT
30
177
Other
LD
50
UNK
N1OSH- Toxic
Substances List
Cross-Referencei
EZ72600
WQ37400
UC01750
FQ61250
SK36750
KOI1000
TB87500
TE75250
-------
o
I
.en
Gas we 11
Accession
No.
188
188A
188AA
188AC
188C
188D
188E
191
191 A
Toxicity Data
Acute Acute
Suspected Oral-LDcg Dermal-LD50 Inhalation-LD50
Carcinogen (mg/kg) (mg/kg) (mg/kg) Other
1
_ -
4,000 mg/kg
UNK-MAM
_
340
_ .. "*
_
€70 232 RBT
' - • •
CAR
800
704
SCU-MUS
LCL0
8,000 ppm/4H
USOS-Air
TWA 50 ppm
NIOSH-Toxic
Substances List
Cross-Reference!
No.
UV80500
YV60100
UG14900
'BP52500
FS91000
192A
192B
192C
-------
o
I
Caswell
Accession
No.
193
194
194AA
194A
194B
195
195A
195B
195BA
195C
195D
196
196A
197
Suspected
Carcinogen
Acute
Oral-LD5Q
(mg/kg)
1,200
LDLQ 100
1,600
Toxic ity Data
Acute
Derma1-LD50
(mg/kg)
380 RBT
27
Inhalation-LD,
(mg/kg)
'50
Other
NIOSH-Toxic
Substances List
Cross-References
No.
AE15750
OW03500
US57750
TD18600
-------
Toxicity Data
Caswell Acute Acute
Accession Suspected Oral-LD50 Dermal-LD50 Inhalation -LD5Q
No. Carcinogen (mg/kg) (nvg/kg) (mg/kg)
198
198A -
201 - 800 1,500
201 A - 197 362 RBT LC50
1,070 mg/mj
202
202A
203 NEO 670 950 SCU
203A -
204 - 85°
204A -
204B
205A -
206 - *
206AA '
Other
•• i i ii
NIOSH- Toxic
Substances List
Cross-Reference
No.
TE80500
TX52500
SK26250
AGO 1750
-------
o
1
u>
00
Caswell
Accession
No.
206AB
206A
206B
207AA
207A
207 B
207C
207D
207DA
207E
209
209A
210
210A
Acute
Suspected Oral-LD50
Carcinogen (rag /kg)
-
-
1,350
-
94 MUS
» —
126
1,800
178
3,000
-
-
-
.
if — — --— NlUStl- TOXIC
Acute Substances List
Dennal-LD50 Inhalation-LD Cross-Reference
(rag/kK) (me/kK) oth*r
— - —
DB56000
•• — —
920 MUS - - TE82250
^ ^
NY28000
YS64250
USOS-Air 0036750
TWA 0.05 ppm
US64750
^ ^ ^j
-
-
-------
NIOSH-Toxic
Ca swell
Accession
No
L1W •
210B
211
211A
211B
211C
211D
211E
212
212AA
212A
213
213A
Acute Acute
Suspected Oral-LD50 Dennal-LD50
Carcinogen (rag /kg ) (mg/kg)
3,500
-
-
3,500
2 200 RBT
1,400
165 MUS 220 MUS
98 190
_
- •
3,960
_ — ~
Substances List
Inhalation-LD50 Cross-Referencei
(mg/kg) Other No.
DV68250
— — *"
_ — —
DV70000
NK53350
WR57750
TE84000
TD54250
-
LD5Q 3,000 mg/kg IL88420
UNK-MUS
WQ38500
LD50 1,500 mg/kg UM39600
ITVTI/ _MAM
213B
-------
Caswell
Accession
No.
214
214A
214B
215
o 2 ISA
° 215AB
215AC
215B
216
216A
216D
216E
216F
Suspected
Carcinoen
Acute
Oral-LD^Q
(mg/kg)
250
150
1,500
Jfpxicity Data
Acute
Dermal-LD50 Inhalation-LD50
fag/kg) (me/kg)
SCU-MUS
8 RBT
LCL0
125 ppm/4H
Other
USOS-Air
TWA 0.1 ppm
LD5Q 175 mg/kg
ORL-MAM
N10SH-Toxic
Substances List
Cross-Reference
PB63000
TY40250
DD24500
WS28000
XU49000
AB58500
-------
NIOSH- Toxic
Caswell
Accession
No.
217A
217AB
217B
218
219
219A
219AA
219AB
219B
220A
220B
Acute Acute
Suspected Oral-LD50 Dermal-LD50 Inhalation-LD5o
Carcinogen (mg/kg) (mg/kg) (mg/kg)
1,100
_
3,700
-
30 -
-
145 202
941 - -
3,000 LDL0 400
SCU-MUS
-
NEO TDL0 1,000 LDLQ 2,290
Substances List
Cross- Reference!
Other NO.
TB91000
-
YS61250
-
FB68250
FB85750
TF63000
TG07000
QI77500
-
AG29750
221
IMP
SCU-MUS
USOS-Air
CL 100 ug/m3
as CrOo
GB24500
-------
Caswell
Accession
No.
221AA
221A
22UB
221B
221C
223
224
224A
225
226
226A
227
228
229
Acute
Suspected Oral-LD5Q
Carcinogen
2,220
4,960
725
725
3,900
Dermal-LD50 Inhalation-LD50
Other
LD5Q 884 mg/kg
IPR
NlOSH-Toxic
Substances List
Cross-Reference
No.
GZ19250
G064750
RG50750
GE73500
GF86150
GF86150
QK89250
GG83850
710
AG35000
-------
NICSH-Toxic
Caswell Acute
Accession Suspected Oral-LD^Q
No. Carcinogen (rag/kg)
229A - 22
229B
230 LDL0 110
MUS
231
232
£ 233
235
235A
235B
235 BA
235C
236
237 - 590
Acute Substances List
Dermal-LD50 Inhalation-LD5Q Cross-Reference
(mg/kg) (mg/kg) Other No.
GL64750
-
_ QK91000
-
-
CG33850
-
ID 9,400 mg/kg GL70400
IPR-MUS
-
-
_ - ~
-
GL73500
-------
Caswell
Accession
No.
238
239
240
Suspected
Carcinogen
241
a 242
243
244
245
246
247
248
248A
Acute
Oral-LD5Q
(ng/kg)
LDLQ 110
MUS
940
Inhalation-LD
(n«/kg)
50
Other
NIOSH-Toxic
Substances List
Cross-Reference
No.
LD50
2,090 ug (Cu)/kg
IPR-MUS
LDLQ 200 mg/kg
ORL-HMN
USOS-Air
TWA 1 n«/m3
as Cu
AH42800
GL76000
QK91000
GL78750
-------
Caswell Acute
Accession Suspected Oral-LDjQ
No. Carcinogen (rag /kg)
248B - 470
249 - 700
250
251 - 520
252
253 NEO
254
254A
255
255A
256 - 960
258
259
Toxicitv Data "AW" —~
Acute Substances List
Dermal-LD50 Inhalation-LD50 Cross-Reference
(rag/kg) (mg/kg) Other _°_:
GL80500
USOS-Air GL82250
TWA 1 mg/m3
as Cu
-
GL66500
_ —
TDL0 156 - - VC525°°
SCU-MUS
-
-
-
-
GL89000
-
-
-------
o
Caswell
Accession
No.
259A
260
260A
261A
26 1A
26 IB
263
263A
•
Acute
Suspected Oral-LD5Q
Carcinogen (mg/kg )
- -
LDLQ 600
RBT
-
725
242
-
*
1,454
460
mAj.wj.uv uaca
Acute
Dennal-LD50 Inhalation-LD,=ft
f /* \. ' Jv
• mo / \f o i / /* v
lu^j/Kg^l \"*S«kB) Ot"hPT
-
^
~ "•
620 - USOS-Air
TWA 5 ppm
(skin)
-
USOS-Air
TWA 5 ppm
(skin)
TLV-Air
5 mg/m3
NIOSH-Toxic
Substances List
Cross-Reference,
\»_
No.
G057750
GF86150
G061250
G059500
TB38500
264
264A
264B
200
1,000
USOS-Air
TWA 4.6 mg/m3
WA96250
B090000
-------
NIOSH-Toxic
Ca swell
Accession Suspected
No. Carcinogen
264C
264D
265
266
266A
i
-P-
<"1 266B
266C
267
267A
268
268A
268AB
Acute
Oral-LD50
(mg/kg)
940
-
-
470
125
-
-
2
32
995 MUS
79
Acute
Dennal-LDcQ Inhalation-LD^Q
(mg/kg) (mg/kg) Other
USOS-Air
TWA 1 mg/m3
as Cu
-
- -
-
- -
-
LDLQ 39 LC50
SCU-MUS 118 ppm/30M
105
-
-
122
SCU-MUS
Substances List
Cross-Reference
No.
GL78750
-
-
GL80500
GS59500
-
GT22750
TE87500
OW17500
TF70000
TB17500
-------
n
i
00
Ca8we11 Xc^ ^ a"5S= —
Accession Suspected Oral-LD50 Dermal-LD50 Inhalation-LD^
—No: Carcinogen fofi/kfi) (mg/kg) (n«/kK) 5° othe,
268AC - If680
2688 - 9 23 RBT
268BA -
268C - 4>500
268D -
269 * 1,297 MUS - _ usos.Air
TWA 300 ppm
270 " i'620 1.000 RBT LCLo USOS-Air
2,000 ppm/4H TWA 50 ppm
270A - 23 SCU
271 - ._
271AA -
271A - 1,500
271B -
271BB ...
NIOSH- Toxic
Substances List
Cross-Reference
XZ18300
NJ64750
QE06100
GU63000
GW10500
MA43750
YS78750
-------
Toxiclty Data
Caswell
Accession
No.
271BC
27 1C
27 ICC
271D
271E
i
JS
vo 272
272B
273
273AA
273AB
273A
273B
Acute
Suspected Oral-LD^Q
Carcinogen (rag/kg)
190
35
1,200
215
160
3,860
LDL_ 300
Acute
Dennal-LDcQ Inhalation-LD^Q
(rag /kg) Gng/kg) Other
USOS-Ai
TWA 100 ui
as Sn (sk:
450
274
MUS
1,200
NIOSH-Toxic
Substances List
Cross-Reference
No.
WH87500
FB80500
XY53800
GZ10500
TF75250
UF12250
WM96250
DT82250
-------
Ul
o
Caswell
Accession
No.
275
275A
275B
276
276A
277
277A
277B
278
278A
278AA
279
Suspected
CAR
CAR
Acute
Oral-LDso
95
4,720
700
500
570
1,775
1.7
Dermal-LD
Ore/kg)
50
345
310 RBT
2,600
SCU
8.2
Inhalation-LD
(°g/kg)
'50
^50 ,
4,000 mg/m3
MUS
Other
USOS-Air
TWA 100 mg/m3
(skin)
NIOSH-Toxic
Substances List
Cross-Reference
Ifo.
PC85750
HK43750
TA21000
UP 8 05 00
UP82250
HF17500
TF31500
-------
Toxicity Data
NIOSH-Toxic
Ca swell
Accession
No.
279A
279B
280
280A
282
283
283A
284
285
285A
286
286AA
286A
Acute Acute Substances List
Suspected Oral-LDgg Dermal-LDcQ Inhalation-LDcQ Cross-Reference
Carcinogen (mg/kg) (mg/kg) (mg/kg) Other No.
_
LD5Q 350 mg/kg HH94500
as Fe
IVN-MUS
4,000 - - USOS-Air SA91000
TWA 50 ppm
5 145 RBT - - TD54500
_
_
89 - - FB84000
700 360 - - AB52500
.
890 - - - TD56000
_
- - -
610 MUS - - - BV82250
-------
o
I
Ui
KJ
Caswell
Accession
No.
287
287AA
287A
287AB
287AC
28 7 B
287C
289
290
291
291A
29 IB
291C
292
Suspected
Carcinogen
Acute
Oral-LD
(mg/kg)
173
Toxicity Data
1,167
410
500
3,510
Acute
Dermal-LD50 Inhalation-LD5Q
(mg/kg) (mg/kg)
1,400 RBT
103 ppm/8H
Other
USOS-Alr
IHA 5 fflg/m3
NIOSH-Toxic
Substances List
Cross-Reference
No.
TX87500
EG70000
VN82250
DB16500
G078750
TL08750
-------
NIOSH- Toxic
Caswell
Accession
No.
L1W *
293
294
295
296
297
o 297AA
Ol
w 298
298A
299
300
301
302
304
Acute Acute
Suspected Oral-LD50 Dertnal-LD50 Inhalation-LD50
Carcinogen (mg/kg) (mg/kg) (mg/kg)
-
1,040
330 790
2,710 1,350 RBT
250
1,300
1,870
CAR 395 2,000 RBT
3,500
LCLo
707 ppm/7H
2.7
_
Substances List
Cross-Reference
Other No.
_
-
DG75250
TE78750
DI35000
TF03500
QL75250
EZ40250
EZ82250
DG19250
CZ45000
XY71750
USDS -Air PA82000
rrv.TA 1 f\(\f\ nnm
-------
Caswell
Accession Suspected
No. C.art-1 r.^rn
304A
305A
306
306A
306AA
306 B
307 NEC-
308 CAR
309 CAR
Acute Acute ~~ " —
Oral-LD Dermal-LD50 Inhalation-LDSft
(mfi/kfi>- - <"Bfrff> <«/!«> nm~
500 i 000
'
_
USOS-Air
TWA 0.2 mg/m3
-
-
10
~ -
113 1,200 RBT
113 2>500 - USOS-Air
TWA 1 mg/m3
(skin)
75 - TnT
LCLo USOS-Air
1,000 ppm/45M CL 15 ppm
(skin)
NIOSH- Toxic
Substances List
Cross- Reference
-
W064750
MU07000
DV50750
KI07000
KJ33250
KN08750
309AA
309AB
309AC
500
2,890
1,000
W065600
KN79600
-------
o
1
Ul
U1
Ca swell
Accession
K1/1
NO.
309 AD
309AE
309 B
310
310A
311
312
313
Toxlcity Data
Acute Acute
Suspected Oral-LD50 Dermal-LD50 Inhalation-LD50
rflrctnogen (mg/kg) Ong/kg) (mg/kg^
-
2,000
500
_ _ —
LDLo 1,500
3,500
410
«JAJon.- J.UAJ.W
Substances List
Cross-Reference
Other No.
_
"
TF01750
DC78750
"
BX29750
DG78750
USOS-Air KI 10500
CL 10 ppm
314
315
315ZC
315AG
315AI
750
375
666
1,500
280
SCU-MUS
USOS-Air
TWA 10 mg/m3
LDL0 250 mg/kg
IPR-MUS
150
VN84000
AG68250
AG89250
AG71750
AG77000
-------
Caswell
Accession Suspected
315AL
315AU
315AV
316
317
o 319
Ol
320
322
322A
323
323A
323B
323D
323E
Acute Acute
Oral-LD50 Dermal-LD50 Inhalation-LD50
(rag /kg) (rag /kg) (rag/kg)
TDL0 150 -
TDLo 150
700
700 800
1,700
730
800 1,400
LDLj, 1,000
LDLo 270 1,680 RBT
740 .
Other
USOS-Air
TWA 15 mg/m3
NIOSH-Toxic
Substances List
Cross-Reference
Njx.
A6S0500
AG85750
AG87500
ES91000
KK45500
KK49000
UF10500
SK91000
TB50750
KN84000
-------
0
1
U1
-vl
Ca swell
Accession
No.
323F
323G
324
324A
325
326
Acute
Suspected Oral-LD50
Carcinogen (mg/Hg)
-
-
140
250
560
LDL0 3,500
Toxicity Data
Acute
Dermal -LD5Q Inhalation-LD^Q
(mg/kg) (sag/kg)
-
-
2,100
LDL0 2,100
RBT
-
-
Other
-
LD50
5,000 mg/kg
UNK-MAM
-
-
-
-
326A
326 B
327
327A
328
757
1,000
56
75
USOS-Air
TWA 1,000 ppm
LD50 14 mg/kg
IPR-MUS
USOS-Air
TWA 1 mg/nr*
(skin)
NIOSH-Toxic
Substances List
Cross-Reference
No.
US79600
TY01750
UC83100
UE49000
DG80500
KI11000
CV38500
DD73500
TC03500
-------
o
I
Ul
00
Caswell
Accession
No.
328A
329
329A
330
331
33 UA
331A
33 IB
332
333
333A
333B
333C
333D
Suspected
Carcinogen
CAR
Acute
(me/kg)
1,800
400
Toxicity Data
84
46
Acute
Dennal-LD
(mg/kg)
'50
Inhalation-LD
50
60
Other
USOS-Air
TWA 250 ug/m3
(skin)
NIOSH-Toxic
Substances List
Cross-Reference
No.
AS40250
SK70000
BP65600
1017500
TF05250
-------
N10SH-Toxic
Gas we 11
Accession
No.
333E
334
334B
335
335A
? 335B
*° 335 BB
335C
337
338
338A
340
340A
341
Acute Acute
Suspected Oral-LD,-0 Dermal-LD50
Carcinogen (rag /kg) (mg/kg)
3
885
2,050
16 860
-
61
-
3,000 2,000 RBT
-
480 LDL0 2,100
SKN-RAT
15 380
3.6 90
LDLo 2 6
Substances List
Inhalation-LD50 Cross-Reference
(mg/kg) Other No.
TF 14000
XY73500
TF14100
GN63000
. -
TD57750
-
SS94850
- -
LQ77000
LD50 2,00 mg/kg ID59500
IVN-RBT
FB38500
TD85750
TLV-Air TD92750
rrmiL 1 f\f\ **r» /wnv
(skin)
-------
o
1
a*
o
Caswell
Accession
No.
342
343
343A
343B
344
344A
344AB
344AC
344B
344C
345
345A
345B
346
Acute Acute
Suspected Oral-LD50 Dermal-LD50
Carcinogen (mg/kR) (rag /kg)
76 455
2 3
50
-
9 250
1,600
82
8 100
-
3.5 11
67
26
200 2,180 RBT
Inhalation-LDcQ
(mg/kg) Other
TLV-Ai:
TWA 100 ,
(skin)
_
-p
"
_ _
.
-
_
-
_ _
_ _
NIOSH-Toxic
Substances List
Cross-Reference
. No.
TF33250
TF38500
TF37500
TD84000
FB92100
TF56350
TD82250
TF57750
GW42000
TF61250
XS36750
-------
Toxicity Data
NIOSH-Toxic
Caswell
Accession Suspected
No. Carcinogen
347
348
349
349B
350
350A
350B
352 CAR
352A CAR
Acute
Oral-LD
(mg/kg1
-
-
-
1,000
-
-
1,600
IPR-RAT
3,800
2,340
Acute
Dermal-LDcjQ Inhalation- LDcQ
(mg/kg) (mg/kg)
-
-
-
-
-
-
.. _
TDL0 1,300
SCU
TDLo 1,500
SCU
Substances List
Cross-Re ference
Other No .
— _
-
LDLj, 180 mg/kg IH20000
ORL-DOG
QL07000
-
-
UP79850
UR59500
UR60000
352 B
352C
353
2,500
VL12250
-------
Caswell
Accession
No.
353AA
353A
353B
354
355
£ 355A
356
356AA
356A
356B
357
358
359
359A
Acute
Suspected Oral-LD5o
Carcinogen (rag/kg)
67
110
-
-
800
-
368
6
200
90 IPR
770
147
-
.
Toxicity Data Nrrn
-------
o
I
Caswell
Accession
No.
359 B
359C
359D
359 DD
359 E
360
360A
361
362
362A
363
364
364A
364B
Toxicity Data
Acute Acute
Suspected Oral-LD50 Dermal-LD^ Inhalation-LD50
Carcinogen (rag/kg) (mg/kg) (mg/kg)
60 15 IPR
147
-
-
500 1,260 RBT
30 275
250
179 1,000
1,000
375
NEO TDLQ 1,440
- - -
240
1 300
Other
-
_
_
-
-
-
-
-
-
-
-
-
NIOSH-Toxic
Substances List
Cross-Reference
No.
CZ17500
EZ91000
BX80500
FC01750
FD12250
FC11400
RB89250
TD61250
AH13500
LQ80500
FC10500
-------
o
I
Caswell
Accession
No.
365
365A
366
366A
366C
366D
367
368
368A
368B
368C
369
369A
Acute
Suspected Oral-LD50
Carcinogen (mg/kg)
800
-
47
4,200
330
-
31
-
-
LDLo 50
-
-
15
Toxic ity Data
Acute
Dermal-LD50 Inhalation-LD50
(mg/kg) (mg/kg) other
— _ _
100
3,500 SCU - USOS-Air
TWA 10 ppm
(skin)
353
-
LDL0 20 -
RBT
~ — —
-
700
~ — _
-
68
NIOSH- Toxic
Substances List
Cross-Reference
No_.
AH15750
TG14200
LQ21000
TE10500
LZ94500
TF80500
TF94500
-------
o
I
Caswell
Accession Suspected
No. Carcinogen
370
371
37 1A
372
373
374
375
376
377
378
378A
379
379A
Acute
Oral-LDcQ
(rag/kg)
7
200
500 TRK
9
250
16
-
16
21
74
7.5
600
103
Toxic ity Data
Acute
Dermal-LD50 Inhalation- 1,050
(Wg/kg) (mg/kg) other
48 RBT
283
_
67 - TLV-Air
TWA 200 u.g/m3
(skin)
LDLQ 300
300 - USOS-Air
TWA 200 ug/m3
(skin)
-
42
112
202
118 RBT
-
160 RBT
NIOSH- Toxic
Substances List
Cross -Reference
No.
TC50750
TE 14000
NI50750
TG01750
TG03500
TEW 250
_
TC38500
TC43750
GQ50750
TB49700
TE26250
TF79000
-------
o
I
Caswell
Accession
No.
380
380A
380B
381
38 1A
382
383
385
385A
385B
386
387
388
Acute
Suspected Oral-LD50
Carcinogen (mg/kR)
4,400 RBT
-
-
20
-
-
2,200
400
1,100
89
650
-
„
*~ — "T •""•" NIOSH- Toxic
ACUte Substances List
Dermal-LD50 Inhalation-LD50 Cross- Reference
(me/kg)
-------
Toxiclty Data
N10SH-Toxic
Caswell Acute Acute
Accession Suspected Oral-LDso Dermal-LD5Q
No. Carcinogen (mg/kg) (mg/kg)
389C - 1,070 130 RBT
390 - 25 200
390A - LDLo 30 LDL,, 20
SCU
391 - 65 LDLo 30
SCU-MUS
39 1A - 400
Substances List
Inhalation-LD^Q Cross-Reference
(mg/kg) Other No.
-
USOS-Air
TWA 200 ug/m3
(skin)
-
-
LDL0
1,000 mg/kg
SKN-GPG
CZ05250
G096250
GP10500
SK66500
SK70000
391B
391C
391D
392
392A
3,600
980
30
25 SCU
LD5Q 23 mg/kg
IVN-RAT
LD50 108 mg/kg
UNK-MAM
XU61250
GQ57750
SL28000
FF89500
392B
-------
Toxicity Data
Caswell
Accession
No.
392C
392DD
392DE
392DF
o 293DG
o\
°° 392DH
392DI
392H
3921
39 2 J
393
Acute Acute Substances List
Suspected Oral-LDso Dennal-LD50 Inhalation-LD50 Cross- Reference
Carcinogen (mg/kg) (mg/kg) (mg/kg) other No
LD50 XK94500
1,000 mg/kg
ORL-DOG
25 80 - SJ98000
"
45 LDLo 67 - - SK05250
™* • w —
-
-
1,900 - - . WN05250
90 1,660 MIS - - FC19250
~ - T.ric/% ")Lf\ mo lira TlVTROCn
394
0.9
UNK-MAM
LD5Q 15 mg/kg
ORL-CAT
NK56000
394A
-------
Toxicity Data
i
01
VO
Caswell
Accession
No.
395
396
398
399
399A
399B
399C
399D
399DA
399E
400
401
401A
402
Suspected
Carcinogen
Acute
Oral-LDjQ
(mg/kg)
293
3,500
LDL0 3,000
1,500
231
Acute
Derma1-LDcQ
(mg/kg)
800
SCU-MUS
Inhalation-LD
(mg/kg)
'50
Other
NIOSH-Toxic
Substances List
Cross-Referenee
No:
AB80500
AL98000
JJ78000
20 SCU
QJ34400
JM56900
-------
o
I
Caswell Acute Acute
Accession Suspected Oral-LD5Q Dermal-LD50 Inhalation-LD
_Np. Carcinogen (mg/kg) (mg/kg) (mg/kg)
402A -
402B - _ _
403 - - _
404
405 - 1,800
406 -..
406A -
406B -
407
Other
—
—
—
-
_
_
_
408
408AA
408A
408AB
900 MIS
5,000
UNK-RAT
LDL0 100 mg/kg
IPR-MUS
NIOSH-Toxic
Substances List
Cross-Reference
No.
PA22750
SN05250
TB20500
DL45500
-------
Caswell Acute Acute
Accession Suspected Oral-LD50 Dennal-LD50 Inhalation-LD50
No. Carcinogen (rag/kg) (rag/kg) (rag/kg)
408B -
409 - ._
410 437
411 CAR LDL 306
o
411A -
413
413A -
413B -
413C - 2,300
413D - - • _
413DA -
413DB -
413DC -
413E -
Other
NIOSH-Toxic
Substances List
Cross-Reference
No.
YS89250
PC82250
DB66500
-------
ho
Toxic ity Data
Caswell Acute Acute
Accession Suspected Oral-LDso Dermal -LD5Q Inhalation- LD50
No. Carcinogen (mg/kg) (rag/kg) (mg/kg)
413EB -
414 - - _
415
416 - - _
416A -
416B -
416C - 400
417 --.
418
418A - T
Other
_
_
_
_
_
-
_
_
.HI. 1 ^ me
418AA
419
420
566
18
74
o ^°
UNK-MUS
TLV-Air
TWA 100
(skin)
NIOSH-Toxic
Substances List
Cross-Reference
No.
B031500
MF19250
MF17500
RB92750
-------
r>
I
Caswell Acute
Accession Suspected Oral-LDso
No. Carcinogen (rag/kg)
421 - 38
421A
421AB
421B
421BA
421C - 51
421D
422 - 23
423 - 3
424 NBO 90
Toxic ity Data
Acute
Dermal -LD50 Inhalation-LD50
(mg/kg) (rag/kg)
— _
— —
-
-
-
750
-
130
15
100 LCL
SKN-RBT 250 pp£/4H
Other
n
T-
_
USOS-Air
TWA 10 ug/i
(skin)
USOS-Air
TWA 5 ppm
(skin)
424A
425
NIOSH- Toxic
Substances List
Cross -Re fere nee
RN78750
RN82250
TF82250
1015750
TX49000
1,120
UF14000
-------
Toxicity Data
NIOSH-Toxic
Caswell
Accession
No.
425A
425B
425C
425D
426
426A
426B
427
427AA
427A
427C
427CC
427D
Acute
Suspected Oral-LD^Q
Carcinogen (rag /kg)
3,400
-
-
-
2,100
-
710
13
34
-
-
-
800
Acute Substances List
Dermal-Li^ Inhalation-LD50 Cross-Reference
(rag/kg) (rag/kg) Other No.
GN17750
-
-
-
2,537 - USOS-Air KJ57750
SCU-MUS TWA 3 ppm
LD5Q SZ71000
4,200 mg/kg
UNK-MAM
EZ72900
62 - - TB45500
60 TE40250
-
-
-
VB82250
-------
•vj
Ul
Caswell
Accession
No.
427E
427EE
427F
428
429
430
430A
430B
431A
4 3 LAB
431AC
431AD
431B
Acute
Suspected Oral-LD50
Carcinogen (rag /kg)
3,800
-
-
2,000 MUS
4,930 RBT
LDLo 220
MUS
56 BDW
1,465
125
-
1,550
-
1,500
Acute Substances List
Dermal-LD50 Inhalation-LD50 Cross-Reference
(rag/kg) (rag/kg) other NO.
GD98000
_
-
XJ47250
5,000 SOU LC5Q USOS-Air AH54250
1,600 ppm TWA 400 ppm
8 .285 - USOS-Air KQ63000
SCU-MUS TWA 1,000 ppm
DG24500
XY87500
2,000 - - TE12250
See 188AC
- - UE75500
-
- fin?nnnn
-------
Toxicity Data
NIOSH-Toxic
Caswell
Accession
No.
432A
434
434A
434AB
434B
435
436
436A
436 B
437
437A
438
438AA
Acute Acute
Suspected Oral-LD5Q Derma 1-LD5Q
Carcinogen (mg/kg) (mg/kg)
3,160
CAR 700
4,000
200 700
150
1,630 1,460 RBT
-
3,000
64
0.8 730 RBT
150 IMS
2,000
2,000
Substances List
Inhalation-LD50 Cross-Reference
(mg/kg) Other No.
EZ36750
LC50 500 ppm - DD22750
IHL-MAM
EZ75250
AI78750
TE38500
LCLj, - FA45500
200 mg/m3/3H
KU53400
LQ28000
EG38500
USOS-Air KH85750
TWA 10 ppm
KV38500
AH40250
AH43750
-------
o
I
Caswell
Accession Suspected
No. Carcinogen
438A
438B
438C
438D
438E
438F
439
440
Acute
(mg/kg)
-
-
1,800
-
-
2,150
140
725
Acute Substances List
Dermal-LD50 Inhalation- LD5Q Cross-Reference
(mg/kg) (mg/kg) Other No.
— _ _ _
_
AH49000
-
-
AH52500
300 RBT LCLj, USOS-Air KH92750
400 ppm/2H TWA 20 ppm
USOS-Air KI01750
TWA 100 ppm
441
441A
442
443
NEO
2,000 CAT
TDL0 4 g/kg
SKN-MUS
330
1,462 ppm/4H
USOS-Air
TWA 50 ppm
KW29750
KX24500
-------
Toxicity Data
NIOSH-Toxic
Caswell
Accession
No.
443A
444
445
446
446A
r>
^ 447
00
447AB
447AC
447AD
447AE
447B
448
Acute
Suspected Oral-LDjg
Carcinogen (mg/kg)
1,850
501
2,400
-
LDLQ 2,300
5,000 RBT
-
-
-
LDLQ 29
ORL-CKN
-
30
Acute Substances Li
Derma 1-LD^Q Inhalation-LD^Q Cross-Referen
(mg/kg) (mg/kg) Other Nb .
LCLQ USOS-Air LQ84000
8,000 ppm/4H TWA 100 ppm
CM26250
MD26250
-
TA04400
DH21900
-
-
_
USOS-Air OV61250
TWA 10 ug/m3
_
200 - USOS-Air OV98000
TWA 10 ug/m3
449
-------
o
I
VO
Caswell
Accession
No.
451
452
453
453A
454
454A
454B
454BA
454D
455
455A
Toxic ity Data
Acute Acute
Suspected Oral-LD50 Dennal-LD50 Inhalation- LD50
Carcinogen (n«/kg) (ing /kg) (mg/kg)
-
30
100
8 73
8 25
-
3 147
-
-
47 100
38 500 LCcn
Other
.
-
-
-
-
-
-
-
-
455B
456
456AA
25
180
195 n«/m3/4H
NIOSH-Toxic
Substances List
Cross-Reference
No.
OW43750
OW38500
TB36750
TB19250
TA59500
TG14200
TF90500
TE43750
TG16500
-------
Caswell
Accession
No.
456A
45 6 B
456C
456D
456EA
o
oo 456EB
0
456EC
456F
457
458
Acute
Suspected Oral-LD-Q
Carcinogen (ing /kg)
15
480
LDL0 500
35
4,720
310
4,000
Toxic ity Data
Acute
Dennal-LDcQ Inhalation-LOcQ
(mg/kg) (rag/kg)
64
LDLQ 2,100
LDL0 5,000
SCU
1,460 RBT
330
Other
USOS-Ai
459
459A
459 B
900
TWA 15 mg/m3
TLV-Air
TWA 1 mg/m3
NIOSH-Toxic
Substances List
Cross-Reference
No.
TB07000
LQ77000
SJ43750
TF76500
HE43750
TF96250
N087500
LJ91000
-------
Caswell Acute
Accession Suspected Oral-LDcn
No. Carcinogen (mg/kg)
459C - 3,250
460
460AA
460A - 89
o *6°B - 2,600
i
00
461 - 5.7
462
462AA
462A - 5
463
464
Toxic itv Data
Acute
Dermal-LD50 Inhalation-LD50
(rag/kg) (mg/kg) other
-
• —
LD50
1,550 mg/kg
UNK-RAT
~
-
80
°-28 scu - TDLjj 2 mg/kg
ORL-HMN
"* ™ _
4
LDLQ
200 mg/kg
ORL-GPG
TDLQ
500 mg/kg
ORL-HAM
NIOSH- Toxic
Substances List
Cross-Reference
No
J.1W •
BR65000
XU51600
YT15750
XS98450
AC 12250
AH59500
AH28000
W82250
TI56850
-------
Caswell
Accession
No.
465
465
465 B
465CC
465E
o
i
00
N>
466
466AA
466A
467
468
Acute
Suspected Oral -LD50
Carcinogen (mg/kg)
NEO 800
-
20
-
— —
127
700 UNK
1,100
-
2,380
Toxicity Data
Acute
Dermal-LDcQ Inhalation-LD^Q
(mg/kg) (mg/kg) Other
420 SCU LCLj, USOS-Air
250 ppm/4H TWA 3 ppm
_
_
-•
LD5Q
200 mg/kg
IPR-MUS
LDLQ 500 LCLQ USOS-Air
SCU-RBT 153 ppm/4H TWA 5 ppm
(skin)
_
_
_
2,560 RBT LCL0
NIOSH- Toxic
Substances List
Cross-Re ference
No.
LP89250
-
FC28000
-
LS96250
LT70000
GZ 16400
DD90100
-
MA24500
5,000 ppm/4H
469
7,750 GPG
MA80500
-------
o
1
00
Caswell
Accession
No.
470
471
471AB
471AC
471AD
47 IB
Acute Acute
Suspected Oral-LD50 Dermal-LD50 Inhalation- LD50
Carcinogen (mg/kg) (me/kg) (wg/kg)
1,950
1,340
4,320
-
-
NEO TDLQ 50 TDLj, 120
SCU-MJS
Other
_
_
—
—
-
472
472A
472B
473
474
474A
474B
40
195
USOS-Air
TWA 500 pg/m3
(skin)
NIOSH-Toxic
Substances List
Cross-Reference
No.
MC52500
NJ38250
MC10750
W698000
PC07000
-------
NIOSH-Toxic
Caswell
Accession
No.
474BA
474C
474D
474E
475
o 476
i
00
477
477A
478
479
480
480AA
Acute Acute
Suspected Oral-LD50 Dermal-LD50 Inhalation-LD50
Carcinogen (mg/kg) (mg/kg) (mg/kg)
_
3,800
-
3,170
_
1,290 2,980 LC50
360 ppm/4H
3,500
_
113
LDLQ 4,000
SCU-RBT
150
7 23
Substances List
Cross-Reference
Other No.
-
NJ37600
-
NJ33250
-
UC21000
- DA29750
-
TLV-Air GY12250
TWA 10 ppb
USOS-Air KI40250
TWA 1 ppm
(skin)
OW34100
1019250
-------
00
Ul
Caswell
Accession
No.
480A
481
481 A
481AB
48 UC
48 IB
48 1C
48 ID
48 IDE
48 IE
48 IF
482
Toxic ity Data
Acute Acute
Suspected Oral-LD50 Dennal-LD50 Inhalation- LD50
Carcinogen (rag/kg) (mg/kg) (n«/kg)
155
-
-
-
-
316 LDLQ 2,000
RBT
-
-
-
2,000 MOS - . -
-
NEO - TDL0 - LI
144 g/kg
SCU
Other
-
-
-
-
-
-
-
-
-
-
-
>5Q 9,200
IVN-RA:
NIOSH-Toxic
Substances List
Cross-Reference
No.
OW42000
XY92750
DU19250
MN47250
482A
-------
Toxicity Data
NIOSH-Toxic
Caswe11 Acute Acute Substances List
Accession Suspected Oral-LD5Q Dermal-LD Inhalation-LD50 Cross-Reference
No. Carcinogen (mg/kg) (mg/kg) (me/kg) Other No.
482AB - 720 3,100 RBT
482AC NEO 550 - - TDL0 2,480 mg/kg
IVG-MUS
482B
482C -
482D ' - TDLQ 20 mg/kg
o PAR-MJS
00
483 - 3.7 MUS LDLQ 3 LC50 USOS-Air
SCU-MUS 544 ppm/5M TWA 10 ppm
(skin)
^84 - - LDLo 100 LC5Q USOS-Air
SCU-GPG 1,276 ppm/lH TWA 3 ppm
485 - LDLQ 200 LDLj, 250
GPG SCU-GPG
486 LC50 USOS-Air
4,700 ppm/30M CL 5 ppm
MJ40250
VH15750
-
-
GM89250
MW68250
MW78750
W82250
MW96250
486A
486AB
-------
o
CO
Caswell
Accession
No.
486AC
486B
486C
486D
486 E
487
48 7 A
487AB
487B
487C
488
488A
Suspected
Carcinogen
CAR
Acute
Oral-LD50
(me/kg)
110
Toxicity Data
3,800
3,130
TDL0 572
MUS
Acute
Derma 1-LDcQ
(mg/kg)
LDL0 0.21
Inhalation-1050
(me/kg)
Other
LD50
337 mg/kg
IPR-RAT
NIOSH-Toxic
Substances List
Cross-Reference
No.
DI40250
NJ37600
MB91850
NJ28000
KL28000
489
-------
Toxicity Data NIOSH-Toxic
Caswell Acute Acute Substances List
Accession Suspected Oral-LD5Q Dermal-LD50 Inhalation-LD5Q Cross-Reference
No- Carcinogen (mg/kg) (mg/kg) (ng/kg) Other No_.
489A ... ...
489B ... ...
490
490A - - - - -
491
491A ... ...
00
oo 492
492A ... ...
492B ... ...
493
494B ... ...
494C . .
494D ... ...
495 - 1,900 - TY73500
-------
o
00
VO
Caswell Acute
Accession Suspected Oral-LDsn
No. Carcinogen (rag/kg)
495AA - 70
495A
495 B CAR 3,800
496 - 535 MUS
496AA
496A - 17
496B - 25
496C
497
498
498A
499
499A
499B
f — - — - wiu on- ioxi C
Acute Substances List
Dermal-LD50 Inhalation-LD50 Cross-Reference
(mg/kg) (mg/kg) other No
QK57750
"• — •
TDLo 1.300 - _ UR59500
SCU
450 MUS - . UT96250
_
GN76300
600 . . FA19250
-
— — •
„ —
_ _ —
LDLQ 100 mg/kg NL52500
IPR-MUS
- _ _
-------
Toxicity Data
NIOSH-Toxic
Caswell
Accession
No.
501
501A
502
502A
o 503
i
VO
503A
503AB
503B
504
505
505A
506
Acute
Suspected Oral-U>50
Carcinogen (mg/kg)
-
_ -
-
0.2
2,460
280
3,400
-
-
2,330
Acute Substances List
Dermal-LD50 Inhalation-LD50 Cross-Reference
(mg/kg) (mg/kg) Other No.
USOS-Air NN15750
CL 0.1 ppm
_
LDL0 250 mg/kg KI77000
IPR-MUS
-
AJ63000
4,240 RBT LCL0 USOS-Air NP96250
8,000 ppm/4H TWA 100 ppm
500 RBT - - NQ43750
YQ92750
_
-
LDL0 USOS-Air GW77000
1,840 ppm/4H
TWA 25 ppm
506A
-------
C as we 11
Accession
No.
507
508
509
509A
o
NO
~ 509 B
510
510AA
510A
511
Acute
Suspected Oral-L05Q
Carcinogen (rag /kg)
LDL0 192
MUS
83
LDLQ 192
2,400 MUS
LDLQ 1,630
NEO 1,000
-
NEO 1,200
810
Toxic ity Data
Acute
Dermal -LD50 Inhalation-LD^Q
(mg/kg) (mg/kg) Other
16 RBT - USOS-Air
TWA 400 ppm
TLV-Air
TWA 500 ug/m
16 RBT - USOS-Air
TWA 400 ppm
-
-
-
-
-
LDLo 2,700
RBT
511D
511DA
511E
13
5.6
NIOSH-Toxic
Substances List
Cross-Reference
No.
NT80500
FC31500
NT80500
XY98000
XZ01750
FD91000
FD80500
FI12250
FA21000
-------
Toxicity Data
NIOSH-Toxic
Caswell Acute Acute
Accession Suspected Oral-LDcQ Dermal-LDjQ Inhalation-LD5Q
No. Carcinogen (rag/kg) (mg/kg) (nog/kg)
512 NEO 1,000
512AA ...
512A 29
512B - 150 MUS
512C ...
513 - 900 - -
o
VO
*» 513AA -
513A ...
513B
514 ...
515
515A ...
515AA - 2.5 MUS
516
516A - 3,000
Substances List
Cross-Reference
Other No .
FD91000
-
FB78750
FC33500
-
AJ83500
-
-
-
-
-
-
QJ57750
-
EY99800
-------
ACa8W*U Acute A^T^
Accession Suspected Oral-LD5Q Dermal-LD
N°_: Carcinogen (mg/ki>) (mg/ke)50
517
517AA
517A
518 .._
518A
519
519A - 2,700
5198 * ^LO 200 LDLo l>500
520 . 23Q
521
522
523 - 1,250
523A CAR TDLo 82
"* "^ __ NIOSH-Toxic
Substances List
Inhalation-LD50 Cross-Reference
(raR/ke) ni-hm-
*=B — aj. Ul-ner No.
LDL0 OA55000
800 mg/kg
ITR-RAT
JR19250
OF38500
NX52500
XK96250
AI52500
-------
Toxicity Data
Caswell Acute Acute
Accession Suspected Oral-LDgQ Dermal-LDcQ
No. - Carcinogen (mg/kg) (mg/kg)
524 - 100
525
525AA NEO - TDLo 48 g/kg
MUS
525A -
o 525B - 42
i
VO
.p.
526 - LDL 4,600
0
527 CAR 88 500
527A
528 - 3,300
528A ...
528B
529 - LDLn 280 LDLo 2,100
Inhalation- LD^Q
(n>g/kg) Other
USOS-Air
TWA 150 ug/m3
-
- -
-
_ _
-
USOS-Air
TWA 500 ug/m3
(skin)
-
-
-
-
USOS-Air
RBT
TWA 500 ug/m3
as As
NIOSH-Toxic
Substances List
Cross-Reference
No.
CG09800
0620250
TB17200
OSS1000
GV49000
YS91000
C610500
-------
o
I
vo
Ul
Caswell
Accession
No.
530
530A
531
532
532A
533
534
534A
534B
534C
535
Suspected
Carcinogen
Acute
Oral-LD5Q
(wg/kg)
LDLQ 5,250
2,800
200 GPG
Toxicity Data
159 RBT
LDL0 75
RBT
599
Acute
Derma 1-LD,
(n>8/kg)
50
LDLQ 900
SCU
400
SCU-GPG
Inhalation-LD5Q
(mg/kg)
Other
LDLQ 1,100 nig/kg
IPR-RAT
LDLQ 1,750 mg/kg
SCU-RBT
USDS-Air
TWA 1 n^/
as Cu
USOS-Air
TWA 15 mg/m3
(skin)
N10SH-Toxic
Substances List
Cross-Reference
No.
OM24700
F001750
OM28000
W85750
OM45000
GL69100
BQ11800
WM84000
-------
Toxicity Data
NIOSH-Toxic
I
VO
Caswell
Accession
No.
537
537A
539
539AA
539A
539A
540
541
54 1A
54 IB
54 1C
543
Acute Acute
Suspected Or&l-LD^Q Dermal- LD.-Q Inhalation- 0)50
Carcinogen (mg/kg) (mg/kg) (mg/kg)
LDLQ 1,600
-
CAR TDL0 64,000
-
-
- - _
3,180 LDL0 2,000
SCU
3,000
_
_
3,968 - .
93 1,550 LCL
Substances List
Cross-Reference
Other No.
ON71750
-
OP07000
-
-
-
OT03500
DL64750
-
-
DL68250
TE22750
31
543A
76
AI85750
-------
n
•vj
Caswell
Accession
No.
544
544A
545
546
546A
546B
546C
546D
547
Acute
Suspected Oral-LD50
Carcinogen (mg/kg)
37
18
210
NEO LDLo 1,429
ORL-HMN
-
-
-
-
1,120
Toxic ity Data
Acute
Derma 1-LD50 Inhalation-LD50
(mg/kg) (mg/kg)
14 SCU LCLo MUS
300 mg/nP/lOM
-
-
TDL0 29 TCL0
IVN-HMN 169 ug/nPMOY
IHL-HMN
-
_
- _
-
1,000 ppm/4H
NIOSH- Toxic
Substances List
Cross-Reference
Other No.
OV91000
OW87500
OV87500
USOS-Air OV45500
CL 1 mg/10 m3
.
—
tm —
.
USOS-Air SB42000
TWA 25 ppm
547A
548
630
XF99000
-------
VO
oo
Gaswe11
Accession
No.
549
549AA
549 B
549C
549CA
549D
549 DD
549 E
550
551
55 IB
Suspected
Carcinogen
Toxicity Data NIOSH-Toxic
Acute
Oral-LDjQ
(rag/kg)
-
20
17
91 MUS
57
5,000
2,460
Acute Substances List
Dermal-LD^Q Inhalation- LD^Q Cross-Reference
(mg/kg) (mg/kg) Other No.
LDLj, UC64750
300 mg/kg
I PR- MUS
25 TE21000
AK29750
82 DF43750
SCU-MUS
720 - - TA75650
USOS-Air KJ36750
TWA 15 mg/m3
1,340 RBT LCLQ USOS-Air KL57750
2,000 ppm/4H TWA 25 ppm
(skin)
16
USOS-Air
TWA 10 ug/m3
OV63000
-------
Caswell Acute
Accession Suspected Oral-LD5Q
No. Carcinogen (mg/kg)
551C
55 ID - LDL0 4,900
552 - LDLQ 420
MUS
553
vo 554 - LDL- 5,000
VD u
555
Acute
Dermal-LD50
(mg/kg)
-
-
9,800
SCU-MUS
-
-
TDL0
8,000 ppm
SKN-HMN
Inhalation- LDcQ
(mg/kg) Other
.
USOS-Air
TWA 100 ppm
(skin)
USOS-Air
TWA 200 ppm
- -
- .
TCLj, USOS-Air
35 ppm CL 20 ppm
IHL-HMN (skin)
irLisan- iUAit
Substances List
Cross-Reference
No.
JM15750
PC 14000
„
QJ96300
PA49000
555A
556A
557
557A
557B
148
5,700 ppm/4H
LCLQ
3,000 ppm/4H
USOS-Air
TWA 100 ppm
1,072
31
756 RBT
EL91000
PA63000
UE88400
LL60700
-------
8
Ca swell
Accession
No.
557C
557D
557E
557K
558
558A
559
559A
559D
559E
561
56 1A
56 IB
56 1C
Toxic ity Data
Acute Acute
Suspected Oral-LDjg Dermal-LDjQ Inhalation- 11)50
Carcinogen (mg/kg) (mg/kg) (mg/kg)
700 LDL0 28
SCU-MUS
_
800
800
_
700 MUS
650 900 RBT
1,060
650 MUS
_
_
4 4 LC50
14 ppm/lH
1,250
460
Other
-
-
-
-
-
-
-
-
-
-
-
USOS-Ai
TWA 400 u
-
-
NIOSH-Toxic
Substances List
Cross-Reference
No_.
AG15750
AG22750
AG26250
ES83800
UE97500
UF01750
UF03500
GQ52500
JF73500
JF75250
-------
Toxic ity Data
NIOSH-Toxic
Caswell Acute
Accession Suspected Oral-LDcn
No. Carcinogen (mg/kg)
562 - 778
563 - 2,690
563A
564 - 860 MUS
564A
o 564B
!-•
0
M 565
566 - 60
566A
567 - LDLQ 1,000
RBT
568 - 2,136
568A
568B
Acute Substances List
Dermal-LD50 Inhalation-LD50 Cross- Reference
(mg/kg) (mg/kg) Other No.
BQ34100
SM01750
-
SM03500
_
_ _ _
_
LDLQ 600 - - SM07000
_
805 6000
6,460 - USOS-Air PA80500
SCU-MUS TWA 500 ppm
-
* — • •
-------
Toxicity Data
Caswell
Accession
No.
568C
569
570
572
573
573AA
573A
573B
573C
573D
573E
Suspected
Carcinogen
CAR
Acute
al-LD
(me/kg)
3,400
1,620 RBT
6,000 RBT
305
20
IPR-MUS
Acute
Dennal-LD
(me/kg)
'50
TDLQ 62 g/kg
MUS
Inhalation-LD
(mg/kg)
'50
LCL
2,000 ppm/4H
Other
USOS-Air
TWA 200 ppm
USOS-Air
TWA 100 ppm
USOS-Air
TWA 10 ug/m3
J50
LDS
15 mg/kg
UNK-MAM
NIOSH-Toxic
Substances List
Cross-Reference
No.
RK08950
EL64750
LQ89250
DH24500
PA96250
OW49000
OW20000
573F
56
OW66500
-------
o
I
Caswell
Accession
No.
573G
573H
573HA
5731
573J
573JA
573JB
573K
573L
573M
573N
5730
573P
Suspected
Carcinogen
Acute
Oral-LD
Toxicity Data
5Q
72
2,140
LDLQ 2,000
Acute
Derma1-LD
(mg/kg)
'50
Inhalation-LD
(me/kg)
'50
Other
NIOSH-Toxic
Substances List
Cross-Reference
No.
OW70000
PQ52000
TY89250
574
3,696
SA07000
-------
Toxic ity Data
NIOSH-Toxic
n
i
Gaswell
Accession
No.
574AA
574A
574B
575
575AA
575A
576
576A
577
577A
578
578A
578AB
Acute
Suspected Oral-LD^Q
Carcinogen (ing /kg)
2,080
62
-
257
200
2,500
1 , 100
1,000
887
-
-
1,170
— —
Acute Substances List
Dermal-LD^Q Inhalation-LD^Q Cross-Reference
(nK/kg) (mg/kg) Other No.
LCLo USOS-Air SA92750
4,000 Ppm/15M TWA 100 ppm
FA24500
_
DG77000
FA26250
- - - FD85750
500 - - FG14000
B090000
V047250
_
LD50 BY62000
2,000 mg/kg
UNK-MAM
WZ07000
_
-------
o
I
t-1
o
Ui
Ca swell
Accession
No.
578B
578C
579
579AA
579A
579B
579C
580
580C
580D
580E
581
58 1A
582
Toxicity Data NIOSH-Toxic
Acute Acute Substances List
Suspected Oral-LD5Q Dermal-LD50 Inhalation-LD50 Cross-Reference
Carcinogen (rag/kg) (mg/kg) (mg/kg) Other No.
60 350 - - FC57750
~
-
-
2,000 - - - YS33250
14 1,500 - - FC07000
LD50 5 g/kg XI26250
UNK-MAM
NEO - TDLQ 40 g/kg - - SE71750
SKN-MUS
750 - - PA24500
-
-
-
- -
LDcft 50 mg/kg PA26250
UNK-MAM
-------
Toxicity Data
NIOSH-Toxic
Caswell
Accession
No.
582A
583
583A
584
i
o
°* 584AA
584A
585
586
587
Acute
Suspected Oral-LDc/j
Carcinogen (mg/kg)
-
CAR 1,480
2,300
1,050
1,500
-
395
250
NEO 1 , 780
Acute
Dermal-LD^Q Inhalation-LD,-Q
(mg/kg) (n«/kg) Other
LD50
250 mg/kg
IMS-RAT
.
-
500 RBT - USOS-Air
TWA 20 ppm
(skin)
- - -
LD5Q
2,000 mg/kg
UNK-RAT
.
800 - USOS-Air
TWA 3 mg/m3
TDLQ 3,500 - USOS-Air
SCU TWA 10 ppm
Substances List
Cross- Reference
No.
WA19000
US63000
AJ80500
QD64750
FA07900
LU51600
FA68250
TB94500
QJ05250
588
-------
i
i-"
o
Caswell
Accession
No.
589
589A
589AB
589B
589C
589D
589 E
590
591
591A
592
593
594
Suspected
Carcinogen
Acute
Oral-LD5Q
(mg/kg)
1,000
2,420
1,770
Toxicitv Data
Dennal-LD
(mg/kg)
50
(TOg/kg)
Other
LDLQ
512 mg/kg
IPR-MUS
2,940
SCU
NIOSH-Toxic
Substances List
Cross-Reference
No_.
QJ08750
QJ12250
QL29750
TH73500
-------
Toxicity Data
NIOSH-Toxic
n
i
h->
o
00
Caswell
Accession
No.
595
595A
Acute
Suspected Oral-LD^Q
Carcinogen (ing /kg)
2,750
-
Acute
Dermal-LDcjQ
(rag/kg)
LDLQ 668
SCU
-
Inhalation-LDtjQ
(mg/kg) Other
-
LDLo
285 mg/kg
IPR-MUS
Substances List
Cross-Reference
No.
QP38500
QP43750
59 6A
596AB
596B
597
59 7A
598
598AA
598A
599
53
55
5,000 MLJS
940
1,470
LDL0 500
SCU-DOG
140
285
LDLQ 4,000
SCU-MUS
850 RBT
USOS-Air
TWA 4.5 mg/m3
USOS-Air
TWA 500 ug/m3
(skin)
LD50
500 mg/kg
IPR-MUS
QR96000
QS52500
QS96250
QT05250
US75250
AJO1750
AJ07000
-------
Caswell
Accession
No.
600
Suspected
Carcinogen
Acute
Oral-LD50
(rag /kg)
LDLQ 700
RBT
Acute
Dermal-LD50
(rag/kg)
LDLQ 600
RBT
Inhalation-LD50
(ing /kg)
Other
USOS-Ai:
TUA 1 rki
NIOSH-Toxic
Substances List
Cross-Reference
. No_.
DA64750
ppm
(skin)
601
601AA
601A
n 601AB
i
*° 601B
602
602A
603
603A
604
604AA
605
NEO
TDLQ 230
SCU-MUS
350
SD95000
SM22750
-------
o
I
(-•
!-•
O
Caswell
Accession
No.
605A
606
607
607A
608
609
609A
610
611
611A
612
613
613A
613B
613C
Toxic ity Data
Acute Acute
Suspected Oral-LDr/j Dermal-LDcQ Inhalation-LDcQ
Carcinogen (rag /kg) (rag /kg) Cog/kg)
2,100
5.3
1,470
-
-
4.8 5
_
5 15
'
1,790 MUS
_
2,800 470 RBT
.
_
_ _ _ —
Other
-
-
-
-
-
-
-
-
-
-
-
-
-
-
_
NIOSH-Toxic
Substances List
Cross-Reference
No.
KL96250
RB87500
YT45500
PC12250
UX59500
RH65500
RB85750
-------
o
Caswell Acute
Accession Suspected Oral-LD__
No. Carcinogen (mg/kg)
613D
614
614A
614B - 368
614C
614D
615 - 2,000
616 - 2,090
616A - 387
617
618
Toxicity Data
Acute
Dermal-LD50 Inhalation-LD50
(mg/kg) (rag/kg) other
LDLQ 25 mj
IPR-MU!
- - _
— _ _
— _ _
— _ _
-
- _
-
-
— — •
6 ISA
618B
4,440
1,000 mg/kg
ORL-MAM
NIOSH- Toxic
Substances List
Cross- Reference
SMS 7 750
B071750
2,500 RBT
DA57750
BZ89250
RI68250
GE87500
LE25300
LY40600
-------
Toxicity Data
NIOSH-Toxic
Caswell Acute Acute
Accession Suspected Oral-LD50 Dermal-LDjQ inhalation-LD50
No. Carcinogen (mg/kg) (me/kK) (me /kg) Other
618C - - . -
618D - - - -
618K - 5,000 ...
618F - 2,840 ...
619 NBO - TDL0 3,120
SCU-RBT
M 619A ... _
ro
620
621
621A - -
622 - 8 - USOS-Air
Substances List
Cross- Reference
No.
-
-
VL04450
XP20000
RG22750
.
-
-
-
CG07000
623
623A
624
IVN-RBT
TWA 500 ug/ra3
as As
LCLQ
707 ppm/7H
CZ45000
2,000
DB52500
-------
Caswe11 Acute Acute
Accession Suspected Oral-LD5Q Dermal-LD50
No. Carcinogen (n«/k§) (mg/kg)
624A
625
625A - 12 UNK
625B -
626 - _
0
£ 627
CO
627A - 2,000
627B
628 - 4,800 LDL0 650
SCU-MUS
631 - 1,400
632 CAR 500 TDLO 142
SCU-MUS
632A -
633 - 800
Substances List
Inhalation-LD50 Cross -Reference
(mg/kj*) other Hn
USOS-Air R024500
TWA 1 n«/m3
RP23500
_ _ _
"
RP49000
• • ^
QI78750
WR57750
USOS-Air CZ45500
TWA 75 ppm
- -
-------
Toxicity Data
Caswe11
Accession
No.
634
635
635A
637
637A
638
639
639A
639 B
640
641
Suspected
Carcinogen
CAR
Acute
Oral-LD50
(me/kg)
57
141
LDLQ 4,000
22
1,650
27
Acute
Dermal-
(me/kg)
80
700
SCU-RBT
576
MUS
105
Inhalation-LD
(mg/kg)
'50
4,238 ppm/2H
Other
USDS-Air
TWA 500 ug/ffl3
(skin)
LCL USOS-Air
10 mg/m3/2H TWA 110 ug/m3
(skin)
USOS-Air
TWA 500 ug/m3
NIOSH-Toxic
Substances List
Cross-Reference
No.
DW22750
DW20100
TF45500
UT47250
GL64750
KI63000
DA66500
SM63000
641A
-------
Caswell Acute
Accession Suspected Oral-LD5o
No. Carcinogen (mg/ke)
641B - 227
641C
641D
641E ' -
642
o 642AA
i
tj
Ul
= f ; _ WlUbH-XOXlC
Acute Substances List
Dermal-LD5() Inhalation- LD5Q Cross-Reference
(me/kg) (nK/kfi) other No
72 SCU * - SM66500
— _ ^
. ^
^ ^
» —
TCLo USOS-Air RZ94500
130,000 ppm TWA 1,000 ppm
642A
642B
642C
6420
644
645
645A
IHL-HMN
LCLQ
2,000 ppm/4H
663
1,540
SA31500
AF83000
XU83500
SD87500
-------
Caswell
Accession
No.
645B
Suspected
Carcinogen
NEO
Acute
Oral-LD50
(mg/kg)
-
Acute
Dermal -1050
(mg/kg)
TDL,, 40 8/kg
MUS
Inhalation-LDcQ
(mg/kg)
-
Substances List
Cross-Reference
Other No.
SE71750
a\
646
646A
646AB
646 B
647
647A
647B
648
648B
649
14
CAR
414
669
USOS-Air
TWA 500 ppm
USOS-Air
TWA 500 ppm
LD50
3,000 mg/kg
UNK-MAM
USOS-Air
TWA 5 ppm
(skin)
SE75250
SE75250
CH63000
FD90500
SJ33250
-------
Caswell
Accession Suspected
No. Carcinogen
650
652
652A
653
654
654A
654B
655
655 B
655C
655D
655DA
655E
656 NEO
Toxic ity Data
Acute Acute
Oral-LD50 Dennal-LD50 Inhalation- LD5Q
(°S/k8) (me/kg)
-------
Toxicity Data
o
i
Caswell Acute Acute.
Accession Suspected Oral-LDc0 Dermal-LDcQ Inhalation-LDSQ
No. Carcinogen (mg/kg) (ing /kg) (mg/kg)
656A -
656B -
656C -
656D ...
565E - 60 47 SCU
657
657A ...
657B ...
657C ...
657D - - - -
657E ...
657F -
657G ...
657H 390
6571 - 63 SCU
Other
-
-
-
-
-
-
-
-
-
-
-
-
-
-
—
NIOSH-Toxic
Substances List
Cross-Reference
No.
OW14000
OW77000
OW84000
-------
Toxicity Data
NIOSH-Toxic
o
i
Caswell Acute Acute
Accession Suspected Oral-U^g Dermal-LDjQ Inhalation-LDso
No. Carcinogen (rag/kg) (rag/kg) (n«/kg)
657J ...
657K 90
657L ...
657M - - - -
657N 30
6570 -
657P - 50 UNK -
658 - 2,700
658A - - - '
658B -
658C -
658D -
658E - M60
658F -
659
Substances List
Cross- Reference
Other No.
OW91000
-
-
BT47250
-
OW97000
DV57750
-
- -
-
-
DV77000
— —
-
-------
N>
O
Caswell
Accession
No.
660
660A
661
662
663
663AA
663AB
663AC
663AD
663B
Acute
Suspected Oral-LDjQ
Carcinogen (mg/kg)
1
120
17
1,530
LDLQ 10
RBT
3,750
-
-
-
15 MUS
Toxicity Data
Acute
Derma 1-LD^Q Inhalation-LD50
(ing/kg) (mg/kg)
3
390
125
2,740
LDLo 13 LDL0
SCU-RBT 500 mg/m3/10M
MUS
-
-
-
-
3
SCU-RAT
Other
^••^•MB^MB
TLV-Air
TWA 50 ug/m3
(skin)
-
-
USOS-Air
TWA 1 mg/m3
USOS-Air
TWA 100 ug/m3
TLV-Air
TWA 10 mg/m3
-
-
-
_
NIOSH- Toxic
Substances List
Cross-Reference
No.
TD94500
TD64750
TC 28000
TB63000
TH35000
TJ75250
-
-
-
TJ91000
664
-------
o
I
I-"
to
Caswell Acute Acute
Accession Suspected Oral-LD50 Dermal-LD50
No. Carcinogen (rag/kg) (rag/kg)
665 - ._
666
667 - _.
668 - 4,900
668A -
669 - 4.4
670 - 3,800 MUS
671 - 280
671AA
671A
671B
672 - __
672A NEO TDL0 7,500
672B -..
Substances List
Inhalation-LD50 Cross-Reference
(mg/kg) Other NO.
_ _
~ — _
TL40250
-
DF49110
XS80500
USOS-Air NK63000
TWA 100 ug/m3
— — — .
» »• —
- — —
— — _
NZ33000
-------
Toxicity Data
o
i
10
Is)
Caswell
Accession
No.
672C
673
674
675
675A
675B
675C
675D
675E
676
676A
676B
677
Suspected
Carcinogen
Acute
(mg/kg)
504
Acute
Dermal-LDi
(rag/kg)"
'50
Inhalation-LD
(me/kg)
'50
NEO
Other
TDL0
2,120 mg/kg
IMP-RAT
NIOSH-Toxic
Substances List
Cross-Reference
No.
CP29750
TQ33250
-------
Caswell Acute Acute
Accession Suspected Oral-LD5Q Dermal-LDgo
No. Carcinogen (mg/kg) (n«/kg)
678 - - LDL0 68
SCU-MUS
678A
678B -
680 - 419
681 CAR - TDL0 2,500
? SCU
t->
ro
681AA
681A
682 - _.
682A NEO 14 150
682B -
682C -..
Substances List
Inhalation-LD5Q Cross -Reference
(mg/kg) Other No.
TR08750
- - -
— •» —
TR52500
TDLQ TR81600
750 ng/kg
IVN-RAT
-
- _ _
-
USOS-Air CG35000
TWA 0.5 ng/m3
as As
-
LDL0 TS66500
150 mg/kg
ORL-GPG
-------
o
I
t-*
to
Toxicity Data
Caswell Acute Acute
Accession Suspected Oral-LD5Q Dermal-LDjg Inhalation- LD5<
No. Carcinogen (mg/kfi) (mg/kg) (me/kg)
684
685 - 1,870
686 - LDLo 2,430
687
688 NEO 841 MUS -
688A - 10 9 SCU
689 ...
690 - - LDL0 10
SCU-RBT
691
)
Other
-
-
-
USOS-Air
CL 100 ug/m3
as CrO^
TDLo
100 mg/kg
IPR-MUS
USOS-Air
TWA 5 mg/m3
(skin)
-
-
LD50
350 n«/kg
IPR-MUS
NIOSH- Toxic
Substances List
Cross-Reference
No.
_
TS77500
TS80500
GB31500
6S68250
TS87500
'
HX76800
EZ61250
691A
-------
Caswell
Accession Suspected
No . Carcinogen
692
692A
692B
693
Acute
(rag /kg)
-
-
-
365
Acute
Derma 1-LD5Q
(rag /kg)
LDL0 400
SCU-MUS
-
-
Inhalation-LD50
(mg/kg)
-
-
-
Substances List
Cross-Reference
Other No.
FG15750
_ _
_ _
TT.V-A-II- TT-nnnn
o
I
»-«
ro
ui
693A
694
694A
695
696
696A
697
698
699
TWA 2
LDLj, 1,862
MUS
1,090
500
SCU-MUS
TT29750
OW98500
SD64750
-------
Toxicity Data
o
i
H»
Is)
Caswell
Accession
No.
699A
700
701
701A
701B
702
702A
703
703A
703B
704
704A
704AB
704B
Suspected
Carcinogen
Acute
Oral-LD50
(me/kg)
Acute
Dermal-LDi
(mg/kg)
'50
Inhalation-IJ>5o
(mg/kg)
Other
LDL0
3,000 rag/kg
SCU-GPG
854
NIOSH-Toxic
Substances List
Cross-Reference
No.
TT59000
XL19250
-------
Toxicity Data
NIOSH- Toxic
o
i
i-*
NJ
Caswell
Accession
No.
704C
704D
704E
704F
705
705A
706
707
708
709
709A
710
Acute Acute
Suspected Oral-LD5Q Dermal-LD50
Carcinogen (mg/kg) (mg/kg)
1,750 2,200 RBT
2,100
1,480 250
70
LDL0 53
-
150 670 RBT
1,510 500 RBT
2,360
CAR TDL0 3,500 TDLQ 20
SCU
1,870 3,230
SCU-MUS
1,020
Substances List
Inhalation-LD50 Cross-Reference
(mg/kg) Other No.
XY42000
XY43900
WT29000
LCLo USOS-Air UK50750
2,000 mg/m3 TWA 1 ppm
MUS (skin)
UK43750
_
LCLo - UC92750
16 ppm/4H
UE59500
UF91000
RQ73500
LCL0 USOS-Air UH82250
4,000 ppm/4H TWA 200 ppm
EZ05250
-------
Toxicity Data
NIOSH-Toxic
o
K)
00
Ca swell
Accession
No.
711
712
713
713A
714
714A
714B
714BA
714BB
714C
715
715
Acute
Suspected Oral-LDcQ
Carcinogen (mg/kg)
1,470
1,900
930
-
-
80
-
1,170
2,330
1,200
1,200
Acute
Dermal-LDcQ Inhalation-LDcQ
(mg/kg) (mg/kg) Other
_
LCLo USOS-Air
2,000 ppW4H TWA 75 ppm
TLm 96
> 1,000
1,500 RBT LCLo USOS-Air
4,000 ppm/4H TWA 100 ppm
LD50
200 mg/kg
IPR-MUS
_
-
.
1,926 RBT -
_
-
LD50
960 mg/kg
UMC-MAM
Substances List
Cross- Reference
No.
FA47250
TX96250
TY20000
TZ29750
DH28000
-
FC75250
-
AE 11400
UR61250
GZ07000
(Pyrethrin I)
GZ17500
(Pyrethrin II)
-------
Toxicity Data
Caswell Acute Acute
Accession Suspected Oral-LD50 Dermal-LD50
No. Carcinogen (mg/kg) (mg/kg)
716 - 200
717 - 891 1,000 SCU
718
718A
o 718AB -
N>
*° 718B -
718C -
719 CAR 1,200
719A
719AA
719B ...
719C NBO 130 TDLo
2,000 mg/kg
MUS
Inhalation-LDcQ
(mg/kg) Other
USOS-Air
TWA 5 mg/m3
LC50 USOS-Air
4,000 ppm/4H TWA 5 ppm
-
-
_
-
-
29 g/kg
-
-
-
LCL0 USOS-Air
320 mg/m3 TWA 0.1 ppm
HIOSH-Toxic
Substances List
Cro s a-Re ference
No_.
UR42000
UR84000
VC42000
DK26250
-------
10
O
Caswell
Accession
No.
720
721
722
722A
723
724
725
727
728
729
730
731
Acute
Suspected Oral-LDso
Carcinogen ( rag/kg )
1,800
LDLQ 1,000
200
-
301
906
NED 132
-
LDL0 25
CAR 1,950
-
891
Toxic ity Data
Acute
Dermal-LDijQ Inhalation-LDjQ
(rag/kg) (mg/kg) Other
_
-
_
-
LDL0 340
SCU-MUS
2,000 - USOS-Air
TWA 10 mg/m3
USOS-Air
TWA 5 n^/m3
-
-
LDLQ 1,000
SCU-RBT
_
LDLo 700
SCU
N10SH- Toxic
Substances List
Cross-Reference
No.
FG31500
WP21000
VF73500
-
VG96250
TG05250
DJ28000
-
YX59500
CY28000
-
V005250
-------
o
l-«
CA»
Caswell
Accession
No.
731A
731B
732
732A
733
733A
734
734A
735
736
737
Acute
Suspected Oral-LDso
Carcinogen (ing /kg)
LDL0 3,000
MUS
2,500
-
138
-
5,000
3,160
3,160
100 MUS
LDL0 300
GPG
50 MUS
Toxicitv Data NTOSH-TOXI e
Acute Substances List
Dermal-LD50 Inhalation-LD50 Cross- Reference
(mg/kg) (mg/kR) other NO.
LDL0 900 - . VQ14000
SCU-MUS
XY49800
LCL0 USOS-Air VS77000
33 mg/kg/8H TWA 0.2 mg/m3
USOS-Air VS89250
TWA 0.2 n«/m
-
YT73500
W73200
W73200
USOS-Air VW36750
TWA 10 ug/m3
LDL0 800 - - VW42000
SCU-GPG
USOS-Air uu/t79«:n
TWA 15 ug/m3
738
-------
to
Caswell Acute
Accession Suspected Oral-LDcQ
No. Carcinogen (mg/kg)
739 - 650
740 - 5,000
741
74 1A - 3,530
742
742A
742B
743 - LDLo 12
RBT
744
Toxic ity Data
Acute
Derma l-LDjQ Inhalation-LD,-0
(mg/kg) (mg/kg) Other
_
_
_
8,000
SCU-MUS
LD50
193 mg/kg
IPR-MIJS
.
_
USOS -Air
TWA 500 ug/m3
as As
LD50
1.2 mg/kg
IPR-MUS
NIOSH-Toxic
Substances List
Gross-Reference
No.
UF82250
XY52500
-
AJ43750
VZ18700
-
-
CG12250
CG34000
746
4,100
2,000
SCU-RBT
DH66500
746A
-------
OJ
u>
Caswell
Accession
No.
747
747A
748
749
750
751
751AA
75 1A
75 IB
752
753
Acute Acute
Suspected Oral-LD50 Dermal-LD50
Carcinogen Ong/kg) (mg/kg)
4,220
LDLQ 200 LDL0 250
GPG SCU-GPG
-
-
-
2,660
-
2,600
-
LDLQ 4,000
1,200
9
Inhalation-LD__
(mg/kg;) Other
-
-
« v
LD50
193 mg/kg
IPR-MUS
LD50
650 mg/kg
IPR-RAT
-
— _
-
-
LD50
117 mg/kg
IPR-MUS
LD50
596 mg/kg
IPR-MUS
ru.UDn-j.ux.LC
Substances List
Cross-Re ference
No.
VZ09500
VY14000
VZ18700
VZ20000
VZ22750
—
CH77000
_
VZ40500
F005250
-------
Toxicity Data
NIOSH-Toxic
n
i
Caswell
Accession
No.
754
755
755A
755B
755C
756
757
757A
758
758A
758B
759
Acute
Suspected Oral -11)50
Carcinogen (rag/kg)
3,000
-
76
320
750
-
-
-
6.4
3,860
570
1,670
Acute
Dermal-LDeQ
(mg/kg)
LDLj, 3,500
SOU
-
-
-
-
-
LDL0 243
SCU-RBT
-
LDLQ 10
SCU-MUS
-
-
- -
Substances List
Inhalation-LD50 Cross-Reference
(n«/kg) Other No.
VZ47250
_
AG14000
AS64750
DB50750
_
LD5Q GB32200
32 rag /kg
IPR-MIIS
_
USOS-Air VZ75250
TWA 5 mg/m3
(skin)
UF12250
UP82250
WA03500
-------
o
I
(->
u>
Ul
Caswell
Accession
No.
761
76U
762
762A
763
764
765
766
768
769
Acute
Suspected Oral-LI^g
Carcinogen (rag /kg)
NBO TDL0 160
IPL
60
1,000
LDLfc 30
1,900
2,000 MUS
63
200
180
Acute
Dermal-LDso
(mg/kg)
LDL0 51
SCU-GPG
LDLj, 20
SCU
66
SCU-MUS
LDLj, 12S
SCU
Inhalation-LD50
(mg/kg) Other
USOS-Aii
CL 100 ug>
as CrO^
LD.JQ 15 ing
IPR-RA1
USOS-Air
TWA 4.6 mg,
USOS-Air
TWA 5.5 ng,
770
0.22
5 SCU
LD5Q
300 mg/nP/lOM
USOS-Air
TWA 50 ug/m3
(skin)
NIOSH-Toxic
Substances List
Cross-Reference
No.
HX77000
CZ17500
FD35000
GF10500
WN05250
WA36750
OV84000
WA96250
WB03500
AH91000
-------
Toxlcity Data
NIOSH-Toxic
Caswell Acute Acute Substances List
Accession Suspected Oral-LDcQ Dermal-LD^Q Inhalation-LD^Q Cross-Reference
No. Carcinogen (mg/kg) (mg/kg) (mg/kg) Other No.
771 - 125 LDLo 50° - USOS-Air
SCU-GPG TWA 4.1 mg/m3
772 - LD5Q
870 mg/kg
IPR-MUS
773 - LDLQ 500 - - USOS-Air
RBT TWA 2 mg/m3
o 774 - - - - LDso
£ 650 mg/kg
& IPR-RAT
WB08750
OY36750
WB49000
VZ20000
775
776
777
778
778A
4,340
LDL0 8 mg/kg
IVN-RAT
600 mg/kg
PAR-MLJS
LDL0
400 mg/kg
UNK-MUS
OW45500
WB64750
ZD70000
OF07000
-------
o
i
t-*
U)
Caswell
Accession
No.
778B
779
779A
780
780AA
780A
781
78 1A
782
782A
783
784
784A
Toxicity Data
Acute Acute
Suspected Oral-LD5Q Dermal-LD50 Inhalation-LD50
Carcinogen (mg/kg) (rag/kg) (rag/kg)
~ - - _
1,288
1,280
700 800 RBT
-
1,770
LDLQ 200
1,100
85 LDLj, 15
SCU
-
-
227 72 SCU
• — •»
Other
-
-
-
-
-
-
-
_
-
-
-
LD-~
NIOSH-Toxic
Substances List
Cross-Reference
No.
WT10500
W92750
FC21000
TH73510
WC56000
MB84000
RA12250
50,
538 mg/kg
IPR-MUS
SM66500
SC73500
-------
Toxicity Data
NIOSH-Toxic
o
i
00
Caswell
Accession
No.
785
785A
786A
787
788
789
790
790A
790AA
790B
791
792
793
Acute Acute Substances List
Suspected Oral-LDcn Derma 1-LD^Q Inhalation-LD^g Cross-Reference
Carcinogen (mfc/kg) (mg/kg) (rag/kg) Other No.
LD50 SE05250
226 mg/kg
IPR-MLJS
- _
.
1,160 - - - DV77000
875 - - WD57750
SCU-MUS
_
1,640 RBT - - DF75250
_ - -
_
_
LDLQ 7 - USOS-Air VS66500
RBT TWA 0.2 mg/nr3
1,280 - - - W92750
LDL0 4,470 mg/kg WE16500
IVN-RBT
-------
o
I
VO
Caswell
Accession Suspected
No. Carcinogen
794
795
796
796A
796B
797
798
799
Toxic ity Data
Acute Acute
Oral-LD50 Dermal- LD50 Inhalation-LDgo
(mg/kg) (mg/kg) (mg/kg) Other
LDL0 181 -
RBT
2,660 -
_
764 -
- -
3,320 -
720 -
LD50
700 mg/kg
IPR-MUS
NIOSH- Toxic
Substances List
Cross-Reference
No.
WE21500
VZ22750
-
XL22750
-
AJ91000
KM49000
YK49000
799A
800
801
801A
801B
CAR
TDL0 2,600
SCU
4,920
W621000
WG21600
-------
Caswell
Accession
No.
80 1C
802
804
804A
805
806
807
808A
809
809A
809B
Toxic ity Data
Acute Acute
Suspected Oral-LD50 Dermal-LD50 Inhalation- LD50
Carcinogen (mg/kg) (mg/kg) (rag/kg)
_
M _ V »
520
SCU-MUS
>
16 0.85
SCU-MUS
5 1.7 SCU
LDLo 2,700
8,000 DOG - - . .
1.6
CAR 3,900 TDL0 135
SCU
CAR TDL0 2,310
MUS
NIOSH- Toxic
Substances List
Cross-Reference
Other No.
-
USOS-Air WJ89250
TWA 500 ppm
WK43750
LD50 WK49900
102 mg/kg
IVN-MUS
USOS-Air WL22750
TWA 150 ug/m3
WL25500
WN24000
AC84500
W059500
W084000
WP23600
-------
o
Caswell Acute
Accession Suspected Oral-LD50
No. Carcinogen (mg/kg)
809D
809E
810
811
812
813
814
815 - 2,140
816
816A - LDLQ 100
Toxicity Data Nrnsii-ivnMo
Acute Substances List
Dermal-LD50 Inhalation- LD50 Cross- Reference
(mg/kg) (mg/kg) other No.
_
- - _ _
~ — _ —
-
WS42500
LCLo USOS-Air WS45500
611 ppm/5H TWA 5 ppm
-
LCLo USOS-Air WS56000
178 ppm/7H TWA 1 mg/m3
WT48700
USOS-Air WT50750
TWA 5 ppm
818
819
CAR
522
5,000 RBT
2,480 RBT
TDL0 4,450
SCU
PD87500
WW50750
820
-------
10
Caswell
Accession
No.
820A
820B
821
821A
821AB
821B
821C
822
823
824
Acute
Suspected Oral-LD^g
Carcinogen (mg/kg)
115
-
1,000
-
5
1,845
2,980
CAR 200
4,300
4,800
Toxic ity Data
Acute
Dermal- LDcQ Inhalation-LD^Q
(mg/kg) (mg/kg)
55
SCU-MIJS
-
1,370
-
1
RBT
-
-
-
-
LDL0 650
SCU-MUS
NIOSH- Toxic
Substances List
Cross-Reference
Other No.
USOS-Air CC68250
TWA 0.5 mg/m3
as Sb
-
TLV-Air TF68900
TWA 10 mg/m3
LD50 YQ93600
5,000 mg/kg
UNK-MfcM
Data by American
Cyanamid Company
XY45500
XY47250
WZ61250
WZ66000
QI78750
825
-------
I
t-l
*>
CO
Caswell
Accession
No.
826
827
829
830
830A
831
832
832A
832B
832C
832D
833
833A
Acute
Suspected Oral-LD50
Carcinogen (n«/kg)
LDLQ 700
DOG
LDL0 5,000
RBT
LDL0 2,150
-
-
NEO
140
-
-
-
-
243
™ «*
Toxicitv Data MTOSH-T^^
Acute Substances List
Dermal-LD50 Inhalation-LD50 Cross -Reference
(mg/kg) ("ns/kg) other NfT
LDLo 500 LCL USOS-Air KI85750
SCU-RBT 1,000 ppm/4H TWA 5 PPm
(skin)
LDL0 2,200 LCLQ USOS-Air KX38500
SCU-RBT 4,000 PPm/4H TWA 100 ppm
XB26250
- " - .
— — •
TDLo 576 - - DC01750
MUS
210 SCU - . S^IOOO
-
— _
\
-
W89000
.
-------
Toxicity Data
NIOSH-Toxic
Caswell
Accession
No.
833B
834
835
835A
836
837
Acute
Suspected Oral-LD^Q
Carcinogen (mg/kg)
-
70
-
-
566
5
Acute
Dennal-LD^Q
(mg/kg)
-
256 RBT
-
-
-
8
SCU-MUS
Substances List
Inhalation-LD5o Cross- Reference
(mg/kg) Other No.
_
XN03500
_
_
WR71000
USOS-Air XN43750
TWA 200 ug/m3
838
838A
839
840
841A
842
0.5
2.4
320
199
1,130 RBT
(skin)
USOS-Air
TWA 50 ug/m3
(skin)
UX68250
XI28000
FC77000
-------
o
I
(Jl
Caswell Acute
Accession Suspected Oral-LDso
No. Carcinogen (mg/kg)
842A - 2,860
842B
843 - 2
844
845A - 450
846
847 - LDLO 40
MUS
848
849 - 16
849A - 3,100
849B
850 - 1.3
Toxic ity Data
Acute
Dermal-LD50 Inhalation-LD50
(rag/kg) (mg/kfi) other
LCL0
275 ppm/8H
GPG
-
2
-
1,800
LD50
330 mg/kg
IPR-MUS
LD5Q 59 mg/kg
IPR-RAT
- -
-
- -
- -
LD50
0.85 mg/kg
IPR-RAT
NIOSH- Toxic
Substances List
Cross-Reference
No.
QK38500
_
TD40250
_
XN45500
AH50750
UX73500
_
XG66000
DE07000
-
GP33250
-------
Toxiclty Data
NIOSH-Toxic
o
i
•-«
£
Ca swell
Accession
No.
851
852
853
853A
853AB
853B
854
855
856
856A
857
Acute Acute
Suspected Oral-LD5Q Dennal-LD50 Inhalation-LD5Q
Carcinogen (pg/kg) (mg/kg) (mg/kg) Other
LDL0
250 mg/kg
IPR-MUS
900 MUS - - LDLo
100 mg/kg
IPR-MUS
_
_
_
3 ,400 MUS - - LD5Q
790 mg/kg
IPR-MUS
_
NEO 20 - '
560 - - USOS-Air
TWA 5 mg/m3
980
. -» — — —
Substances List
Cross-Reference
No.
SN03500
SN05250
-
-
-
BA36750
-
YU28000
JO 14000
XP22750
-
-------
o
I
Caswell
Accession
No.
858
859
859A
859B
860
861
86 1A
862A
863
863A
864
865
Acute
Suspected Oral-LD50
Carcinogen (rag /kg)
-
5,000
-
-
-
60
-
LDL0 800
410
178
150
910
Acute Substances List
Dermal-LD50 Inhalation-LD50 Cross-Reference
(mg/kg) (rag/kg) other No.
_
LDLQ 5,000 LCL0 USOS-Air XS52500
SCU 4,000 ppm/4H TWA 200 ppm
-
-
-
780 LDLo USOS-Air XW52500
2,000 mg/m3/2H TWA 500 ug/m3
MUS (skin)
-
LDLo 400 KM35000
IPR-RAT
110 SCU - - VN89250
TA29750
168 - - TG54250
615 - - TG56000
-------
Toxicity Data
Caswell Acute
Accession Suspected Oral-LDjQ
No. Carcinogen (mg/kg)
867 - 99
.
867AA
867A
867B
0 867C
£ 867D
867E
867F
867G
867H
868 NEO 20
Acute
Dermal-LDcQ Inhalation-LD^Q
(n«/kg) (n«/kg) Other
USOS-Ai
TWA 100 in
as Sn (sk
-
_
_
.
_
_
- . -
.
_
USOS-Ai
869
870
300
3,320
j/m3
NIOSH- Toxic
Substances List
Cross-Reference
WH57750
TWA 1 mg/ra3
CG08300
BZ50750
AJ78750
-------
Casvell
Accession
No.
870A
872
873
873A
873B
874
874A
875
876
876AA
Acute
Suspected Oral-LD5Q
Carcinogen (rag /kg)
1,471
756
650
1,644
3,075
-
-
-
5,660 RBT
CAR 4,920
-
Toxicity Data NIOSH-Toxic
Acute Substances List
Dermal-LD50 Inhalation-LD50 Cross-Reference
(mg/kg) (mg/kg) Other No.
EZ85750
DC21000
1,500 - - DH77000
SCU-MUS
DH84000
XT85750
-
-
— — — _
USOS-Air KJ292750
TWA 350 ppm
LDLj, 1,800 LCLo USOS-Air KX45500
SCU-RBT 8,000 ppm/4H TWA 100 ppm
LDLo 200 - LD100 FM94500
SCU 400 mg/kg
ORL-RAT
877
490 MUS
XZ15750
-------
Toxicity Data
NIOSH-Toxic
Ul
o
Caswell
Accession
No.
877B
878
878A
879
880
880A
880B
880C
Acute Acute
Suspected Oral-LDcQ Dermal-LD-- Inhalation-LD^Q
Carcinogen (mg/kg) Ong/kg) (mg/kg) Other
LCL0
10 ppm/6H
USOS-Air
TWA 1,000 ppm
_
820 2,260 SCU - LD50
355 mg/kg
IPR-RAT
_
_
1,620
820 - - LD50
276 mg/kg
IPR-RAT
Substances List
Cross- Reference
No.
YC01750
PB61250
-
SN14000
-
-
SN27500
SN15750
881
881A
881P
300
TDLQ 0.45
SCU-MUS
USOS-Air
TWA 10 mg/m3
AJ84000
495
AJ84850
-------
n
i
Casvell
Accession
No.
8811
881X
881Y
882
882A
882F
882FA
882G
882H
883
883A
883AB
883B
883C
Suspected
Carcinoen
Acute Acute
Oral-LD50 Dennal-LD50 Inhalation-LD50
0>«/kg) (rag/kg) (rag/kg)
495
3,000
2,460 LDLQ 1,770
RBT
1,100
80 -
Other
-
-
-
750
NIOSH-Toxic
Substances List
Cross-Reference
No.
AJ85750
AJ87500
UF80500
UU09550
UU77800
XZ19250
-------
o
I
I-"
tn
10
Gas we 11
Accession
No.
884
884AA
884A
884B
885
886
888
888A
Acute
Suspected Oral-LDjQ
Carcinogen (rag /kg)
3,000
-
190
-
594
8,000
- -
316
Toxic ity Data
Acute
Dermal- LD^Q Inhalation-LD^Q
(ing /kg) (rag /kg)
-
— _
-
-
-
9,739
SCU-MUS
LDL0 2,000
RBT
NIOSH-Toxic
Substances List
Cross -Reference
Other No.
USOS-Air TD03500
TWA 0.1 mg/m3
-
USOS-Air WH87500
TWA 100 ug/m3
as Sn (skin)
-
XY54250
KL92750
YE45500
XY92750
888B
889
890AA
890A
500
813
LDLQ 40 mg/kg
IPR-RAT
SM52500
XU92750
DH92750
-------
Caswell Acute
Accession Suspected Oral-LDsn
No. Carcinogen (n«/kg)
890B
891 - 1,080
892
892A
893 - LDLQ 2,000
o 893A - 208
1
^*
J3 894 - 375
896
896A
89 6 B
896C - 125
896D
896E - 46
Acute
Dermal-LD50 Inhalation-LD^Q
( rag/kg) (mg/kg) Other
-
™ • —
— M —
-
-
-
— _ _
- - _
•• — —
44 - USOS-Air
SCU-MUS TWA 100 ug,
as Sn (skii
-
ITSnK-A-f T-
NIOSH-Toxic
Substances List
Cross-Reference
No.
UB87500
SA14000
FC82250
YJ47250
WH66500
TWA 100 ug/n>3
as Sn (skin)
WH-85750
-------
Toxic ity Data
NIOSH-Toxic
o
I
h-«
Ln
4s
Caswell
Accession
No.
896F
89 6G
897
898
898A
899
900
900A
901
902
902A
903
Acute Acute Substances List
Suspected Oral-LD50 Derma 1-LD5Q Inhalation-LD Cross-Reference
Carcinogen (mg/kg) (mg/kg) (mg/kg) Other No.
-
-
850 - - - KK47250
-
1,400 - - - QF22750
-
- ' - - TCLo 75 ppm Y084000
IHL-HMN
LDLj, 20 mg/kg YP29750
I PR- RAT
2,500 - YQ29750
LDLj, 3,000 - - YR62500
SCU-RBT
-
3 - USOS-Air GN45500
TWA 0.1 mg/m3
903A
700 MUS
GN47250
-------
o
I
)-•
Ol
Caswell Acute Acute
Accession Suspected Oral-LD50 Dermal-LD50
No. Carcinogen (mg/kg) (mg/kg)
904 - ._
905 - ._
9°6 - 4,300
907 - ._
907AA CAR 3,200 1,040
907A
908 -._
909 -..
909A
910 ...
Inhalation-LD5Q
(mg/kg) Other
^
NIOSH
TWA 100 ppm
_ _
» —
LDL0
500 mg/kg
IPR-MUS
_
— _
M
LDLo 30 mg/kg
IVN-RAT
911
912
913
NIOSH-Toxic
Substances List
Cross-Reference
No.
ZE21000
ZE65000
ZE50750
ZH14000
-------
o
I
I-*
01
Caswell
Accession Suspected
No . Carcinogen
913A
914
915
916
917
918
919
920
921
921A
922
922A
923
924
Acute
Oral-LD5Q
(fflg/kg)
-
LDLQ 100
-
-
540
630
4,920
-
-
-
40
-
309
—
Acute Substances List
Dermal-LD50 Inhalation- LD50 Cross-Reference
(ing/kg) (ma/kg) other No.
-
ZH36750
-
- - -
DL70000
ZH43500
QK92750
USOS-Air ZH48100
TWA 5 n«/m3
-
-
ZH49000
-
UT92750
-
-------
ToxicIty Data
NIOSH-Toxic
in
-vl
Caswell Acute Acute
Accession Suspected Oral-LD50 Dermal-LD50
No. Carcinogen (mg/kg) (mg/kg)
925
926
927 NEO - TDL0 6.2
SCU-RBT
927A
928
929 - 1,000
930 CAR TDL0 54 g/kg
931 CAR 1,400
931A - 1,400
932 - 600
Substances List
Inhalation-LD^Q Cross- Reference
(mg/kg) Other No.
-
-
LD5Q 40 mg/kg ZH52600
IPR-RAT
-
-
ZH56000
TDL0 ZH33250
160 mg/kg
IPR-MUS
ZH05250
ZH16000
TLV-Air XS42000
TWA 5 mg/m3
-------
APPENDIX D
TABULATION OF AVAILABLE EMISSIONS DATA
FOR THE PESTICIDES INDUSTBY
D-l
-------
Table D-l. AIR EMISSION POLLUTANTS GENERATED BY
PESTICIDE MANUFACTURERS
Pesticide manufactured Type of pollutant Ib Pollutant/lb A.I. Ib Pollutant/unit tine
Methyl parathtoni/ S02 (gas) 0.41 1,550 lb/hr
MSMA- **2°3 (partlculate) 3 x 10~U 6.44 x 10"8 lb/hr
TrlflurallnE/ Nitrate (particulate) — i ib/hr
Sulfate (partlculate) — 1 lb/hr
Chloride (partlculate) — 1 lb/hr
S02 (gas) -- 3 lb/hr
S03 (gas) — i lb/hr
m <8«) — 1 lb/hr
HCl (vapor) .. 10 lb/hr
NOx (gas) „ 3 lb/hr
PCP- PCP (partlculate) 5.5 x 10"4
Na - PCP (partlculate) 2.2 x 10~3
Phenol (vapor) l.o x 10'3
Captani/ Captan (partlculate) ~ 4
O
10 DDTl/ DDT (partlculate) .. „ 2.5 lb/hr
a/ Ifeadi (1975); Ealssions calculated by author.
b/ Ibid.) Emissions estinated by Diamond Shamrock Chemical Company, Greens Bayou, Texas.
c/ Ibid.) Emissions measured by Ell Lilly Company at their Lafayette, Indiana Plant.
d/ Ibid.; PCP emission reported by Relchhold Chemical, Inc., Tacoma, Washington; Phenol and Na-PCP reported by Monsanto
Industrial Chemicals Company, Sauget, Illinois.
el Lawless, et al. (1972)) Captan emission reported by Calhlo Chemical (a Stauffer-Chevron Subsidiary, Perry, Ohio).
if F. Dryden, Head, Technical Services Department, County Sanitation District of Los Angeles County, June 1976.
-------
Table D-2. RAW WASTEUATER CHARACTERISTICS OF ORGANIC PESTICIDE MANUFACTURERS
Pesticides(s) pH COO BODs
Chlorinated pesticide.-' 0.5 3,600 2.000
CarbaaMtest/
7-10 10.000 Nil
Parathlon and awthyl 2 3.000 700
para tb look/
Dlolefln-baaed chlorinated 2 5OO 50
Total
solids
62,000
40.000
27,000
1,000
Suspended
solids
10
Nil
--
100
hydrocarbon at/
2,4,5-Tj 2,4-D; 1
Carbaryl£'
Cblordane£/
MSMAE/
Creosote^'
Haneb
Sndrln*-/
Toxaphene£/
AtraclneJ/
Pesticide^/
Halonenated
A
B
B
C
D
I
r
c
Or»anopho«phorua
H
I
J
K
L
M
N
O
1CPAE' 0.5 8.300 6.300
„
-.
..
-.
--
3-4
3-5
6.0-8.5 42O 60
Uaatewater
Data flow
type!/ (gal/1.000 Ib product)
W 2,500
H 1,200
W 1,200
H 48,000
H 10,400
H 48,000
W 17.300
W 37.800
12,900
989
7.200
H 6,680
1.430
7,440
900
6,530
104.000
--
—
-.
—
—
--
--
—
COO
810
16,000
14,400
--
400
—
._
2.490
3,110
40,200
3,150
8.910
3.850
3,100
42.OOO
3,150
2,500
—
—
—
--
—
500-800
--
120
BODj
120
8.500
3,300
—
-.
—
..
1,800
-_
--
—
—
--
—
-.
--
Uaatewater characteristics (given in ag.lt)
Organic
Chlorides Sul fates Phosphates nitrogen Pesticides and other wastes
50,000 8.0OO — — Phenol and creaol: 10 ppai; chlorophenols and chlorocreaola:
10O ppai' chlorophenoxyacet Ic acids: 100 PPB~
alcohols: 1,000 ppa.
100 20,000 Nil 500 Sodluai: ¥.000 pp«7~Carbaautes: Nil.
7.000 3.000 250 20 Sodiuaj: 6.000 ppai. Parathlon: 20 ppai.
High — — — Endrln: 100-300 ppb.
52,000 -- Low Low 2,4-D: Up to 3,000 ppai. 2,4-Ds 130 ppai Is typical.
Carbaryl: 0.1-1.0 ppai.
Chlordane: 400 pp>. Sodluai Hydroxide: 20,000 ppai.
Araenlc: 0.7-0.8 ppai.
Phenolic aaterUla: 800-900 ppai.
Sodluai aulfate, aunganeae aulfate, and aodluai trlthlocarbasMtea
combined: 9 lb/13 Ib aaneb product.
Endrln: 100-1,500 ppb; 700 ppb avg; carbon tatrachlorlde: 400
ppai; hcxachloronorbornadlene: 30-50 ppb; baptachloronorbor-
nene: 30-50 ppb.
Toxaphene: < 6 to 2,200 ppb.
6.6 Atrulne: 36 ppai
Wastewater characteristics*/ (Riven In s«/I)
Total solids Total Total r<»lri«hl
TOC OIL Suspended!/ Dissolved Phenol phoaphorus Chloride MH3-M nitrogen Metal
550 3 48 1,550 0.5
3.580 0.5
8,000 4,300 100 115,000 200.0
10
450
198
»« <•• a»B alv va» a> • A
603 6 10 733 0.03
7,130 -- 51 2,260
210,000 — 6.900 147.000
9.420 — 304 6,500
49.800 -- 770 33,000 5,300
58,500 — 1,170 44,000 20.200
16.600 — 115 5.700
125,000 -- 4,260 75.000
19.250 -- 1,930 700 2,200
-------
Table 0-2 (coatlnuad)
Uaatawatar characteristic*!/ (given la at/l)
... ltot*Ji Uaate»at«r flow
P«tlclda£' t^pii' ((al/l.OOO lb product) COD
P
Q
R
s
T
U
V
u
X
Y
Z
AA
BB
S
Oruito-nltroiten
CC
DO
n
rr
CG
HB
II
JJ
n
LL
IM
m
00
»
QQ
ML
ss
XT
CC
mi
w
Hetallo-organlc
WW
XX
YY
H 5
H 5
H 5
H
H 1
H 3
H
H
• 2
H 8
U 1
U 2
H 5
H
H 10
H 5
H 5
H 5
H 1
H
4
6
H 1
2
6
4
a «
5
U
12
H 5
U 1
U 11
U 10
H 7
H 8
U 32
,950
,140
,150
333
,530
,760
64O
179
.530
.MO
,780
.400
.510
333
,2OO
,180
.400
,700
.200
670
.300
.000
.210
500
.400
,200
.000
.250
,250
,000
.500
.400
.200
.600
.800
.590
,000
,900
2.160
3.600
4.100
19.700
6.100
--
-.
—
~
--
335
15,600
4,240
12.500
4,740
1,480
..
—
800
—
6.030
3.900
14.300
7,150
2.650
770
1.800
1,680
15,100
8,000
15,000
14.000
8.100
2.300
2.300
2,200
1,500
450
Total aollda
•OOj
—
—
540
--
—
--
—
«
--
135
1.350
955
--
..
—
820
840
300
--
—
—
—
—
—
350
750
«9S
11,400
5,600
11,500
2,400
2,500
1,155
1.160
790
670
22
TOC oil Suap«ndadi/
..
..
1,700
.-
..
—
..
—
.-
..
108 10
3.850 20
934 59
6,830 7.200
__ »•
.-
—
—
.-
—
—
„
—
..
—
__
.-
—
..
—
..
5.200 0.5
4.200 9.0
420
420 81
-.
..
77 16
„
—
—
—
--
—
—
—
—
--
73
55
15
36
— _
—
..
—
—
--
—
—
—
—
--
„
—
—
--
—
—
1.845
200
10
11
3.170
1.645
3.300
Oiaaolv«d Phenol
19
86
41
54
14
79
44
6
19
36
20
57
38
2
2
29
340
255
.000 0.3
.000
..
..
..
.-
—
-_
.500 0.6
.OOO 0.5
.800 11
,000 36
.300
.400
.900
,700
,000
—
—
—
—
—
—
--
.-
—
.-
--
--
.300
.800
.000
.000
..
.700
Total
phoaphorua
...
--
210
19.000
—
--
—
—
--
--
2
2SO
610
2.150
_.
--
178
190
--
—
--
—
—
~
--
—
—
--
~"
-•
—
1.640
250
—
••
.i-
--
— •
Chlotlda
„
'
6.900
~
—
—
«
—
—
«
—
74,000
~
—
13,700
4,400
18,800
25,300
450
—
6,600
2,500
23,000
—
3,900
..
—
--
•-
--
--
—
2,600
—
••
--
--
"
Total rjcldahL
MHl-H nttiot«* Itetal
..
—
--
—
—
—
--
--
--
--
2
850 13
630 9,400
250
318
—
—
—
13
—
2,100
288
1,500
—
80
—
—
--
~~ "•• ~~
— -™ •-
—
67
250
1 .020
910
715 (Mn)
450
737 843 1.350 (M)
-------
Table D-2 (concluded)
Dote: Dash (—) Indicate* data not available, or data not determined.
a/ Source: Gruber (1976). Data taken fro* analysis of one plant.
b/ Source: Atkins (1972). Ihe data given are reported at "typical" waste stream, and do not represent analyses frosi any particular plant or plants.
c/ Source: von Rmfeer, et el. (1974).
d/ Source: Miners, et al. (1976).
•/ Source: Hslners, et al. (1976).
If Source: Reference Ho. 13. Section 3. See Table D-7
£/ Source: Ueston (1975). In the case of Multiple data for a specific pesticide, sure than one plant waa studied.
h/ Pesticide Identification;
A - 2,4-D; dalapon; or 2.4,5-T.
B - POP or sodlusi PCP.
C, D, B - Heptachlor, endrln, or Isodrtn.
F, G - Heptachlor or endrln
H, I, J, K, L, M, H, 0 - Cotmaphos, dlsulfoton, azlnphossnthyl, swthaaldophos, fensulfothlon, fenthlon, dcmton, or •ethyl deaeton.
P, Q, R - Parathlon, aethyl parathlon, or Nlran 6-3.
S - Composite of cblorpyrllos, crufo«ate, and ronnel.
T - Composite of Methyl parathlon and Aspon.
U, V, H, X - Sterofos, neviphos, naled, or dlchlorvos.
T - Composite of fonofos, carbophenothlon and bensulflde.
Z - Composite of sterofos, dlchlorvoa, naled, and awvtphoa.
AA - Dlazinon
BB - Composite of cousnphos, dlsulfoton, azinphosawthyl.
CC. DO - Metrlbueln or bencazisjlde.
BB, FF - Atraxlne, alswzlne, propazlna, aswtryne, pronetryne, sUwtryne, sualtol, terbatryne, proaetone, or cyanazlne.
CC - Dlnoseb
Hfl - Butylste. BPTC, vemolste. cycloste, Molinate, or pebulste.
II, JJ, KK, IX, Ml - Alachloiv CUnA, propachlor, butachlor.
MM, 00, PP, QQ, U, SS - Dluron, broMcil, thlrasi, aethosiyl, llnuron, or terbacil.
TT - Atrszlaa
UU, W - Alacblor or propachlor.
HH - Htnganesa dlthlocarbasnte.
XX - Zinc dlthlocarbasnte.
TV - Manganese dlthlocarbasuta.
it Data type la represented as follows: H - Historical plant data.
H - Data obtained by Heston personnel during plant visits via •••pie collection and analyses.
I/ The total suspended solids do not represent swasured data. Instead, the concentrations given are allowable wastewater concentrations proposed by Weston (197S).
-------
Table D-3. RAW WASTEWATER CHARACTERISTICS OF ORGANIC PESTICIDE FORMULATORS
Wastewater
flow rate
1,500-2,000 gpd^/
Wastewater characteristics (given in mg/1)
pH BOD5 COD
-- 483
TOG S.S.
661
TDS Phenol Toxicant concentrations
631 — Arsenic: 37
Remarks
Measured in 1970
D
3,000 gpd^/
2,000 gpy£/
2-5 gpmi/
240 gpd-/
4-7
5.7-6.6
2,4-D: 28.5 to 1,190
2,4,5-T: 3.91 to 162
Malathion: 2.06
Methoxychlor: 0.13
Methyl orange: 34.2
Toxicants: < 1.0
140 ppm total toxicants
Measured in 1972
Runoff plus waste-
water, measured
in 1973
Chlorophenol residues: 0 ppm Measured in 1975
Eptam: 2 ppm (avg.)
Sutan: 1 ppm (avg.)
Ro-Neet: 2 ppm (avg.)
£/ Ferguson (1975).
b/ Monitoring data from Stauffer Chemical Company, Portland, Oregon.
Note: Dash (—) indicates not determined or data unavailable.
-------
Table D-4. NEASUUD UASTEVATER QUALITY OF SELECTED INORGANIC PESTICIDE MANUFACTURERS
• „..
Parameter
Uaatewater Flow
(gat/ton product)
PH
B005
Dissolved aollda
Suipended >olld«
Nllj-N
Sulfate
Chloride
Chroeute
Barlusj
Calclu*
Sodluai
Copper
Iron
O Hagnaalusi
I Manganese
*•* Nickel
Lead
Zinc
Copper
6
Concentration
(•B/i)
N.D.
36,650
59
10
N.D.
16
< 0.5
N.D.
N.D.
N.D.
13
3.6
1.0
0.1
0.1
0.7
1.3
carbonate
11,000
.3-6.5
Trl-baslc
5
01 (charge Concentration
(Ib/ton product) {um.lt)
N.D.
3.398
5.47
0.93
N.D.
1.48
< 0.05
N.D.
N.D.
N.D.
1.21
0.33
0.09
0.01
0.01
0.06
0.12
N.D.
33.400
240
4.800
24,000
3.4
< 0.4
N.D.
N.D.
N.D.
136
38
I.S
0.17
0.9
0.12
1.4
Sod tun chlorate
copper sulfate
7,000
.9-7.0
Plant
1 Plant 2 Plant 3 Avo.
N.D. 2,300 N.D.
6-8 6-10 6.4-7.3 --
Discharge
(Ib/ton product)
N.D.
2,023
13.71
274
1,371
0.19
< 0.02
N.D.
N.D.
N.D.
7.77
2.17
0.09
0.01
O.OS
0.01
0.08
12
240
10
I.S
25
55
N.D.
8
10
100
N.D.
N.D.
N.O.
N.D.
N.D.
N.D.
N.D.
Plant 1
Concentration
N.D.
3,822
216
7
1,700
1,200
N.D.
N.D.
400
1,000
N.D.
N.D.
N.D.
N.D.
N.D.
N.D.
N.D.
6.7
952
14
6.8
42.3
276
N.D.
N.D.
118
142
N.D.
N.D.
N.D.
N.D.
N.D.
N.D.
N.D.
9.35
1,671.33
80.0
5.10
589.1
510.33
N.D.
8
176
414
N.D.
N.D.
N.D.
N.D.
N.D.
N.D.
N.D.
12.73
254.47
10.62
1.59
26.47
58.24
N.D.
8.47
10.59
105.88
N.D.
N.D.
N.D.
N.D.
N.D.
N.D.
N.D.
Plant 2
Plant 3
--
Discharge
(Ib/ton nroduec)
N.D.
217.04
12.27
0.40
96.59
68.18
N.D.
N.D.
22.73
56.82
N.D.
N.D.
N.D.
N.D.
N.D.
N.D.
N.D.
8.52
960.2
17.90
8.69
54.08
352.84
N.D.
N.D.
150.85
181.53
N.D.
N.D.
N.D.
H.D.
H.D.
N.D.
N.D.
10.63
477.24
13.60
3.56
59.06
159.75
N.D.
8.47
61.39
114.74
N.D.
N.D.
N.D.
H.D.
N.D.
N.D.
N.D.
Source: Pettarcoa (1*7)).
Note: N.D. ••••• not determined.
-------
Table D-5. ORGANIC PESTICIDE HAMIFACTUIteftS• AND FOaMULATORS' FINAL WASTEUATER
EFFLUENT QUALITY MEASURED AFTER TREATMENT
Uaateuater effluent quality data
Pesticide Category
Halogenated organic
Manufacturer
Organo-pnoaptaorua
Manufacturer
Organo-pho aphonia
Manufacturer
Organo-pbosphorus
Manufacturer
1 Organo-phosphorus
CO Manufacturer
Orgaao-phospborua
and organo-nltrogen
Manufacturer
Natal lo-organtc
Manufacturer
Foraulator
Data
type--'
P.V.
H.R.
H.R.
H.R.
P.V.
H.R.
P.V.
H.R.
P.V.
H.R.
P.V.
H.R.
P.V.
H.R.
1005
(Msi/l1)
12
7
50
..
110
80
130
36
20
a
12.3
2
.-
9
COD
(•»/!)
__
189
--
272
678
575
390
146
--
--
72.1
107
202
60
TOC
(•«/<)
._
34
--
187
92
106
..
39
-.
--
..
33
10
32
Oil S.S
(MK/I) (MK/1)
60
3.7
25
38
0.0
0.5 42
175
3^0 3
..
19
20.5
5.1 21
..
0.5 216
Phenol
(•«/*)
_ _
0.050
0.50O
0.005
..
0.020
_.
0.016
--
0.066
.-
0.016
—
0.002
Total phosphorus
(MK/I)
__
0.52
--
24
106
8.0
65
1.7
-.
0.5
--
0.36
..
0.42
Total Kjeldahl nitrogen
(MK/1)
„
9.8
—
0.65
1.1
4.8
__
3.6
..
24.6
19.9
25
—
6.2
Cyanide Heavynwtala
(•K/i) (MK/1)
0.37
--
-. -.
0.02
- - --
0.02 00
--
0.02
0.7(Nn)
0.028 0.6(Hn)
-.
0.02
Type of treatment
Trickling filter/
activated sludge
LUw precipitation
Activated iludge
Aerated lagoon
Alkaline hydrolyala/
oil separation
Cyanide reMovil/
aerated lagoon
Netala precipitation/
aerated lagoon
Oil aeparatlon/
aerated lagoon
Source: Roy P. Ueaton, Inc. (1975).
a/ H. R. are data obtained fro* historical records of the plant.
P.V. are data obtained by plant via It and aaaaplea analyala perforated by Roy F. Weaton, Inc., paraonnel.
Note: Dead (--) Indicates data not available.
-------
T.bl. 0-6. SOtlD UASTtS GKHEKATID BY PESTICIDE MANUPACTUREU AND POMUUTOIS
O
t
vo
Peatlcldc
Aldrln* Manufacture
Captan*- Manufacture
DD1P Manufacture
2,4,5-T5 Manufacture
Organophoaphorua£' Manufacture
Toxapttene£ Manufacture
Organophoaphorue£'
Halogenated organic^/
Organo-nltrogenS'
Hetallo-organlcd/
Fonulatora^^
Entire organic peatlclda£'
Manufacturing Induatry
Entire organic peatlcldci*/
femulating Induatry
Type of pollutant
Ca(OH)2
Chemicals
Enpty container*, bag*, etc.
Phenolic waatea
Sludge
Sludge (aoatly Haw)
Toxaphene
Sludge
Sludge
Sludge
Sludge
Sludge
Total discharge
Haiardoui waata atreaaia
Hazardou* coayonenta
. Highly Dangeroua coaa/onenta
Total dlacharge
Hatardoua waate atreaaa
Hasardoua component§
Highly dangeroua coaponenta
Lb pollutant/lb pesticide (A.I.)
0.202
0.331
0.297
0.109
0.068
0.0033 Ib/lb/product
0.0033 Ib/lb/product
0.0013 Ib/lb/product
0.0008 Ib/lb/product
a/ Lawlaaa, at al. (1972).
b/ Atklna (1972).
c/ Nelnera, at al. (1976).
d/ We*eon (1975).
£/ Cruber (1976). Eatlaiatea are for 1973. Amount• of pollutant* are given on a water-free beala.
Unit* pollutant/unit time
1,200 Ib/year
10-15 cu yard/day
50-75 Ib/month
300 Ib/day
7.5 ton/day
3 Ib/day
2,400-24.000 Ib/day
1,200 Ib/day
2,160-14,900 Ib/day
5.140 Ib/day
200 Ib/day
170,953 Metric tons/year
153,233 Metric tona/year
56,160 Metric tona/year
35,315 Metric tons/year
4.159 Metric tona/year
4,159 Metric tona/year
1,683 Metric toni/year
1,003 Metric tons/year
-------
Table D-7. NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM, DISCHARGE MONITORING REPORT - ATRAZINE
ClfU-GCIGr CORPORATION
MH 0 C MCINTYHf
P 0 HOX 11
ST GABRIEL LA 70776
•'
i'"tt '•!• '
'J :Tf INSTRUCTIONS
LA
51
| L*OOOS*flf
1 rtmurm>»mt» J
REFOftTING PERIOD FMOM
301
Oil
tao-aii
7,6
YEAR
WC
0,3
HU
°li
DAT
1
1 LATITUDE
'A*
THRU
LOHCITUOt
tac-zri ijv-ni IK-BII
7,,
YEAH
0
j
MO
3|1
DAY
I. Pro.id. d*t« for period ca.ered by Ihi. report U apacea ••iked "REPORTING PEKIOD"
1. Caler reported .InHnum. aveiafe and .«<..« nlaea under "QUANTITY" -nd "CONCENTRATION"
la »e uaita apecitted for each parameter •• appropriate. Do not enter containing
aaleriak* "AVERAGE" U »era(e computed o«ei actual thae dlicharce i> operatiac, "MAXIMUM"
and "MINIMUM" are eilrame vdrnl obwmd doriaf the raponiai period.
iber of analyzed aaaiplat IWI ««ceed (be Mmum C«>d/or mJainnaa ae appropriare)
4. apccify frequency of eaalyali for each parameter aaNa. aaaly*e«/No. data, fe , . "3/7" if «ouiva-
lanl to J analr>e« parfenneif ererr 7 d*rt.) If continuous enter "OONT."
S. Specify >aa>ple lypef "frfb" or " fir. ooaxw'te") ai applicable. If frequency »•« coatinuoui.
eater "HA".
6. Appropriate •lenalure U required on hotloai ol Ikla foiav
7. Reinove carbon and reuin copy for your lecorda.
1. Fold along dolled line*. Maple and mall Ordinal to office ajiecified In penult.
l*4-»l I,,-701
I
IfJ
PAKAMCTEH
Flow
TOC
^
BOD
4
COO
TSS
I
AjMonla-N
Tuanitip
lyamue
r^rbon Tetrachlorlde
COHCMTIOM
NCPOMTCD
PCM4IT
CONCMTIOM
MCPOItTKD
f>CMM*T
CONCMtlON
f*«t»OKTIO
PftPtMl T
CONDITION
MCFOMTCO
PCMMIT
CONDITION
MCPOMTCO
PCHMIT
COHDt TIOM
PCMMIT
CONDITION
MCFOflTCD
PCIiMIT
NAME Of •BIMCIPAL EKECUTIVt OFflCEB
Mincy. John W.
j c~tfo-.fr> QUANTITY
(W -«^> t.W-111 !••>
MIHIMUM
1.9
N/A
734
N/A
460
N/A
1854
N/A
856
N/A
4
N/A
0.2
N/A
3
N/A
AVEHAOE
2.8
N/A
3484
10.000
1324
3130
9766
16.000
2,794
18.000
153
1.100
0.2
3.0
5
50
• II »«-*»
* MAXIMUM
4.
3
N/A
6425
15.000
3513
4695
17.309
24.000
5,805
27,000
631
1.650
0.5
4.
5
9
75
TITLE or tHEorricEH
Plant Manatjer
kf«.«fl.W-ll»^4
UHITI
HGO
Ibs/day
Ibs/day
Ibs/day
Ibs/day
Ibs/day
Ibs/day
Ibs/day
DATE
76 0
YIAK
1 «.lUL
MO DAY
MO.
EX
0
0
0
0
0
0
0
f«««M«"W CONCENTRATION
IM-4B IM-IX l,«-<»
MINIMUM
*
>
AVERAGE
MAXIMUM
<•*-•«
UNITS
r carter 0UU 1 •• lumlllti will Ae fnfbnafian coaMMW la «>•
rajwrl aarf »«( to Me fcr./ of «r tooled*. Md baHaf Mien fnfor-
Mffaa I • (rue. coMpfe,., and aerunMa, /
1 ^
HO.
ex
-•"—
FREQUENCY
OF
ANALYSIS
Cont.
»
Dally
Daily
1M
1/wk
Dally
n
H
H
H
H
H
M
H
U
SAMPLE
TYPE
Record
M
24-hr comr.
24-hr comj
24-hr com
24-hr coni|
24-hr comf
»
H
II
H
H
»
H
H
H
/],y /& MK,^, ^~
Ld&L^t.*//f'rns'-7,<^-
-------
Table D-7 (concluded)
L
CI8A-GtIGY COMPOMATION
WM 0 C MCINTYRE
P 0 HOX I 1
ST GABHIEL L* 70776
(!•*
IL71
i«-ie>
LA0005487 I
I PERMIT NUMBCM I
301
REPORTING PERIOD FROM
| LATITUDE
X
1
LONGITUDE
IM-MI l».»l 110 III
7(ft
YEAN
0
3
MO
3|1
DAY
.
I. Provide detei for period covered by fell report la epeces marked "REPORTING PERIOD"
J. EnUl reported sUnimuB. nverate a»d ••>!•«• »lue* wider "QUANTITi— end "CONCENTRATION"
I. Ike unit. •POCined far «.ck parameter .. appropriate. Do r»l ealer .elue. In bo.e. contain,.,
••Intake. "AVERAGE" It »<•>•«• computed over actual line dUckerce I. operettac. "MAXIMUM"
and "MINIMUM" ere eitrerae values observed dorimj Ik* reporting period.
1 Specify the number of tn.lyicd .mplet Out eueed the neilenn fend/or minimum „ eppnprtefe)
penlt condition* In Ike column, lebeled "He. E«." If none, enter "O". -WF /
4. Specify frequency of eaelyeli for eech peremeler n* Ho- enely»ee/No. deye. f«.». "J/r" /. «u|r^
len« lo 3 tamlymtm peilomed e»ery 7 rf«r« ) If conUrmoul enter "COHT."
5. Specify Miple type f "into" or " hi. conpoeile") •• eppliceUe. If frequency w.. conllnuoue.
enter If A .
6. AppropriMe >lpi«ture In required on bottom of dill form
7. Remove cerbon end retain copy for your records.
S. Fold along dotted lines, eteple end e»ll Orl.in.l to office specified In permit.
Toluene
Atrazine
Temperature
CONDITION
NCPOtlTtD
*>CMMf T
CONDITION
««**OMrco
COMfMfiON
CONtMllOM
CONOl 1*0*4
»»CMM*T
CONCMTION
•*f**OHTCD
**(MM*T
•ifontro
•••iitMi r
r o**o» T.o**
iAMf or i*p.iNrii»At iirctuTivff orricrn
.r>c>. John tf.
nittr MI
f J c-r<* only> QUANTITY
«••«•> l4*-«tl i«4-«l> »a.
MINIMUM
12
N/A
469
N/A
._..
TITlf O
Plant Htntq
AVERAGE
43
200
828
1300
. ._ . _
r TMI or net*
*r_ , . .
TlfLI
MAXIMUM
197
300
1559
1950
. .._.
•- — -
7l£
-
UNITS
Ibs/day
Ibs/day
-----
OATC
o h Iz 17
MO O*»
HO
EX
0
0
-
-
(•« can! onlrj CONCENTRATION
MINIMUM
- -
AVERAGE
MAXIMUM
31
41
-
UNITS
°c
— —
N
E
0
FREQUENCY
OF
ANALYSIS
Dally
U
H
II
I/Day
M
.
SAMPLE
TYPE
24-hr conJ
H 1
II
M I
Grab
H
I certify Aa/ 1 aai Ifmlllmi wlllt (fte /ntoanaMcui ronlarnerf In */• 1 //./ /J-S ''??} 1 \
«t>»rl and /*•< la Ike •»«( ef err >noiHr4(e and *•//•/ «««* lalofyf^JSf'ft^^t ,'^rVa'a~1 r^i^3 Ji I
maHfef«, and ecru>a
-------
Table D-8. NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM, DISCHARGE MONITORING REPORT - HERBICIDES
a
la
Monsanto Company
P. 0. Box 473
Muscatine, Iowa 52761
.*.«. .... North _Wes_t_ _ J
0000205 ' 281&' Jtl020'59"T9iOQ4'i8"^
»• , we
L A TITtiOC I LONCI TUOC
O.T,«.,,OD ,«- 7jJ)l7_QjJ ro J7.5Jl'2;3i;
VIA*! HO 0«Y
INSTRUCTIONS
I P«*v.4« *M«S tot p«m*tf tovwe.fi bf ttua *«p«it M »»*c*» »Mfc*«J "REPORTING PERIOD"
2 E»l*f r*po«*>*J •.•>.• i»-». •»•*-•«• *M*J **«••... «•!.»«• M*4«* "QCIAMT1TV" M*J "CONCKMT.tAT.OM"
>• tt.* imii* ***c.l.*«J fc" *«* pMM««r as .pfropri..* DO •»! •»!« *•!«•• w .»••• CMIMMM
oiivn.*... "AVERAGE" i» •«*r*f« co*»puie«i ev«t •ciu«l u.*« •••'*••
1 j i.«««^r. QUANTITY
j i r««AMtr«» .
1 1 WmiMUM AVKHACI ' MAXIMUM j UMlTft
j i «-o.,.o 6.202 7.319, 8.687 i
j i Flow /c o'nccft TITLC or TM« orriccit j OATB
>£%7 j,^^ ^v i^^.^^^.]^]^
|f4 CMtf Mir)
' «0
-
1
47
CONCENTRATION
««•*»• «*••!.
i " .
'194 ': 370
.;
1 158
0.5
r
b
1
i
25
395 976
5.30 17.7
L US ; 199
w
mil J^
PPM
1
1 PPM
1
PPM
: i PPM
3.2 j 8.2 49.1
f cwiilr «M / •*• <*M<
•»*«• 1* MMb MBplMBj
l_ I
j
i
j
i
M»tmr mmmwtmmtm tut *»••» «Kk i
PPM
*M<
*>•«•
ANALYSIS
SAMPLI
TTPi
I/day NA
i
I/day t?4 hr co
I/day t?4 hr co
' I/day 24 hr co
H
;
I/day (24 hr co
I/day
1
. I/day
24_hrc«
NA
'7kPl^d*Q Clftfe.
llutATUmtOt pknOPAL (IIICVTIVC
or rice* on MITMOWKO *ccitt
»P
'P
IP
..P
h
»>*c«
-------
REFERENCES TO APPENDIX D
1. Atkins, P. R. The Pesticide Manufacturing Industry - Current Waste Treat-
ment and Disposal Practices. 12020 FYE 01/72, January 1972.
2. Ferguson, T. L. Pollution Control Technology for Pesticide Formulators and
Packagers. EPA-660/2-74-094, U.S. Environmental Protection Agency, January
1975.
3. Gruber, G. I. Assessment of Industrial Hazardous Waste Practices, Organic
Chemicals, Pesticides, and Explosives. EPA Contract No. 68-01-2919, January
1976.
4. Ifeadi, C. N. Screening Study to Develop Background Information and Deter-
mine the Significance of Air Contaminant Emissions from Pesticides Plants.
Batelle Report on Task 12, Contract No. 68-02-0611, March 5, 1975.
5.. Lawless, E. W., R. von Rumker, and T. L. Ferguson. The Pollution Potential
in Pesticide Manufacturing. OWP/EPA Technical Studies Report No. TS-00-72-04,
June 1972.
6. Meiners, A. F., C. E. Mumma, T. L. Ferguson, and G. L. Kelso. Wastewater
Treatment Technology Documents for Aldrin/Dieldrin, Endrin, Toxaphene, and
DDT Manufacture and Formulation - four volumes. EPA Contract No. 68-01-3524,
February 6, 1976.
7. Patterson, J. W. State-of-the-Art for the Inorganic Chemicals Industry:
Inorganic Pesticides. EPA-600/2-74-009a, U.S. Environmental Protection
Agency, March 1975.
8. von Rumker, R., E. W. Lawless, and A. F. Meiners. Production, Distribution,
Use and Environmental Impact'Potential of Selected Pesticides. EPA-540/1-
74-001, U.S. Environmental Protection Agency, 1974.
9. Western, R. F., Inc. Development Document for Effluent Limitations Guide-
lines and Standards Performance - Miscellaneous Chemical Industry. Draft
Report, EPA Contract No. 68-01-2932, February 1975.
D-13
-------
APPENDIX E
U.S. ENVIRONMENTAL PROTECTION AGENCY REGIONAL CONTACTS
E-l
-------
Region I
Administrator
Air Division
John A. S. McGlennon
J. F. Kennedy Federal Building
Boston, MA 02203
(617) 223-7210
Lawrence M. Goldman, Chief
Air Compliance Section
J. F. Kennedy Federal Building
Boston, MA 02203
(617) 223-5610
Water Division
Solid Waste Division
Pesticides Branch
Lester A. Sutton, Director
J. F. Kennedy Federal Building
Boston, MA 02203
(617) 223-2226
Dennis Huebner, Chief
J. F. Kennedy Federal Building
Boxton, MA 02203
(617) 223-5775
A. Charles Lincoln
J. F. Kennedy Federal Building
Boston, MA 02203
(617) 223-5126
Region II
Administrator
Air Division
Water Division
Gerald M. Hansler
26 Federal Plaza
New York, NY 10007
(212) 264-2525
Stuart Roth
Air Enforcement
26 Federal Plaza
New York, NY 10007
(212) 264-4711
Charles N. Zursor, Chief
26 Federal Plaza
New York, NY 10007
(212) 264-1833
E-2
-------
Region II (concluded)
Solid Waste Division
Pesticides Branch
Michael F. DeBonis, Chief
26 Federal Flaza
New York, NY 10007
(212) 264-0503
Stanley H. Fenichel, Chief
26 Federal Plaza
New York, NY 10007
(212) 264-8356
Region III
Administrator
Air Division
Water Division
Solid Waste Division
Pesticides Branch
Daniel J. Snyder
Curtis Building
6th and Walnut Streets
Philadelphia, PA 19106
(215) 597-9814
John Rasnic
Air Compliance
Curtis Building
6th and Walnut Streets
Philadelphia, PA 19106
(215) 597-0812
Greene Jones, Director
Curtis Building
6th and Walnut Streets
Philadelphia, PA 19106
(215) 597-9410
Charles Howard
William Schremp, Representatives
Curtis Building
6th and Walnut Streets
Philadelphia, PA 19106
(215) 597-8114
A. Nelson Davis, Chief
Curtis Building
6th and Walnut Streets
Philadelphia, PA 19106
(215) 597-9869
E-3
-------
Region IV
Administrator
Air Division
Water Division
Solid Waste Division
Pesticides Branch
Region V
Administrator
Air Division
Water Division
Jack E. Ravan
1421 Peachtree Street, N.E.
Atlanta, GA 30309
(404) 526-5727
James Wilburn
Air Enforcement
1421 Peachtree Street, N.E.
Atlanta, GA 30309
(404) 526-5291
Joseph Franzmathes, Director
1421 Peachtree Street, N.E.
Atlanta, GA 30309
(404) 526-5727
James Scarbrough, Head
1421 Peachtree Street, N.E.
Atlanta, GA 30309
(404) 526-3016
Roy P. Clark, Chief
1421 Peachtree Street, N.E.
Atlanta, GA 30309
(404) 285-3621
Francis T. Mayo
230 South Dearborn Street
Chicago, XL 60604
(312) 353-5250
Thomas Voltaggio
Engineering Investigation
230 South Dearborn Street
Chicago, IL 60604
(312) 353-8730
Henry Longest, II, Director
230 South Dearborn Street
Chicago, IL 60604
(312) 353-1050
E-4
-------
Region V (concluded)
Solid Waste Division
Pesticides Branch
Karl J. Klepitsch, Jr., Chief
230 South Dearborn Street
Chicago, IL 60604
(312) 353-6560
Mitchell Wrich, Acting Chief
230 South Dearborn Street
Chicago, IL 60604
(312) 343-6219
Region VI*
Administrator
Air Division
Water Division
Solid Waste Division
pesticides Branch
John C. White
1600 Patterson Street, Suite 1100
Dallas, TX 75201
(214) 749-1962
Bruce Elliott
Enforcement Branch
1600 Patterson Street, Suite 1100
Dallas, TX 75201
(214) 749-1983
Dr. Richard L. Hill, Director
1600 Patterson Street, Suite 1100
Dallas, TX 75201
(214) 749-1267
Herbert Crowe, Representative
1600 Patterson Street, Suite 1100
Dallas, TX 75201
(214) 749-1121
Norman E. Dyer, Chief
1600 Patterson Street, Suite 1100
Dallas, TX 75201
(214) 749-1121
After August 20, 1976» the new address will be:
First International Building
1201 Elm Street
Dallas, Texas 75270
E-5
-------
Region VII
Administrator Jerome H. Svore
1735 Baltimore Avenue
Kansas City, MO 64108
(816) '374-5493
Air Division Dewayne Durst
1735 Baltimore Avenue
Kansas City, MO 64108
(816) 374-3791
Water Division Carl B. Blomgren, Director
1735 Baltimore Avenue
Kansas City, MO 64108
(816) 374-5616
Solid Waste Division Morris G. Tucker, Chief
1735 Baltimore Avenue
Kansas City, MO 64108
(816) 374-3307
Pesticides Branch John C. Wicklund, Chief
1735 Baltimore Avenue
Kansas City, MO 64108
'(816) 374-3036
Region VIII
Administrator John A. Green
1860 Lincoln Street
Denver, CO 80203
(303) 837-3895
Air Division Robert Despain (Temporary)
Enforcement Branch
1860 Lincoln Street
Denver, CO 80203
(303) 837-4903
Water Division Charles W. Murray, Jr., Director
1860 Lincoln Street
Denver, CO 80203
(303) 837-4871
E-6
-------
Region VIII (concluded)
Solid Waste Division
Pesticides Branch
Lawrence P. Gazda, Chief
1860 Lincoln Street
Denver, Colorado 80203
(303) 837-2221
Ivan W. Dodson, Chief
1860 Lincoln Street
Denver, CO 80203
(303) 327-3926
Region IX
Administrator
Air Division
Water Division
Solid Waste Division
Pesticides Branch
Paul DeFalco, Jr.
100 California Street
San Francisco, CA 94111
(415) 556-2320
Charles Seeley
Air Compliance
100 California Street
San Francisco, CA 94111
(415) 556-0970
Sheila Prindville, Director
100 California Street
San Francisco, CA 94111
(415) 556-0893
Charles Bourns, Chief
100 California Street
San Francisco, CA 94111
(415) 556-4606
Jake Mackenzie, Chief
100 California Street
San Francisco, CA 94111
(415-556-0217
E-7
-------
Region X
Administrator Clifford V. Smith
1200 6th Avenue
Seattle, WA 98108
(206) 442-1220
Air Division Clark L. Gaulding, Chief
1200 6th Avenue
Seattle, WA 98108
(206) 442-1387
Water Division Robert S. Burd, Director
1200 6th Avenue
Seattle, WA 98108
(206) 442-1237
Solid Waste Division Tobias A. Hegdahl, Chief
1200 6th Avenue
Seattle, WA 98108
(206) 442-1260
Pesticides Branch Robert A. Poss, Chief
1200 6th Avenue
Seattle, WA 98108
(206) 442-1090
E-8
-------
APPENDIX F
EPA PESTICIDE PROGRAMS
F-l
-------
This section is devoted to a brief discussion of pesticide-related pro-
grams and was taken from a directory describing federal, state, and local
environmental quality monitoring programs as related to pesticides published
December 1974.I/ More recent activities of the EPA Office of Pesticide Pro-
grams related to regulatory actions and policy are described in Section VI*
The Environmental Protection Agency, since its creation in 1970, has
participated in the cooperative, interagency National Pesticide Monitoring
Program. At the present time, the Agency is operating five of the nine am-
bient pesticide monitoring networks* The networks for soil and raw agricul-
tural crops, water, estuaries, and human tissue are currently operational*
The Air Monitoring Network was operational for 2 years, but instrumentation
difficulties forced the suspension of this program*
The following represents a summary of federal programs that cooperate
in the National Pesticide Monitoring Program*
National Air Monitoring Program: This program was established in 1970
to detect pesticide residues in air. Because of technological difficulties,
this program was suspended in 1972 until further field evaluations could be
made. Upon completion of this study, the National Air Monitoring Program
will be redesigned and reinstituted.
National Estuarine Monitoring Program: The objective of this program
is to determine the presence or absence of persistent pesticide residues,
establish baseline residue levels and detect trends. The program involves
the semiannual collection of composite samples of herbivorous and carniv-
orous fish from 113 estuaries in the United States, the Virgin Islands and
Puerto Rico. Samples are collected through contracts and voluntary assistance
by state and university personnel*
National Water Monitoring Program: Since 1973, the program has been
jointly sponsored by the U.S. Geological Survey which collects the samples
and the U.S. Environmental Protection Agency which analyzes the samples.
The 162 station network is designed to sample surface waters and sediment
in order to establish baseline residue levels and changes thereof. Water
samples are collected quarterly with sediment being collected semiannually.
National Soils Monitoring Program: The National Soils Monitoring Pro-
gram was designed to determine average levels of pesticide residues in soils
and agricultural crops in the United States and through periodic sampling,
to determine changes in these levels. Two land-use categories are recognized:
cropland and noncropland. One-quarter of the allocated sites in each state
are sampled every year. At the time of harvest, soil and crop samples are
collected at each site. Data on the crop and the kinds and amounts of pes-
ticides applied to the site that season are also collected*
F-2
-------
National Ocean Monitoring Program: The objective of this oilot-
was to identify persistent, synthetic residues in coronercial fish sl
and those intermediate in their food chain. This co
NOAA fenced in 1974 and collections were made in
grounds of the American fleet in the Atlantic, Caribbean and plcifif *
NOAA collects the fish samples utilizing the LA**,! H Pacific areas.
of the National Marine ''
revie"ed
thl. laboratory is part of the
th. rs rabushed in
dences of exposure to pesticides In thf lnclfances' levels> »d <"*« =vi-
The «a]or operational element" the ^o86"'1 il,f fuU"°" o£ «>« «»".d State,,
analyzes it for some 17 orw^ln™?? ^ "' """"^ USSUe a"d
phenyls. Pathologists are rec^i ^ acCordi^ t" ^ *°l?M°«™'* «-
take adipose tissue sables from post ^rt^ T exp«lmen"1
specimens previously submitted for pattolo^ 'f1""10"3 ^d £
fro«n and shipped under dry ice to t^ c^^'ff Mtl0n- Sam!>Us "'
analysis. contract laboratory for residue
National Food and Teed Monitoring Programs- Th.=
tained by the U.S. Department of Agriculture^ J n Pr°8ralM a" mai"-
Education, and Welfare. Programs emma^LT Department of Health,
a continuing Mrket basket Ldy to"et ™ine rLid %"" lnClUdeI U)
diet of a 16 to 19-year-old male ( staUstTcatlyM *? b"iC 2-
(b) nationwide surveillance of unprocessed food and
£or
Pesticide Monitoring in Wildlife: The Bureau of Snort w u ,
Wildlife, U.S. Department of Interior, is responsible for FiSheries and
programs. Species selected for monitoring include the starlinT"^^*/11
and black ducks, and the bald eagle. Starlings, *.*£^Sl£l£*.
tory species, are collected from 128 sites across the count™ in i?8™
years. Duck wings, from mallard and black ducks, are available £ot T**
ing purposes as a by-product of a nationwide waterfowl productivS
in which cooperative hunters mail thousands of wings to central col
points for biological examination. The bald eagle is included L
tional program because of its unique position at the top of estuarin!
chains. Since this species is rigidly protected by law and the population
levels are low, the only birds utilized for analysis are those found dead n
incapacitated and beyond recovery.
F-3
-------
National Fish Monitoring Program: The Bureau of Sport Fisheries and
Wildlife also monitors freshwater fish at 100 locations in the continental
United States. Each year composite samples of each of three species of fish
are collection at each location*
REFERENCE TO APPENDIX F
1. Scotton, J. W., K. T. Mullen, J. Whitman, and R. Citron. Directory of
EPA, State, and Local Environmental Quality Monitoring and Assessment
Activities. National Technical Information Service, U.S. Department of
Commerce, Springfield, Virginia, PB-214 757, December 1974.
F-4
-------
APPENDIX G
STATE ENVIRONMENTAL AGENCY CONTACTS
G-l
-------
STATE ENVIRONMENTAL OFFICES
Alabama
Air Division
James W. Cooper, Director
Air Pollution Control Commission
645 South McDonough Street
Montgomery, Alabama 36109
(205) 834-6570
Water Division
James W. Warr
Chief Administrative Officer
Alabama Water Improvement Commission
State Office Building
Montgomery, Alabama 36130
(205) 277-3630
Charles R. Horn
Alabama Water Improvement Commission
Industrial Waste Control
State Office Building
Montgomery, Alabama 36130
Solid Waste Division
Alfred Chipley, Director
Division of Solid Waste and Vector Control
State Health Department
State Office Building
Montgomery, Alabama 36130
(205) 832-6758
Agricultural Chemistry Division
John H. Kirkpatrick, Director
Division of Agricultural Chemistry
Department of Agricultural and Industries
P.O. Box 2336
Montgomery, Alabama 36109
Alaska
Air Division
Thomas R. Hanna, Supervisor
Air Quality Control
Alaska Department of Environmental
Conservation, Pouch 0
Juneau, Alaska 99811
Water Division
Jonathan W. Sribner, Director
Division of Water Programs
Alaska Department of Environmental
Conservation, Pouch 0
Juneau, Alaska 99811
Ronald G. Hansen, Chief
Water Quality Control Section
Alaska Department of Environmental
Conservation, Pouch 0
Juneau, Alaska 99811
Terrestrial Programs Division
Dale Wellington, Director
Division of Terrestrial Programs
Alaska Department of Environmental
Conservation, Pouch 0
Juneau, Alaska 99811
Pesticides Division
Richard Stokes, Supervisor
Pesticides Branch
Alaska Department of Environmental
Conservation, Pouch 0
Juneau, Alaska 99811
(907) 465-2635
G-2
-------
Alaska
Extension Service Division
Peter Probasco
Alaska Cooperative Extension Service
Palmer Community College
Palmer, Alaska 99645
Agriculture Division
William E. Burgoyne, Ph.D.
Division of Agriculture
Alaska Department of Environmental
Conservation
P.O. Box 1088
planter, Alaska 99645
SPA Region X Representative
Stanley Brust
EEA Region X
605 W. Fourth Avenue
Anchorage, Alaska 99501
Arizona
Air Division
Nils Larson, Chief
Bureau of Air Pollution Control
Arizona Department of Health Services
Division of Environmental Health
1740 West Adams St.
phoenix, Arizona 85007
(602) 271-5306
Water Division
Ronald Miller, Ph.D., Acting Chief
Bureau of Water Quality Control
Arizona Department of Health Services
Division of Environmental Health
1740 West Adams St.
phoenix, Arizona 85007
(602) 271-5455
G-3
Arizona
Solid Waste Division
John Beck, Chief
Bureau of Sanitation
Arizona Department of Health Services
Division of Environmental Health
1740 West Adams St.
Phoenix, Arizona 85007
(602) 271-4641
Arkansas
Air Division
Jarre11 Southall, Chief
Air Division
Arkansas Department of Pollution
Control and Ecology
8001 National Drive
Little Rock, Arkansas 72209
(501) 371-1136
Water Division
Hugh Hannah, Chief
Water Division
Arkansas Department of Pollution
Control and Ecology
8001 National Drive
Little Rock, Arkansas 72209
(501) 371-1701
General Office
Solid Waste Division
Ray Hightower, Chief
Solid Waste Division
Arkansas Department of Pollution
Control and Ecology
8001 National Drive
Little Rock, Arkansas 72209
(501) 371-1701
General Office
-------
California
Colorado
Air Division
William H. Lewis, Jr., Executive Officer
California Air Resources Borad
1709 - llth Street
Sacramento, California 95814
(916) 322-2892
Water Division
Bill B. Dendy, Executive Officer
California Water Resources Control Board
P.O. Box 100
Sacramento, California 95801
(916) 445-9490
Solid Waste Division
Albert Marino, Executive Director
Solid Waste Management Board
Resources Building Room 1335
1416 North Street
Sacramento, California 95814
(916) 322-3330
Agricultural Chemical Division
California Department of Food and
Agriculture
Division of Inspection Services
Agricultural Chemicals and Feed
1220 N Street Room A-268
Sacramento, California 95814
Hazardous Wastes D ivision
Dr. Harry Collins, Chief
Hazardous Waste Management Program
Department of Public Health
744 P Street
Sacramento, California 95814
(916) 322-2337
Air Division
A. C. Bishard, Chief
Colorado Department of Health
Air Pollution Control Division
4210 East llth Avenue
Denver, Colorado 80220
(303) 388-6111
Water, Division
Robert J. Shukle, Chief
Colorado Department of Health
Water Quality Control Division
4210 East llth Avenue
Denver, Colorado 80220
(303) 388-6111
Solid Waste Division
Orville F. Stoddard
Colorado Department of Health
Engineering and Sanitation Division
4210 East llth Avenue
Denver, Colorado 80220
(303) 388-6111
Pesticides Registration Division
Robert Sullivan, Chief
Colorado Department of Agriculture
Division of Plant Industry
State Services Building
Denver, Colorado 80220
(303) 892-2838
G-4
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Connecticut
Delaware
Air Division
Henry Beale, Director
Air Quality Division
Department of Environmental Protection
Sate Office Building
Hartford, Connecticut 06115
(203) 566-4030
Water Division
Robert Taylor, Director
Water Quality Division
Department of Environmental Protection
State Office Building
Hartford, Connecticut 06115
(203) 566-3245
Solid Waste Division
Joseph Boren, Director
Solid Waste Division
Department of Environmental Protection
State Office Building
Hartford, Connecticut 06115
(203) 566-5847
Pesticides Division
Director
General Engineering Services
Pesticide Compliance Section
Department of Environmental Protection
State Office Building
Hartford, Connecticut 06115
(203) 566-5148
Air Division
Robert R. French, Manager
Air Resources Section
Department of Natural Resources
and Environmental Control
Edward Tatnall Building
Dover, Delaware 19901
(302) 678-4791
Water Division
Lee J. Beetschen, Manager
Water Resources Section
Department of Natural Resources
and Environmental Control
Edward Tatnall Building
Dover, Delaware 19901
(302) 678-4761
Solid Waste Division
Patrick Canzano, Chief
Solid Waste Section
Department of Natural Resources
and Environmental Control
Edward Tatnall Building
Dover, Delaware 19901
(302) 678-4781
District
Air Division
Water Division
Solid Waste Division
Malcolm Hope, Chief
Office of Environmental Planning
Department of EnviroaMntal
Sciences
415 12th Street, N.W.
Washington, D.C. 20004
(202) 629-4581
G-5
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Florida
Georgia
Air Division
Water Division
Joseph W. Landers, Jr. Secretary
Department of Environmental Regulations
2562 Executive Center Circle
Montgomery Building
Tallahassee, Florida 32301
(904) 488-4807
Solid Waste Division
J. Benton Druse
Department of Pollution Control
2562 Executive Center Circle
Montgomery Building
Tallahassee, Florida 32301
(904) 488-1345
Solid Waste Division
Moses N. McCall, III, Chief
Land Protection Branch
Environmental Protection Division
Georgia Department of Natural
Resources
270 Washington, S.W.
Atlanta, Georgia 30334
(404) 656-2833
Pesticides Division
Ron Conley, Director
Pesticide Division
Georgia Department of Agriculture
Capital Square
Atlanta, Georgia 30334
Georgia
Air Division
Robert H. Collorn, Chief
Air Protection Branch
Environmental Protection Division
Georgia Department of Natural
Resources
270 Washington Street, S.W.
Atlanta, Georgia 30334
(404) 656-6900
Water Division
Gene B. Wesh, chief
Water Protection Branch
Environmental Protection Division
Georgia Department of Natural
Resources
270 Washington Street, S.W.
Atlanta, Georgia 30334
(404) 656-4713
Hawaii
Air Division
Ralph K. Yukumoto, P.E.
Pollution Technical Review Branch
Department of Health
P.O. Box 3378
Honolulu, Hawaii 96801
(808) 548-6410
Water Division
Paul F. Aki, Chief
Water and Air Enforcement and
Monitoring
Pollution Investigation and
Enforcement Branch
Department of Health
P.O. Box 3378
Honolulu, Hawaii 96801
(808) 548-6355
G-6
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Hawaii
Illinois
Solid Waste Division
Dr. James R. Kumagi, Director
State Department of Health
P.O. Box 3378
Honolulu, Hawaii 96801
(808) 548-2811
Pesticide Division
Hawaii State Department of Agriculture
Pesticide Division
1428 S. King Street
Honolulu, Hawaii 96814
Idaho
Air Division
Murray Michael, Supervisor
Air Quality Program
Department of Health and Welfare
Division fo Environment
State House
Boise, Idaho 83720
(208) 384-2390
Water Division
Al Murrey, Chief
Bureau of Water Quality
Department of Health and Welfare
Division of Environment
State House
Boise, Idaho 83720
(208) 384-2390
Solid Waste Division
Howard Burkhardt, Chief
Bureau of Environmental Health
Department of Health and Welfare
Division of Environment
State House
Boise, Idaho 83720
(208) 384-2390
Air Division
Dr. John Reed, Chief
Division of Air Pollution Control
Illinois Environmental Protection
Agency
2200 Churchill Road
Springfield, Illinois 62706
(217) 782-7326
Water Division
James Park, Chief
Division of Water Pollution Control
Illinois Environmental Protection
Agency
2200 Churchill Road
Springfield, Illinois 62706
(217) 782-2027
Solid Waste Division
Rauf Piskin, Chief
Division of Land Pollution Control
Illinois Environmental Protection
Agency
2200 Churchill road
Springfield, Illinois 62706
(217) 782-6760
G-7
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Indiana
Iowa
Air Division
Ralph C. Pickard, Technical Secretary
Indiana Air Pollution Control Board
1330 West Michigan Street
Indianapolis, Indiana 46206
(317) 633-4420
Water Division
Stephen M. Irwin
Indiana Stream Pollution Control
Board
1330 West Michigan Street
Indianapolis, Indiana 46206
(317) 633-5467
Solid Waste Division
Brian Opel, Chief
Solid Waste Section
1330 West Michigan Street
Indianapolis, Indiana 46406
(317) 633-4393
Iowa
Air Division
Dr. Edward J. Stanek, II, Director
Air Quality Mangement Division
.Iowa Deparmtent of Environmental
Quality
3920 Delaware Avenue
P.O. Box 3326
Des Moines, Iowa 50316
(515) 265-8134
Rexford Walker, Chief
Surveillance and Compliance Section
Air Quality Mangement Division
Iowa Department of Environmental
Quality
3920 Delaware Avenue
P.O. Box 3326
Des Moines, Iowa 50316
Water Division
Joseph Obr, P.E., Director
Water Quality Mangement Division
Iowa Department of Environmental
Quality
3920 Delaware Avenue
P.O. Box 3326
Des Monies, Iowa 50316
Solid Waste Division
Peter R. Hamlin, Director
Land Quality Mangement Division
Iowa Department of Environmental
Quality
3920 Delaware Avenue
P.O. Box 3326
Des Moines, Iowa 50316
B. Z. Karachiwala, Chief
Surveillance and Compliance Section
Land Quality Management Division
Iowa Department of Environmental
Quality
3920 Delaware Avenue
P.O. Box 3326
Des Moines, Iowa 50316
Kansas
Air Division
Howard F. Saiger, Director
Bureau of Air Quality and Occupational
Health
Division of Environment
Department of Health and Environment
Building 740
Forbes AFB
Topeka, Kansas 66620
(913) 296-3896
G-8
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Kansas
Kentucky
Water Division
N. Jack Burris, Director
Bureau of Water Quality
Division of Environment
Department of Health and Environment
Building 740
Forbes AFB
Topeka, Kansas 66620
(913) 296-3825
Solid Waste Diviion
Charles H. Linn, Chief
Solid Waste Section
Division of Environment
Department of Health and Environment
Building 740
Forbes AFB
Topeka, Kansas 66620
(913) 296-3821
Kentucky
Air Division
John T. Smither, Director
Division of Air Pollution
Department Natural Resources and
Environmental Protection
Capital Plaza Tower
Frankfort, Kentucky 40601
(502) 564-3382
Water Division
William S. Forester, Acting Director
Division of Water Quality
Department for Natural Resrouces
and Environmental Protection
275 East Main Street
Frankfort, Kentucky 40601
(502) 564-3410
Solid Waste Division
Samuel N. Johnson, Jr., Director
Division of Solid Waste
Department for Natural Resources
and Environmental Protection
275 East Main Street
Frankfort, Kentucky 40601
(502) 564-6716
Pesticide Division
Fred Waters, Director
Pesticide Section
Division of Special Programs
Department for Natural Resources
and Environmental Prtoection
275 East Mina Street
Frankfort, Kentucky 40601
(502) 564-6716
Louisiana
Air Division
Vernon C. Parker, Chief
Air Quality Section
Louisiana State Division of Health
State Office Building
P.O. Box 60630
New Orleans, Louisiana 70160
(504) 527-5115
Water Division
Robert LaFleur, Chief
Water Quality Section
Louisiana Stream Control Commission
P.O. Drawer FC-LSU
Baton Rouge, Louisiana 70803
(504) 389-5309
G-9
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Louisiana
Maine
Solid Waste Division
G. Roy Hayes
Health and Social Rehabilitation
Services Administration
Sate Office Building
P.O. Box 60603
New Orleans, Louisiana 70160
(504) 527-5123
Pesticide Division
Robert Odora
Louisiana State Department of
Agriculture
Baton Rouge, Louisiana
(504) 389-5478
Maine
Air Division
Frederick C. Pitman, Director
Bureau of Air Quality Control
Department of Environmental Protection
State House
Augusta, Maine 04333
(207) 289-2437
Water Division
George C. Gormley, Director
Bureau of Water Quality
Department of Environmental Protection
State House
Augusta, Maine 04333
(207) 289-2591
Solid Waste Dtvi..Hnn
Ronald Howes, Chief
Division of Solid Waste Mangement
Department of Environment Protection
State House
Augusta, Maine 04333
Pesticides
Clayton F. Davis, Director
Inspections Divison
Department of Agriculture
State House
Augusta, Maine 04333
(207) 289-3841
Maryland
Air Division
George P. Ferreri, Director
Bureau of Air Quality and Noise
Control
Department of Health and Mental
Hygiene
Environmental Health Administration
201 West Preston Street
Baltimore, Maryland 21201
(301) 383-2757
Water Division
James D. Clise, Director
Bureau of Sanitary Engineering
Department of Health and Mental
Hygiene
201 West Preston Street
Balitmore, Maryland 21201
(301) 383-2740
G-10
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Maryland
Massachusetts
Water Resources Division
Herbert M. Sachs, Adminstrator
Bureau of Water Resources
Tawes State Office Building
Annapolis, Maryland 21401
Solid Waste Division
Walter A. Miles, Chief
Division of Solid Waste
Maryland State Department of Health
and Mhtal Hygiene
201 West Preston Street
Baltimore, Maryland 21201
(301) 383-2770
Massachusette
Solid Waste Division
Alden Cousins, Director
Bureau of Solid Waste Disposal
Massachusetts Department of
Public Works
100 Nashua Street
Boston, Massachusetts 02114
(617) 727-4293
Hazardous Waste Division
Hans Bonne, Acting Chief
Oil and Hazardous Waste Branch
Department of Natural Resources
State Office Building-Room 1901
100 Cambridge Street
Boston, Massachusetts 02202
(617) 727-3855
Air Division
Gilbert T. Joly, Director
Bureau of Air Quality Control
Division of Environmental Health
Department of Public Health
600 Washington Street - Room 320
Boston, Massachusetts 02111
Water Division
Thomas C. McMahon, Director
Division of Water Pollution Control
Levevett Saltonstall Building
100 Cambridge Street
Boston, Massachusetts 02202
(617) 727-3855
Michigan
Air Division
Lee E. Jager, Chief
Air Pollutior Control Division
Department of Natural Resources
908 D Southland Drive
Lansing, Michigan 48914
(417) 373-7573
Water Division
John Hesse, Chief
Water Quality Appraisal Section
Bureau of Water Mangement
Department of Natural Resources
Stevens T. Mason Building
Lansing, Michigan 48926
(517) 373-2682
G-ll
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Michigan
Mississippi
Solid Waste Division
Fred Re How, Chief
Solid Waste Mangement Division
Department of Natural Resources
Stevens T. Mason Building
Lansing, Michigan 48926
Pesticide Division
Robert L. Kirkpatrick
Plant Industry Division
Lewis Cass Building
Michigan Department of Agriculture
320 S. Walnut Street
Lansing, Michigan 48913
(517) 373-1050
Minnesota
Air Emissions
Edward M. Wiik, Director
Division of Air Qualtiy
Minnesota Pollution Control Agency
1935 West County Road B2
Roseville, Minnesota 55113
(612) 296-7202
Water Division
Louis J. Breimhurst, Director
Division of Water Quality
Minnesota Pollution Control Agency
1935 West County Road B2
Roseville, Minnesota 55113
Solid Waste Division
Robert A. Silvagni, Director
Division of Solid Waste
Minnesota Pollution Control Agency
1935 West County Road B2
Roseville, Minnesota 55113
(612) 296-7315
Air Division
Jeffy Stubberfield, Chief
Air Pollution Division
Mississippi Air and Water
Pollution Control Commission
Robert E. Lee Building
P.O. Box 827
Jackson, Mississippi 39205
(601) 354-6783
Water Division
Charles Chisolm, Chief
Water Pollution Division
Mississippi Air and Water
Pollution Control Commission
Robert E. Lee Building
P.O. Box 827
Jackson, Mississippi 39205
(601) 354-7661
Solid Waste Division
Jack McMillan, Director
Division of Solid Waste Mangement
and Vector Control
P.O. Box 1700
Board of Health
Jackson, Mississippi 39205
(601) 354-6616
G-12
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Missouri
Montana
Air Division
Michael T. Marshall, Staff Director
Air Conservation Commission
Division of Environmental Quality
Department of Natural Resources
P.O. Box 1368
State Office Building
Jefferson City, Missouri 65101
(314) 751-3252
Water Division
L. F. Garber
Assistant to the Director
Water Quality Program
Division of Environmental Quality
P.O. Box 1368
State Office Building
Jefferson City, Missouri 65101
(314) 751-3241
Solid Waste Division
Robert M. Robinson, Director
Solid Waste Mangement Program
Division of Environmental Quality
Department of Natural Resources
P.O. Box 1368
State Office Building
Jefferson City, Missouri 65101
(314) 751-2815
Water Division
Don Willems, Chief
Water Quality Bureau
Environmental Sciences Division
Department of Health and Environment
Sciences
Cogswece Building
Helena, Montana 59601
(406) 449-2407
Solid Waste Division
Terrence D. Carmody, Chief
Solid Waste Management Bureau
Environmental Sciences Division
Department of Health and Environment
Sciences
Cogswece Building
Helena, Montana 59601
(406) 449-2821
Pesticide Division
Terrence D. Carmody, Chief
Environmental Sciences Division
Department of Health and Environment
Sciences
Cogswece Building
Helena, Montana 59601
(406) 449-2821
Montana
Air Division
Mike Roach, Chief
Air Quality Bureau
Environmental Sciences Division
Department of Health and Environmental
Sciences
Cogs-well Building
Helena, Montana 59601
(406) 449-3454
G-L3
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Nebraska
Nevada
Air Division
Gene Robinson, Chief
Air Pollution Control Division
Nebraska Department of Environment
Control
P.O. Box 94653
State House Station
Lincoln, Nebraska 68509
(402) 471-2186
Water Division
Dennis Lessig, Chief
Water Pollution Control
Nebraska Department of Environment
Control
P.O. Box 94653
State House Station
Lincoln, Nebraska 68509
Solid Waste Division
Maurice.W. Shell, Chief
Solid Waste Division
Nebraska Department of Environment
Control
P.O. Box 94653
State House Station
Lincoln, Nebraska 68509
Pesticide Division
Marvin Sitorius, Chief
Bureau of Plant Industry
Department of Agriculture
P.O. Box 94756
Lincoln, Nebraska 68509
(402) 471-2394
G-14
Air Division
Norman Glaser, Chairman
Nevada Environmental Commission
201 S. Fall Street
Carson City, Nevada 89701
(702) 885-4363
Water Division
Norman Glaser, Chairman
Nevada Environmental Commisidn
201 Carson City, Nevada 89701
(702) 885-4363
Solid Waste Division
H. LaVerne Rosse
Department of Health and Welfare
1209 Johnson Street
Carson City, Nevada 89701
(702) 885-4670
New Hampshire
Air Division
Donald G. Davis, Chief Engineer
Air Pollution Control Agency
State of New Hampshire
State Laboratory Building
Hazen Drive
Concord, New Hampshire 03301
(603) 271-2281
Water Division
Thomas A. La Cava, Director
Deputy executive
New Hampshire Water Supply and
Pollution Control Commission
P.O. Box 95
105 Loudon Road
Concord, New Hampshire 03301
(603) 27H-3503
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New Hampshire
New Jersey
Solid Waste Division
Thomas L. Sweeney
Solid Waste Mangement
Division of Public Health Services
61 South Spring Street
Concord, New Hampshire 03301
(603) 271-2747
Pesticides Division
Francis D. Houghton
Pesticides Surveillance Scientist
Water Supply and Pollution Control
Commission
P.O. Box 95
105 Loudon Road
Concord, New Hampshire 03301
(603) 271-3503
New Jersey
Air Division
Dr. Ralph Pasceri, Supervisor
Air Quality Services and Evaluation
Bureau of Air Pollutaion Control
Division of Environmental Quality
New Jersey Department of Environmental
Protection
P.O. Box 2807
Trenton, New Jersey 08625
(609) 292-6704
Water Division
Rocco D. Ricci, Assistant Commissioner
Division of Water Resources
New Jersey Department fo Environemntal
Protection
P.O. Box 2807
Trenton, New Jersey 08625
(609) 292-1637
Solid Waste Division
Beatric Tylatki, Director
Bureau of Solid Waste Mangement
New Jersey Department of
Enviornmental Protection
P.O. Box 1390
Trenton, New Jersey 08625
(609) 292-7645
Pesticide Division
George Beyer, Supervisor
Office of Pesticide Control
Division of Environmental Quality
New Jersey Department of Environmental
Protection
P.O. Box 2807
Trenton, New Jersey 08625
(609) 292-1637
G-15
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New Mexico
New York
Air Division
Cubia Clayton, Chief
Air Quality Division
Environmental Improvement Agency
P.O. Box 2348
Santa Fe, New Mexico 87503
(505) 827-2373
Water Division
John R. Wright, Chief
Water Quality Division
Environmental Improvement Agency
P.O. Box 2348
Santa Fe, New Mexico 87503
(505) 827-2373
Solid Waste Division
Bryan E. Miller, Chief
General Sanitation Division
Environmental Improvement Agency
P.O. Box 2348
Santa Fe, New Mexico 87503
(505) 827-2693
Pesticide Section
Barry Patterson, Chief
Division of Pesticide Control
New Mexico Department of Agriculture
New Mexico State University
Las Cruces, New Mexico 88001
(505) 646-2133
Environmental Chemicals Monitoring
and Training Division
James L. White, Program Mangeer
Environmental Chemicals Division
Environmental Improvement Agency
P.O. Box 2348
Santa Fe, New Mexico 87503
Air Division
Gerard E. Blanchard
Principal Air Pollution Control
Engineer
Division of Air Resources
Bureau of Technical Services
Department of Environmental
Conservation
50 Wolf Road
Albany, New York 12233
(518) 457-6674
Water Division
Eugene F. Seebald, Director
Division of Pure Waters
Bureau of Technical Services
Department of Environmental
Conservation
50 Wolf Road
Albany, New York 12233
(518) 457-6674
Solid Waste Division
William G. Bentley, Director
Division of Solid Waste Mangement
Bureau of Technical Services
Department of Environmental Conservatiot
50 Wolf Road
Albany, New York 12233
(518) 457-6603
Pesticide Division
C. H. Frommer, Director
Bureau of Pesticides
Department of Environmental Conservation
50 Wolf Road
Albany, New York 12233
(518) 457-6674
G-16
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North Carolina
North Dakota
Air Division
James A. McColman, Chief
Air Quality Section
Division of Environmental Mangement
Department of Natural and Ecomonic
Resources
P.O. Box 27687
Raleigh, North Carolina 27611
(919) 829-4740
Water Division
L. P. Benton, Jr., Chief
Water Quality Section
Division of Environmental Management
Department of Natural and Economic
Resources
P.O. Box 27687
Raleight, North Carolina 27611
(919) 829-4740
Solid Waste Division
Sidney H. Usry, Head
Solid Waste and Vector Control Branch
Department of Human Resources
P.O. Box 2091
Raleigh, North Carolina 27662
(919) 829-2178
Pesticide Division
William B. Buffalo, Chief
Pest Control Division
North Carolina Department of Agriculture
Agriculture Building
Raleigh, North Carolina 27601
(191) 829-7125
Air Division
Gene A. Christiansen, Director
Air Pollution Control Programs
Division of Environmental Engineering
North Dakota State Department of
Health
State Capitol Building
Bismark, North Dakota 58505
(701) 224-2348
Water Division
Norman 1. Peterson, Director
Division of Water Supply and
Pollution Control
North Dakota State Department of
Health
State Capitol Building
Bismark, North Dakota 58505
(701) 224-2386
Solid Waste Division
Gerald W. Knudsen, Director
Division of Solid Waste Managment
North Dakota State Department of
Health
State Capitol Building
Bismark, North Dakota 58505
(701) 224-2386
G-17
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Ohio
Oklahoma
Air Division and Water Division
Ned E. Williams, Director
State of Ohio Environmental Protection
Agency
P.O. Box 1049
Columbus, Ohio 43216
(614) 466-8318
Solid Waste Division
David Sharp, Chief
Division of Waste Management and
Engineering
State of Ohio Environmental Protection
Agency
P.O. Box 1049
Columbus, Ohio 43216
(614) 466-7220
Pesticide Division
Ms. Terry Voss
Pesticide Coordinator
State of Ohio Environmental Protection
Agency
P.O. Box 1049
Columbus, Ohio 43216
(614) 466-8804
Agriculture Department
Oren Spillker
Ohio Department of Agriculture
14573 National Road, S.W.
Reynoldsburg, Ohio 43068
Air Division
Mark S. Coleman
Assistant Deputy Commissioner
Oklahoma State Department of Health
Air Pollution Control Division
P.O. Box 53551
10th and North Stonewall
Oklahoma City, Oklahoma 73105
(405) 271-4200
Water Division
Charles D. Newton, Chief
Water Quality Service
Oklahoma State Department of Health
P.O. Box 53551
10th and North Stonewall
Oklahoma City, Oklahoma 73105
Solid Waste Division
Calvin T. Grant, Chief
Sanitation Service
Oklahoma State Department of Health
P.O. Box 53551
10th and North Stonewall
Oklahoma City, Oklahoma 73105
Agriculture Department
Clyde A. Bower
Administrative Assistant
Department of Agriculture
122 State Capitol
2302 Lincoln Building
Oklahoma City, Oklahoma 73105
(405) 521-3866
G-18
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Oregon
PennsyIvanla
Air Division
Harold M. Patterson
Assistant Director for Air Quality
Department of Environmental Quality
Air Quality Control Division
1234 S.W. Morrison St.
Portland, Oregion 97205
(503) 229-5359
Water Division
H. L. Sawyer
Assistant Director for Water Quality
Department of Environmental Quality
1234 S.W. Morrison St.
Portland, Oregon 97205
(503) 229-5696
Solid Waste Division
Ernest A. Schmidt, Director
Solid Waste Management Division
Department of Environmental Quality
1234 S.W. Morrison St.
Portland, Oregon 97205
(503) 229-5696
Hazardous Wastes and Pesticide
Residues Division
Patrick Wicks
Land Quality Division
Department of Environmental Quality
1234 S.W. Morrison St.
Portland, Oregon 97205
(503) 229-5696
Air Division
James Hambright, Acting Director
Bureau of Air Quality and Noise Control
Department of National Resources
P.O. Box 2063
Harrisburg, Pennsylvania 17120
(717) 787-9702
Water Division
Walter A. Lyon, Director
Bureau of Water Quality Management
Department of National Resources
P.O. Box 2063
Harrisburg, Pennsylvania 17120
(717) 787-2666
Solid Waste Division
William C. Bucciarelli, Director
Division of Solid Waste Management
Department of Natural Resources
P.O. Box 2063
Harrisburg, Pennsylvania 17120
(717) 787-7381
Pesticide Division
William Apgar, Coordinator
Pesticides Project
Department of Natural Resources
P.O. Box 2063
Harrisburg, Pennsylvania 17120
(717) 787-8810
G-19
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Rhode Island
South Carolina
Air Division
Austin C. Daley, Chief
Rhode Island Department of Health
Division of Air Pollution Control
204 Health Building, Davis Street
Providence, Rhode Island 02908
(401) 277-2808
Water Division
Pearce Klazer, Prinicpal Sanitary Engineer
Division of Water Supply and Pollution
Control
Rhode Island Department of Health
209 Health Building, Davis Street
Providence, Rhode Island 02908
(401) 277-2234
Solid Waste Division
John Quinn, Jr., Chief
Division of Solid Waste Management
Department of Health
204 Health Building, Davis Street
Providence, Rhode Island 02908
(401) 277-2808
Water Division
John C. Hawkins, Chief
Bureau of Wastewater and Stream
Quality Control
Office of Environmental Quality Control
South Carolina Department of Health and
Environmental Control
J. Marion Sims Building
2600 Bull Street
Columbia, South Carolina 29201
(803) 758-5450
Solid Waste Division
H. Gerald Edwards, Director
Solid Waste Management Division
Office of Environmental Quality Control
South Carolina Department of Health and
Environmental Control
J. Marion Sims Building
2600 Bull Street .
Columbia, South Carolina 29201
(803) 758-5681
South Carolina
Air Division
J. T. Thornberry
Air Programs Manager
Bureau of Air Quality Control
Office of Environmental Quality Control
South Carolina Department of Health
and Environmental Control
J. Marion Sims Buidling
2600 Bull Street
Columbia, South Carolina 29201
(803) 758-5450
G-20
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South Dakota
Tennessee
Air Division
Lyle Randen, Chief
Air Quality and Solid Waste Programs
Department of Environmental Protection
State Office Building 2
Pierre, South Dakota 57501
(605) 224-3351
Water Division
Richard Howard, Chief
Water Quality Programs
Department of Environmental Protection
State Office Building 2
Pierre, South Dakota 57501
(605) 224-3351
Solid Waste Division
Roger Stead
Division of Solid Waste and Land Management
Department of Environmental Protection
Sate Office Building 2
Pierre, South Dakota 57501
(605) 224-3351
Agriculture Department
Roger Pearson
Sate Department of Agriculture
State Office Building
Pierre, South Datkota 57501
(605) 224-3375
Air Division
Charles Rice
Tennessee Air Pollution Control Division
Department of Public Health
256 Capitol Hill Building
301 Seventh Avenue, North
Nashville, Tennessee 37291
(615) 741-3931
Water Division
S. Leary Jones, Technical Secretary
Tennessee Water Quality Control Board
621 Cordell Hull Building
Nashville, Tennessee 37219
(615) 741-2275
Solid Waste Division
Thomas Tiesler, Director
Division of Sanitation and Solid
Waste Management
Department of Public Health
Capitol Hill Building, Suite 320
Nashville, Tennessee 37219
(615) 741-3424
G-21
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Texas
Air Division
Charles R. Barden, Executive Director
Texas Air Control Board
8520 Shoal Creek Boulevard
Austin, Texas 78758
(512) 451-5711
Water Division
Thomas S. Beasley
Texas Water Quality Board
Stephen F. Austin Office Building
1700 North Congress Avenue
Austin, Texas 78701
(512) 475-2651
Solid Waste Division
David Houston, Chief
Environmental Development Program
Department of Health
1100 West 49th Street
Austin, Texas 78756
(512) 397-5721
Industrial Waste and Agriculture
Disposal Division
Robert G. Fleming
Division of General Operations
Water Quality Board
Stephen F. Austin Office Building
1700 North Congress Avenue
Austin, Texas 78701
(512) 475-2651
Emissions Inventory Division
Joseph Pennington, Chief
Emissions Inventory Section
Texas Air Control Board
8520 Shoal Creek Boulevard
Austin, Texas 78758
G-22
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Utah
Air Division
Grant S. Winn, Director
Bureau of Air Quality
Environmental Health Services Branch
Utah State Division of Health
44 Medical Drive
Salt Lake City, Utah 84113
(801) 533-6121
Environmental Epidemiology Division
J. Wanless Southwick, Director
Bureau of Environmental Epidemiology
Environmental Health Services Branch
Utah State Division of Health
44 Medical Dive
Salt Lake City, Utah 84113
(801) 533-6121
Water Division
Calvin K. Sudweeks, Director
Bureau of Water Quality
Environmental Health Services Branch
Utah State Division of Health
44 Medical Drive
Salt Lake City, Utah 84113
(801) 533-6121
Solid Waste Division
Dale Parker, Chief
General Sanitation Section
Utah State Division of Health
44 Medical Drive
Salt Lake City, Utah 84113
(801) 328-6163
Agriculture Department
Ray J. Downs, Director
Division of Plant Industry
Utah State Department Agriculture
State Capitol Building
Salt Lake City, Utah 84114
(801) 328-5421
G-23
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Vermont
Virginia
Air Division
Richard Valentinetti
Air Pollution Control Officer
Agency of Environmental Conservation
Division of Environmental Engineering
P.O. Box 489
Montpelier, Vermont 05602
(802) 828-3395
Water Division
David Clough, Director
Water Quality Division
Agency for Environmental Conservation
Department of Water Resources
Montpelier, Vermont 05602
(802) 828-3361
Solid Waste Division
Richard Valentinetti, Chief
Air and Solid Waste Programs
Agency of Environmental Conservation
Division of Environmental Engeineering
P.O. Box 489
Montpelier, Vermont 05602
(802) 838-3395
Pesticide Advisory Council
Harold Stowe
Public Health Laboratory
Department of Health
60 Main Street
Burlington, Vermont 05401
(802) 862-5701
Air Division
James W. Watson
Assistant Executive Director
State Air Pollution Control Baord
Room 1160
North Street Office Building
Richmond, Virginia 23219
(804) 786-2378
Water Division
Michael A. Bellanca, Director
Bureau of Surveillance and Field
Studies
State Water Control Board
2111 Hamilton Street
Richmond, Virginia 23230
(804) 786-1411
Solid Waste Division
R. E. Dorer, Director
Bureau of Solid Waste and Vector Control
State Department of Health, Room 209
401-A Colley Avenue
Norfolk, Virginia 23507
(804) 627-4511
Pesticide Division
Harold K. Rust, Supervisor
Pesticide, Paint and Hazardous Substance
Section
Department of Agriculture and Commerce
Division of Product and Industry
Regulation
P.O. Box 1163
Richmond, Virginia 23209
(804) 786-3798
G-24
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Washington
West Virginia
Air Division
Herley F. McCall Supervisor
Analytical Services Division
Office of Air Programs
Department of Ecology
Olympia, Washington 98504
(206) 753-2821
Water Division
James P. Behlke, Executive Assistant
Director
Office of Comprehsenive Programs
Department of Ecology
Olympia, Washington 98504
(206) 753-2817
Solid Waste Division
Avery N. Wells, Chief
Solid Waste and Resource Recovery
Division
Department of Ecology
Olympia, Washington 98504
(206) 753-2800
Social and Health Services Division,
Monitoring Programs Division
Samuel Reed
Department of Social and Health Services
P.O. Box 1788
Olympia, Washington 98504
(206) 753-5406
Air Division
Carl 6. Beard,II, Director
West Virginia Air Pollution Control
Commission
1558 Washington Street East
Charleston, West Virginia 25305
(304) 348-3286
Water Division
M. S. Baloch, Assistant Chief
Division of Water Resources
Department of Natural Resources
1201 Greenbrier Street
Charleston, West Virginia 25305
(304) 348-2107
Solid Waste Division
Dale Parsons, Director
Solid Waste Program
State Department of Health
1800 Washington Street East
Charleston, West Virgina 25305
(304) 348-2987
G-25
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Wisconsin
Air Division
Douglas W. Evans, Chief
Air Pollution Control Section
Wisconsin Department of Natural Resources
Bureau of Air Pollution Control and
Solid Waste Disposal
P.O. Box 450
Madison, Wisconsin 53701
(608) 266-0924
Water Division
Carl J. Blabaum, Acting Director
Bureau of Water Quality
Wisconsin Department of Natural Resources
P.O. Box 450
Madison, Wisconsin 53701
(608) 266-3910
Solid Waste Division
John J. Reinhardt, Chief
Solid Waste Management Section
Wisconsin Department of Natural Resources
P.O. Box 450
Madison, Wisconsin 53701
(608) 266-0158
Wyoming
Air Division
Randolph Wood, Administrator
Air Quality Division
Department of Environmental Quality
Hathaway Building- No. 117
Cheyenne, Wyoming 82002
(307) 777-7391
Water Division
Arthur E. Williamson, Administrator
Division of Water Quality
Department of Environmental Quality
Hathaway Building
Cheyenne, Wyoming 82002
(307) 777-7781
Solid Waste Division
Charles Porter
Solid Waste Program Supervisor
Department of Environmental Quality
Hathaway Building
Cheyenne, Wyoming 82002
(307) 777-7391
G-26
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APPENDIX H
STATE PESTICIDE RELATED ENVIRONMENTAL PROGRAMS - 1976
H-l
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This section is devoted to a brief discussion of pesticide-related
programs in 1976 as determined by letter and telephone contact. In some in-
stances, no personal response was obtained and the information given is taken
from a directory of EPA, state, and local environmental monitoring and as-
sessment activities.!/
ALABAMA
The Pesticide Residue Laboratory performs statewide, random, and routine
field work in terms of taking samples of all raw agricultural commodities
and checking for pesticide residues* The laboratory cooperates with the State
Department of Conservation by analyzing residues in any type of accidents
concerning pesticides such as fish and wildlife kills.!/
The City Council of Huntsville adopted regulations for the control of
pesticide emissions as an amendment to the air pollution control rules and
regulations on May 22, 1975. No formal survey on air emissions from the
pesticide industry has been taken in Huntsville area as of April 1976*i/
The Tri-County District Health Services of Decatur has not surveyed
air emissions from the pesticide industry as of March 1976 J:/
The Jefferson County Department of Health has no knowledge of any sur-
veys or studies of the pesticide industry in Jefferson County having been
conducted.— (We have found there are at least 11 pesticide formulators in
Jefferson County.)
ALASKA
The Department of Environmental Conservation reports that at present
there are no monitoring programs for pesticides in Alaska J^' (There are no
manufacturing or formulating operations in Alaska. Further, repackaging of
pesticides is not permitted.)
ARIZONA
The Bureau of Sanitation in Phoenix performs monitoring of pesticide
levels in food products. The Fisheries Division of the Department of Game
and Fish in Phoenix has monitored pesticides in water in conjunction with
federal agencies—EPA and Bureau of Sport Fisheries. Most work is concerned
with other pollutants such as heavy metals JL'
ARKANSAS
The Department of Health monitors pesticides in air, water, meat, and
milk. Additional monitoring of persons who load planes for aerial spraying,
etc., is also carried outJL'
H-2
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The Arkansas Department of Pollution Control and Ecology has sole re-
sponsibility for control of air emissions, effluents, and solid waste dis-
posal. They are currently working with several pesticide producers that they
are experiencing trouble with in relation to their emissions*^/
CALIFORNIA
The Sacramento Monitoring and Surveillance Unit of the State Water Re-
sources Control Board has performed pesticide studies in the past. Beginning
with fiscal year 1976/1977, they will monitor for pesticides in bottom sedi-
ments according to the EPA regulations which will indicate areas of pesticide
buildup where further studies will be needed. They will begin water column
sampling in fiscal year 1976/1977 at appropriate state areas with high pes-
ticide use or specific water quality problems related to pesticides*!/
The Inspection Services of the Department of Food and Agriculture and
three other laboratories in the state perform daily screening of raw agri-
culture products and investigate isolated problems such as accidents caused
by pesticides*!/
EPA Region IX in San Francisco has no record of specific pesticide emis-
sions in their region.£/
An inspection of the pesticide plant owned and operated by Chevron Chemi-
cal at Richmond was completed on March 29 and 30, 1976. It was learned that
the plant capacity will be doubled in the near future. No air emissions sam-
ples were taken at the time of the inspectionJL'
The Air Resources Board in Sacramento is not aware of any air emissions
from the pesticide industry in California.!/
The Water Resources Control Board only reports general information about
agencies that would be concerned about pesticide control. No specific infor-
mation about pesticide programs was given Jl'
COLORADO
Once a year the Department of Agriculture monitors water sources* Other-
wise only accidents involving commercial applications are investigated*k'
The Epidemiologic Pesticide Studies Center at Colorado State University
in conjunction with EPA has done monitoring for pesticides in air, house dust,
reservoir water, soil, and human tissue.1/
EPA in Denver has no information regarding pesticide emissions••
H-3
21
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In 1971 the Colorado Community Pesticide Program at Greeley sampled am-
bient air for pesticide active ingredient•$/ The study was not expanded at
that time but some small amount of air sampling under contract to the EPA
at four different sites recently was completed. The results are not yet avail-
able for publication.±_2_t'
Shell Chemical Company has operated a pesticide manufacturing plant for
many years on the Rocky Mountain Arsenal property northeast of Denver. Re-
cently there have been reports of dicyclopentadiene, a pesticide precursor,
entering nearby surface and groundwaters in low parts per million concentra-
tion levels.2»5,6/
Diisopropylmethylphosphonate (DIMP), a by-product of the chemical de-
struction and manufacture of GB nerve gas, was initially disposed of to two
lakes on the arsenal property from 1957 to the early 1960's after which the
practice was discontinued. DIMP has now been found in a series of wells both
on and off the arsenal property. Concentrations of DIMP ranged from 1, to
48, to 400 ppra for various off-site wells, on-site wells, and an on-site lake,
respectively.??-*?.?/
Balco1m Chemical, Inc., a formulator at Greeley, recently began a pesti-
cide drum rinsing operation to reclaim used pesticide drums. Thimet residues
from the rinsing operations will be treated with caustic prior to disposal
in the Greeley sewage system.i:,>V
CONNECTICUT
On July 1, 1974, the Water Compliance Unit of the Department of Environ-
mental Protection initiated trend monitoring for pesticides in yearly sediment
samples*!'
The Connecticut Department of Environmental Protection has one unit,
Pesticide Compliance, that regulates activity affecting manufacturing industry
in areas of discharge into air or water and disposal of solid wasted'
DELAWARE
The Technical Services Section of the Department of Natural Resources
samples water from the Delaware River quarterly taking about 34 samples an-
nually. They have monitored offshore ocean waters including aquatic organisms
and sediment. The monitoring program of streams in the state will increase
in the near future*!'
DISTRICT OF COLUMBIA
The Environmental Health Administration has made budgetary provisions
for the coining fiscal year for monitoring pesticide residue levels indoors
H-4
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and outdoors* It is concerned mainly with households since the District is
1 /
not a rural area*!' (There are six formulators in the District of Columbia.)
FLORIDA
The Department of Pollution Control has 100 stations throughout the state
to scan pesticide residues in sediment and fish on an annual basis* The Depart-
ment investigates accidents involving pesticide misuse* They plan to begin
monitoring in connection with the inspection of sites of pesticide formula-
tions.-^
The Game Research Office of the Fish and Game Commission in Gainsvilie
is involved with two major pesticide monitoring studies* One study concerns
brown pelicans around the Florida coast, and samples are taken once a year
during the nesting season. This study started in the late 1960's. The second
study which has been completed involves monitoring mirex bait distributed
for the control of fire ants and procuring specimens* They also investigate
accidental pesticide misuse J:'
The Pesticide Residue Laboratory of the Department of Agriculture's
primary responsibility is to monitor pesticide residue levels in food includ-
ing fish and shellfish. They also investigate accidental pesticide misuse..!'
The University of Miami School of Medicine study has been examining
pesticides in air in south Florida since 1973 JjJ:' In order to trap and con-
centrate the very low level of pesticides occurring in air, a double impinger-
trap system was employed. Ethylene glycol was found to have excellent trap-
ping qualities for pesticides entering in an air stream. The impingers were
originally developed by Midwest Research Institute and have been described
earlier*^ Trapping efficiencies generally ranged from 80 to 100% recovery
as proven by use of spiked samples and depended on the pesticide.
After trapping the pesticide, the ethylene glycol solution was subjected
to a multiclass-multiresidue separation procedure based on silica gel chroma-
tography using a series solvents of increasing polarityj^/ Identification
of the pesticides fractions was accomplished by GC-MS *
Quantification was achieved by GLC using columns optimized for maximum
peak separation and sharpness using specific detectors; a tritium foil elec-
tron capture detector for organochlorine pesticides and a flame photometric
detector for organophosphorus pesticides.^—
GEORGIA
The Pesticide Division of the Department of Agriculture performs food
and environmental monitoring for pesticides and investigates problems in the
field relating to pesticide application«i'
H-5
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The Laboratories Division does surveillance of raw agriculture products-
leafy vegetables and milk. The Division also monitors animal, feed, pondwater,
and miscellaneous media for regulatory purposes*!'
HAWAII
There is no information about pesticide monitoring in Hawaii..!/ There
has been no pesticide monitoring in Hawaii as of February 1976•£
IDAHO
EPA sponsors 12 community studies through the Deparment of Health and
Welfare that monitor pesticides in all media in relation to human health*!'
ILLINOIS
EPA monitors pesticides in terms of a general overall water quality pro-
gram. They sample water, bottom sediments, and fish in Lake Michigan and its
tributaries*!'
The Department of Public Health monitors milk supplies, feed, and meat
for pesticides* They also investigate poisoning in children.!'
The State Natural History Survey monitors pesticides in milk, meat, soy-
beans soil, water, terrestrial and aquatic lifeJL'
There are no specific regulations, monitoring requirements, or emissions
and/or effluent standards for pesticide manufacturing facilities«£'
There has never been a survey on air emissions from the pesticide in-
dustry in Region Vȣ'
INDIANA
The State Board of Health periodically monitors pesticides in fruits,
vegetables, and milk J/
The Water Quality Surveillance of the State Board of Health has stopped
a 3-year monitoring program in Lake Michigan since they were not able to find
significant problems.!'
The Stream Pollution Control Board is not actively involved in any study
of emissions as of February 1976£l
H-6
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IOWA
The Pesticide Section of the Department of Agriculture monitors foods,
especially dairy products, meat, vegetables, and feed ingredients. They also
investigate on a case-by-case basis the misuse and abuse of pesticides and
crop residues JL'
The Iowa Conservation Commission has performed some environmental moni-
toring specifically for dieldrin in fish and pheasants*!'
The Chemical Technology Division of the Department of Environmental Qual-
ity works with Iowa State University in investigating incidents of pesticide
related environmental damage and also monitors farm runoff.1'
KANSAS
The work on monitoring the air around Topeka by the Department of Health
has been recently suspended. It may be resumed in the future*!'
KENTUCKY
Since 1966, the Consumer Product Safety Section of the Department of
Human Resources has maintained statewide comprehensive surveillance of intra-
state commercially produced raw agriculture products for compliance of per-
missible pesticide residues. Special studie's have been discontinued that in-
volved monitoring of pesticides in ambient air and pesticide residues in major
watersheds •!'
The Department of Natural Resources Environmental Protection currently
monitors stream runoff, air, and milk for pesticide content and monitoring
of manufactured pesticides to determine if the contents are the same as
stated on the label .I/
LOUISIANA
The Feed and Fertilizer Laboratories at Louisiana State University is
a pesticide regulatory agency* It also does some monitoring of fish, wildlife,
water, meat, and animal feed.!/
The Louisiana Air Control Commission currently routinely checks permits
and emission inventory questionnaires for possible problem insecticide emis-
sions* Special studies are accomplished as necessary«i'
MAINE
The Division of Inspection of the Department of Agriculture performs
monitoring of pesticides in feeds only*!'
H-7
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The Fish and Game Department performs monitoring of pesticides in salmon
in Serago Lake*!/
MARYLAND
The Inspection and Regulation Division of the Department of Agriculture
performs mainly duties such as checking labeling and guarantees on formula-
tions sold. It also monitors pesticide residues in meat, vegetation, soil,
and public water supplies-=/
MASSACHUSETTS
The only routine monitoring program involves chlorinated hydrocarbons
in fish. Estuary studies have been conducted through the Division of Marine
Fisheries. Special programs investigating accidents with pesticides are run
occasi.onally.-i/
EPA conducted a survey and emission test for the period September 10
through 12, 1974, at the General Electric Company, Pittsfield, Massachusetts,
relative to the disposal of pesticides. The test program was to establish
capability of the Company's thermal oxidizer to process and dispose of a li-
quid formulation in an environmentally acceptable manner.*
MICHIGAN
The Food Inspection Division performs year-round monitoring of all fresh
produce including milk and meat. Meat is monitored on a less regular basis*!'
The Water Quality Control Division in conjunction with several state and
federal agencies carries out annual surveys of dieldrin and DDT in Great Lakes
fish, and also annually samples Great Lakes tributaries for dieldrin and DDT
in addition to other pesticides* Since 1968, they have been monitoring dieldrin
and chlordane on a yearly basis in Bervien County where controlled pesticide
treatments for Japanese beetles have been conducted .I/
Neither the Michigan Department of Natural Resources nor any of the
local air pollution agencies conduct a program of air monitoring of emissions
specifically related to the pesticide industry••=/
MINNESOTA
The Department of Agriculture performs ongoing surveillance for pesticides
in food and feedstuffs, and in conjunction with the State Health Department,
checks pesticide levels in well water. The Department of Natural Resources
routinely monitors pesticide levels in fish* Analysis on other wildlife is
sporadic* The State Pollution Control Agency performs semiannual statewide
monitoring of water for pesticides•!/
H-8
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MISSISSIPPI
The state and federal government through the Game and Fish Commission
sponsors continual monitoring of lakes and fish in Mississippi, especially
in the Delta area* It has closed three lakes on the basis of information ob-
tained. They also monitor game*!/
The Imported Fire Ant Control Division in the Department of Agriculture
monitors air. water, soil, and living organisms for pesticides used in fire
ant control.!'
MISSOURI
The Bureau of Pesticide Control reports that the only monitoring that
is done or will be done is in conjunction with the USDA concerning residues
in soils and crops*!'
The Division of Environmental Quality through the Clean Water Commission
staff has been approved by EPA for the administration of the National Pollu-
tant Discharge Elimination System Permit Program* The program requires that
a permit be obtained to discharge effluents to the waters of the state. The
sampling of the effluent and analysis of the sample to establish compliance
with water quality standards is the responsibility of the permit holder*^
The Air Conservation Commission staff does not have a specific program
involving the pesticide industry.!'
MONTANA
The Health and Environment Sciences Department's Pesticides Demonstration
Program in conjunction with EPA monitors food, crops, and water during and
after spraying when high levels are suspected, and not routinely, but in re-
sponse to reports of incidents of misuse* Routine monitoring stopped in 1972;
it may be resumed in connection with chemicals disposal site*!'
NEBRASKA
The Plant Protection Division, USDA, cooperates with the federal USDA/EPA
program in Nebraska and Kansas* No monitoring is carried out through state
agencies*!'
The Air, Water, and Solid Wastes Division of the Department of Environ-
mental Control has permit programs limiting the quantity and quality of dis-
charges and/or emissions* The Solid Waste Division is currently conducting
a hazardous waste disposal study to determine what, where, and under what
conditions or control hazardous waste may be placed in sanitary landfills.!/
H-9
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The USDA monitors pesticide formulations for chemical ingredients to see
that they meet the guarantee on the label JL'
NEVADA
The Cooperative Extension Service of the College of Agriculture at the
University of Nevada carries out only monitoring in the state. It monitors
air, water, soil, vegetation, wildlife, etc., around four pesticide disposal
sites-i'
NEW HAMPSHIRE
The State Laboratory Building samples all types of environmental media
for pesticides, only for isolated complaints or incidents. They are hampered
by the lack of funds for other monitoring•!/
The State of New Hampshire has no pesticide industry.!' (There are 10
formulators in New Hampshire.)
NEW JERSEY
Routine analysis of water, food, and milk is performed by the Health
Department•
Air is no longer routinely monitored, but they investigate specific in-
cidents or complaints.
The Department of Environmental Protection has no control activities
directed toward the pesticide industry per se. Any controls on pesticide man-
ufacturing and formulation are subject to the same air pollution control reg-
ulations applicable to all industrial sources•=/
NEW MEXICO
The Environmental Improvement Agency performs monitoring for pesticides
on a small scale only. It currently monitors vector control crews. They are
now in the process of setting up monitoring for raw agricultural commodities
and are trying to set up two air monitors in one specific location where
herbicide problems have existed* Most efforts are restricted to specific prob-
lems of accidents concerning pesticides.—
The EIA, Environmental Chemicals and Monitoring and Training, has two
specific programs under contract with EPA. One is a survey to identify sources
of toxic and hazardous wastes and ultimately to assess the effectiveness of
the disposal of these wastes. The other program is for multimedia environmen-
tal monitoring for pesticide residues in water courses, stream bottom sediments,
H-10
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raw agricultural commodities, and air in the State of New Mexico. The programs
are not specifically involved in the pesticide industry because there is no
significant pesticide industry in New Mexico*!' (There are 13 f emulators in
New Mexico.)
The EIA, Water Quality Division, has sections that monitor agriculture
pesticide drift and cholinesterase testing in pesticide personnel. Monitor-
ing for pesticides in milk is carried out by the Food Quality Division«£'
NEW YORK
The Pesticides Bureau of the Department of Environmental Conservation
performs monitoring sporadically. It monitors pesticides in water once or
twice annually. Air monitoring has been discontinued*!'
The Food Control Division of the Department of Agriculture monitors food
for a variety of substances including pesticides »=/
The Meat Inspection Division monitors meat and poultry for a variety of
substances including pesticides ••=/
NORTH CAROLINA
The Food and Drug Division of the Department of Agriculture performs
monitoring for pesticides in conjunction with the inspection of food, feed,
and dairy products ••=/
The Department of Natural and Economic Resources monitors stream water
for pesticides and is planning to monitor water, fish, and to examine bottom
sediments annually.*
The Water Quality Section of the Department of Natural and Economic Re-
sources is not monitoring surface waters for pesticides on a routine basis*
Pesticide sampling is done only in connection with environmental emergencies*^'
The Air Quality Section reports that no pesticide emission monitoring
is conducted.1*
The Pest Control Division monitors disposal sites routinely and samples
for pesticide residues in ground and surface waters* Foods are also routinely
examined for pesticidesȣ'
NORTH DAKOTA
The Water Supply and Pollution Control Division of the Department of
Health monitors stream water for pesticides. They are planning eventually
to begin monitoring more extensively by including bottom sediments, etc.—'
H-ll
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OHIO
The Environmental Evaluation Section of EPA in Ohio monitors mainly sur-
face waters, fish, bottom aquatic life, and bottom sediments*^'
EPA in Ohio is currently monitoring and taking samples monthly from 26
statewide surface water sites that are checked for 15 different organochlorine
pesticide parameters«=/
The Hazardous Waste Section of EPA's Land Pollution Control Division
is conducting a survey among manufacturers of hazardous wastes of the quan-
tities disposed of in the state. A follow-up study will be conducted to see
whether it is being disposed of properly*=-
There is no program in the Division of Air Pollution Control pertaining
to pesticide emissions and no air quality standards have been setJ=/
OKLAHOMA
The Plant Industry Division of the Department of Agriculture samples
grain and feed, as well as soil and groundwater in agricultural areas* This
is done only when there is a demand for it, the particular season warrants
it or in the case of contamination»=/
The Department of Pollution Control serves a coordinating function for
this Department of Agriculture's monitoring for pesticides in water•!'
The Water Quality Division of the Water Resources Board collects pesti-
cide samples (both water and sediment) at 26 selected points across the state.
All of the major stream systems are monitored on a quarterly basis—'
The Department of Health runs its own independent programs which monitor
runoff, milk, and foods. Air monitoring was recently halted. It also investi-
gates accidental pesticide related incidents in whatever environmental medium
it happens to affect*-'
OREGON
The Laboratory Services Division of the Department of Agriculture moni-
tors all foods including dairy products, some frozen and processed foods,
and animal feeds. It also monitors soil, water, wildlife, etc., in all cases
where pesticides are used on federal and state lands. It is also currently
monitoring DDT levels in certain areas of Douglas firs.±'
H-12
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PENNSYLVANIA
The Water Quality Division of the Department of Environmental Resources
is conducting monitoring on a small scale for effects on streams of spraying
for gypsy moths JL'
The Division of Pesticide Community Studies of the Department of Environ-
mental Resources is currently conducting a survey which will involve all of
the 185 pesticide producing industries in Pennsylvania which are registered
with EPA pursuant to Section 7 of FIFRA as amended. A questionnaire has been
distributed to these establishments soliciting information of the types and
quantities of pesticide products being produced and the nature of liquid and
solid waste products being generated. The Department's Bureau of Air Quality
and Noise Control will be examined to determine those industries which have
submitted an emissions inventory. This project is designed to act as a focal
point for evaluating environmental problems associated with pesticides JJ
RHODE ISLAND
The Laboratories Division of the Department of Health performs routine
analyses for pesticides in both water and food. It also investigates pesti-
cide levels after isolated spray ings ••=•'
Although there are extensive air pollution and emission control pro-
grams in Rhode Island, none specifically involve pesticides-^
SOUTH CAROLINA
The Department of Health and Environmental Control carries out a limited
amount of monitoring on surface waters used for public supplies and some on
soil. Only a very small amount is done on wildlife and aquifers on demand or
a problem basis only.—
The College of Agriculture at Clems on University in Clems on monitors
soil and water in connection with the Fire Ant and Witch Weed Control Pro-
grams -i/
The Medical University of South Carolina in Charleston is conducting
some monitoring for pesticide levels in humans«•=/
The Bureau of Air Quality Control has no statutory or regulatory role
in the control or monitoring of pesticides in the State of South Carolina*!/
SOUTH DAKOTA
The Solid Wastes and Pesticide Program of the Department of Environmental
Protection has equipment for routine monitoring but mostly investigates accidents
H-13
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as they occur. It also has a computer program which codes information con-
cerning all commercial applications which can be correlated with accident
reports. Air monitoring was recently stopped for financial reasons•!'
The Department of Environmental Protection has no knowledge of any in-
dustry in South Dakota that manufactures or formulates pesticidesJL' (There
are 24 pesticide formulators in South Dakota.)
South Dakota University does some research involving pesticide moni-
toring of streams and rivers in South Dakota«=/
TENNESSEE
The Food and Drug Division of the Department of Agriculture monitors
pesticide residues in dairy products in conjunction with FDA and in live-
stock in conjunction with USDAx It also monitors other materials such as
flour, leaves, pondwater, and soil.!'
The Department of Health monitors pesticide levels in milk, water, air,
and human tissue.!'
TEXAS
The Environmental Consumer Health Protection Department of Health moni-
tors pesticide and radiation levels in milk, water, air, and human tissue.!'
s
There is no specific pesticide monitoring being routinely conducted for
air emissions in Texas as of February 1976•—'
The Texas Air Control Board has investigated air emissions from Central
International Chemicals of Liberty, Texas, resulting from citizen complaints
dating to March 1972. The facility formulates a number of perticides including
Imidan [(N-mercaptomethyl)phthalimide S-(0,0-dimethyl phosphorodithioate)]
which has a particularly offensive odor and may be compared to the odor of
rotten cabbage. Central International Chemicals modified the emissions control
equipment in an effort to alleviate odor complaints in April 1973 but Imidan
odors continue to be detected near the plant2J
The Texas Air Control Board has requested the formulator to advise them
30 days in advance of any product line changes, including new pesticides and
formulations* Air samples near the facility are taken whenever citizen com-
plaints are received. The plant itself is inspected every 2 years~
H-14
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UTAH
The Environmental Health Bureau in conjunction with EPA's Community
Pesticide Program monitors air, water, soil, and wildlife mostly on a grab-
bag sampling basis. Air monitoring was stopped recently for lack of signifi-
cant results. Pesticide related incidents are also investigated JL/
The Utah Epidemiologic Studies Project has not investigated any pesti-
cide episode involving emissions from pesticide industries*^
VERMONT
The Water Quality Division of the Agency of Environmental Conservation
will begin monitoring surface waters for pesticides by the end of summer*!/
Vermont has formed a Pesticides Advisory Council .-v
VIRGINIA
The Food Inspection Section of the Department of Agriculture maintains
a routine check on food products* The Pesticide, Paint, and Hazardous Sub-
stances Section investigates all pesticide related accidents or incidents of
misuse but does not perform routine monitoring activities .-^
The State Water Control Board operates 100 stations throughout the state
to monitor water. Samples. are taken bi-annually depending upon seasons of
spraying or application *=
The State Air Pollution Control Board has no knowledge of air emission
studies on pesticides since 1971.1'
WASHINGTON
The Department of Social and Health Services in conjunction with EPA's
Community Pesticides Program monitors storage levels in humans and principal
routes of human exposure to pesticides* It also surveys agricultural usage
of pesticides in the state and investigates all suspected accidents involv-
ing pesticide '
Neither the Air Programs Branch nor the Pesticides Branch of the U.S.
EPA Region X has undertaken surveys on air emissions from pesticides manu-
facturers or formulators nor do they have knowledge of any data from studies
by other interested parties .1'
H-15
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APPENDIX I
REBUTTABLE PRESUMPTION CATEGORY IV CHEMICALS AND TENTATIVE
SCHEDULE OF PRESUMPTION NOTICE
1-1
-------
Under the amended Federal Insecticide, Fungicide and Rodenticide Act
(1975), the Environmental Protection Agency (EPA) must re-register all pes-
ticides to determine their efficacy, safety, and long-term environmental im-
pact. This includes estimating the chemical's benefit versus its risk. To
carry out this mandate the EPA may require more long- and short-term informa-
tion, e.g., mutagenic, carcinogenic, and other toxicity studies. Alternately,
the EPA may presume against registration if the risks outweigh the benefits.
Several categories have been defined to indicate the types of informa-
tion required for pesticide active ingredient re-registration* These are:
Category I - Those active ingredients for which all required data,
e.g., toxicity data, residue studies, chronic feeding
studies, etc., to support re-registration are available.
Category II - Those active ingredients for which long-term testing
data, e.g., teratogenicity and chronic feeding studies
are lacking.
Category III - Those active ingredients for which short-term testing
data, e.g., acute oral and dermal toxicity studies are
lacking.
Category IV - Those active ingredients that show evidence of posing
potential unreasonable risk to human health and/or the
environment.
Category V - Those active ingredients which do not fit into the above
categories.
As of the date of this report the EPA has not officially assigned any
active ingredients to Category IV. However, a provisional listing of ap-
proximately 100 chemicals has been compiled based on existing evidence, un-
verified studies from the scientific literature, or a chemical similarity to
cancelled pesticide active ingredients. -Various reasons or rationales have
been advanced for placing an active ingredient in Category IV and include the
following: Actual or potential carcinogenicity, embryotoxicity, delayed
neurotoxicity, population reduction to nontarget organisms, hazard and/or
fatality to nontarget or endangered species.
The decision to list various active ingredients in Category IV is tenta-
tive and is based on a presumption of unreasonable risk to various life forms
and/or the environment. If after an extensive scientific review of appropriate
data for each of the active ingredients placed in Category IV there still
remains an unreasonable risk, the active ingredients may be denied re-registration
and withdrawn from the market.
1-2
-------
At this point registrants, users, the scientific community, and the gen-
eral public will have the opportunity to rebut the presumptive risk. This
potential sequence of events has led to Category IV being termed a Rebuttable
Presumption Category. These factions will be given every opportunity to demon-
strate that the risk is not as substantial as originally presumed, that it may
be reduced through labeling and other use restrictions, or that the benefits
of the active ingredients outweigh the risk involved and thus, support re-
registration. Thus, the placement of a particular active ingredient in Category
IV could trigger a Reubttable Presumption Against Registration (RPAR). Further
details may be found in the Federal Register and other sources.il2/ The list-
ing of chemicals presently included in Rebuttable Presumption Category IV as
obtained from the EPA follows in Appendix I.
Subsequent to the release of the Rebuttable Presumption List of Pesticides
in February 1976, the EPA has indicated the order in which the pesticides will
be scheduled for presumption against re-registration.—' The schedule is given
after this Rebuttable Presumption List in Appendix I.
1-3
-------
REFERENCES TO APPENDIX I
1. Federal Register, February 19, 1976.
2. Pesticide Chemical News, p. 15, March 3, 1976.
3. Chemical and Engineering News, p. 19, March 22, 1976,
4. Chemical and Engineering News, p. 18, June 14, 1976.
1-4
-------
PM
No. Common Names
22
99
23
12
12
23
15 BHC
Chemical and Biological Names
Ammonium arsenlte
Antlinocadmium dilactate
Arsenic acid; Orthoarsenic
acid
Arsenic pentoxide
Arsenic sulfide
Arsenic trioxide
Benzene hexachloride,
other isomers
Trade and Other Names Uses Reason in IV Status
Cancer
Cancer:
Testicular
atrophy
H,X Cancer
Cancer
Cancer
Cancer
Cancer
Decision
under review
Decision
under review
Decision
under review
Decision
under review
Decision
under review
Hearing
awaiting
further
study
13
23 Cacodylic acid
2 - (j»- ter t-Buty Iphenoxy ) -1-
methylethyl 2-chic roethy1
sulfite
Dimethylarsinic acid
Aramite; Aracide
Silvisar 510
Cancer
H,X Cancer
Decision
under review
-------
PM
No. Common Names
23 Cacodylic acid,
sodium salt
21
21
21
21
21
21
23
12
Chemical and Biological Names Trade and Other Names Uses Reason in IV Status
Dimethylarsenlc acid, sodium
salt
Cadmium-caIcium-copper-zinc-
sulfate-chromate complex
Cadmium carbonate
Cadmium chloride
Cadmium sebacate
Cadmium succlnate
Cadmium sulfate
Calcium acid me thane-
arsenate
Calcium arsenate;
Trlcalcium arsenate
Cancer
Cancer;
testicular
atrophy
Cancer;
testicular
atrophy
Cancer;
testicular
atrophy
Cancer;
testicular
atrophy
Cancer;
testicular
atrophy
Cancer;
testicular
atrophy
Cancer
Cancer
Decision
under review
Decision
under review
Decision
under review
12
Calcium arsenlte; Mono-
calcium n-arsenite
Cancer
Decision
under review
-------
PM
No._ Common Names
21
12
11
21 Chloranil
15 Chlordane
13 Chlorobenzllate
Chloroform
99
24
11 Compound 1080
12
21 D3CP
25 Dl-allate
Chemical and Biological Nanes
Calcium ethylenebisdithio-
carbamate
Calcium propanearsonate
Carbon tetrachlorlde
Tetrachloro-p-benzoquinone
607. Octachloro-4,7-methano-
tetrahydroindane and 40%
related compounds
Ethyl 4,4'-dichlorobenzilate
Trichlorome thane
Chlorome thoxypropy1mercuric
acetate
Coal tar, creosote
Sodium fluoroacetate
Trade and Other Names
Dithane-calcium
Copper arsenlte
1,2-Dlbromo-3-chloropropane
S-(2,3-Dichloroailyi)dli8o-
propy1thiocarbama te
Spergon
Ortho-klor
Nemagon;Fumazone
Avadex
Uses Reason in IV
F Thyroid cancer
Cancer
I Cancer
F Possible
carcinogen
I Cancer
I Cancer
Cancer
Embryotoxic
I.F.D Cancer
M,R Population re-
duction to
nontarget
organisms
Cancer
N.I.F Stomach
cancer
H Cancer
Status
Decision
under review
Hearing
awaiting
further
study
Decision
under review
-------
I
00
PH
Ho. Common Names
21
16 Dimethoate
22
23 DSMA
23
22
12 EFN
25 Erbon
Chemical and Biological Names Trade and Other Names
Diammoniufli ethylene blsdlthlo- Amoban
carbamate
0,0-Dl«ethyl S- (•ethylcarbaaoyl)-
•ethyl phoaphorodlthioate
Di(phenylmercury)dodecenyl-
•uccinate
Dl-n-propylmaleate iaoaafrole
condensate; n-Propyl isomer
Dlsodlua methanearsonate
DodecylauMmlum methanearsonate
EndrIn
Ethylmercury phosphate
0-Ethyl O-p-nltrophenyl phenyl-
phoa phono th loa te
a-(2,4,S-Trlchlorophenoxy)ethyl
2,2-dlchloroproplonate /
Usea Reason in IV status
Thyroid cancer
I Cancer
F Enbryotoxic
Cancer
Ethylane dibronlde 1,2-Dlbromoethane
Cancer
Cancer
Hazard to
nontarget
and en-
dangered
apecles
Delayed neuro-
toxicity
Dloxln
Stomach
cancer
Decision
under review
Decision
under review
Delayed
-------
PM
No. Comnon Names
15 Heptachlor
99
23
16
16
23 MAMA
21 Mancoceb
21 Maneb
25 Merphos
22
22
22
22
Chemical and Biological Names
Heptachlorotetrahydro-4,7-
methanolndene and related
compounds
3,4,5,6,7,7-Hexachloro-N-
(methylmercuri)-l,2,3,6-
tetrahydro-3,6-endometh-
anoph tha1Imlde
Lead acetate
Lead arsenate
Lead arsenate, basic
Monoammonium nethanearsonate
Zinc Ion and manganese
ethyleneblsdithlo carbanwte
Manganese ethyleneblsdlthlo-
carbamate
Trlbutyl phosphorotrlthloate
Mercuric chloride
Mercuric oxide
Mercurous chloride
Methyl mercury qulnolinolate
Trade and Other Names Uses Reason in IV Status
I
Memmi
Dithane M-45; Manzate
200
Manzate; Dithane M-22
Folex
Cancer
Embryotoxic
F Cancer
I,F,P Cancer
Cancer
H Cancer
F Thyroid cancer
F Thyroid cancer
Delayed neuro-
toxiclty
Hearing
Hearing
Decision
under review
Decision
under review
Decision
under review
Corrosive sublimate
Calomel
Metasol
F
F
F
F
Embryotoxic
Embryotoxic
Embryotoxic
Embryotoxic
Hearing
Hearing
Hearing
Hearing
-------
I
I-*
o
PM
No^ Common Names
12 Mlrex
2 5 Monuron
23 MS MA
21 Nabam
25
17
22
22
99 Paris green
24 PCP
24
Chemical and Biological Names Trade and Other Names
Dodecachlorooctahydro-1,3,4-
methene-1H-cyclobutafed]
pentalene
3-(p-Chlorophenyl)-l,l-di-
me thylurea
Monosodium acid nechane-
arsonate
Dlsodlum ethyleneblsdithiocarba-
mate
Octyl ammonium methanearsenate
Oil of camphor sassafrassy
10,10'-Oxybisphenarsazine
10,10'-OxyblsphenoxarsIne
Copper acetoaraenlte
Pentachloropheno1
Phenarsazlne chloride
Uses Reason In IV Status
I Cancer Hearing
H Cancer
Cancer
Thyroid cancer
Cancer
I Cancer
Contains
arsenic
(cancer)
F,S Contains
arsenic
(cancer)
Cancer
H.I.F.K Photodegrades
to dioxln
Decision
under review
Decision
under review
Decls ion
under review
Decision
under review
Decision
under review
H
Cancer
Decision
under review
22
Phenyl mercuric acetate
PMA
Embryotoxic Hearing
-------
Common Names
H
PM
No.
22
22
22
22
22
22
22
22
22
22
21 Folyram
21
22
25
Promamide
Chemical and Biological Names Trade and Other Names
Phenylmercuric ammonium acetate
Pheny liner curie ammonium propionate
Phenylmercuric borate
Phenylmercuric carbonate
Phenylmercuric 2-ethylhexoate;
Phenylmercuric octanoate
Phenylmercuric formamide
Phenylmercuric lactate
Phenylmercuric oleate
Phenylmercuric propionate
Phenylmercuric triethanol
ammonium lactate
Mixture of ammoniate of [Ethylene-
bis(dithiocarbamato)]zinc and ethylene-
bis[dithiocarbamate]
Potassium ammonium ethylene- Kaybam
bisdlthlocarbanate
Potassium mercuric iodide;
Potassium tetraido-
mercurlate
3,5-Dichloro-N-(l,l-dimethyl- Kerb
2-propynyl)-benzamide
Uses
F
F
F
F
F
F
F
F
F
F
Reason in IV
Embryotoxic
Embryotoxic
Embryotoxic
Embryotoxic
Embryo toxic
Embryo toxic
Embryotoxic
Embryotoxic
Embryotoxic
Embryotoxic
Status
Hearing
Hearing
Hearing
Hearing
Hearing
Hearing
Hearing
Hearing
Hearing
Hearing
Thyroid cancer
Thyroid cancer
Embryotoxic
Cancer
Hearing
-------
I
»-•
ro
PM
Mo. Common (taws
22
14 Ronnel
11
23 Sllvex
23
Chemical and Biologic*! Names
Pyridylmercurlc acetate
0,0-Dimethyl 0-<2,4,S-tri-
chloropheny 1 ) phosphor othlo-
ate
Safrole
2,4,5-Trlchlorophenoxy-
proploolc acid, salts,
and eaters
Sodium arsenlte; Sodium
metaarsenite
Trade and Other Names Uses Reason In IV Status
F Embryotoxlc Hearing
Korlan; Trolene I Derived from
2.4.5-T
(dloxln)
R Cancer
H Dioxln Delayed
contaminant
H.I Cancer Decision
under review
99
12
11 Strychnin*
11 Strychnine
Sodium ethylmercurithlo-
salicylate; [o-(Carb-
oxypheny1)th io]e thy1
mercury
Sodium pyroarsenate
Sp«rm oil
Strychnine (alkaloids)
Thimersol
Strychnine sulfate
R.B.M
R.B.M
Embryotoxlc
Cancer
Endangered
species
Population
reduction
to non-
target
organisms
Population
reduction
to non-
target
organisms
Decision
under review
Hearing
awaiting
further
study
Hearing
awaiting
further
study
-------
PM
No. Common Names
17 SuIfoxide
23 2,4.5-T
11
25 Tri-allate
25
16 Trichlorfon
22
21
21 Zlncb
Chemical and Biological Hangs
l,2-(Hethylenedioxy)-4-[2(octyl-
sulfinyl)-propylJbenzene; m-
Octyl sulfoxide of laosafrole
2,4,5-Trichlorophenoxyacetic
acid, salts and esters
Thai HUB sulfate
S-(2,3,3-Trichloroallyl)dliso-
propylthiocarbamate
S,S,S-Tributyl phosphorotri-
thioate
Dimethyl (2,2,2-trtchloro-
l-hydroxyethyl)phosphonate
2,4,5-Trichlorophenol, and
•alts
Zinc Mercury chroaate
Zinc ethyleneblsdithlo-
carhaaate
Trade and Other Names
Avadex BW
Def
Dlpterex; Dylox
Uses Reason in IV Status
I Cancer
Dioxln
R,M Population
reduction to
nontarget
organisms
H Cancer
Delayed
neurotoxiclty
Cancer
Dioxln con-
tanlnant
Delayed
hearing
Hearing
awaiting
further
study
Delayed
hearing
Eobryotoxlc Hearing
Thyroid cancer
Source: U.S. Envlronawntal Protection Agency, Washington, D.C., February 1976.
-------
EPA SCHEDULE OF PRESUMPTION NOTICE FOR PESTICIDES AND OTHER CHEMICALS
Date
August 1976
September 1976
October 1976
November 1976
December 1976
January 1977
February 1977
Chemical
Endrin, Toxaphene, Strobane, Compound 1080,
Strychnine, Lindane
Cadmium, DBCP, BHC, Dimethoate, Di-allate,
Tri-allate
Ethylene dibromide, Trichlorfon, Lead acetate,
PCNB, Paraquat, Ethylene oxide
EPN, Carbaryl, Arsenicals, Aramite, PGP
Creosote, Chloranil, Monuron, Benomyl, 2,4,5-Tri-
chlorophenol, DDVP
(SST)DEF, Piperonyl butoxide, Rotenone, Perthane,
Safrole, 2,4,5-T and related compounds,
Pronamide
Merphos, Sperm oil, EBDC
1-14
-------
APPENDIX J
CRITERIA FOR SELECTION OF PESTICIDES
J-l
-------
The information contained in Appendix J is incorporated into this report
to supply additional detail as to the methodology required to select or rank
a pesticide active ingredient according to its pollution potential. The in-
formation was taken from an EPA document entitled "Production) Distribution,
Use and Environmental Impact Potential of Selected Pesticides," by R von Rumker,
E. W. Lawless, and A. F. Meiners, EPA 540/1-74-001.
A systematic effort was made to select approximately 25 pesticides for
intensive study on this project* A goal was to select major pesticides that
would be representative of all the diverse uses of pesticides.
A preliminary rating was made for over 85 pesticides, based on estimated
production volume, use patterns, environmental concern and other criteria.
These ratings were reviewed with project officers from CEQ and EPA; the weight-
ings of certain criteria were revised slightly, a few new criteria were added,
and additional pesticides were suggested*
Approximately 125 pesticides were then divided according to activity
type (insecticides, herbicides, etc.) and chemical class and rated with the
results shown in Table J-l. A summary of these ratings is shown in Table J-
2 and the recommended pesticides are listed in Table J-3. The guidelines for
ratings are shown below. At the suggestion of EPA officials the organotin
compounds were selected in place of the copper compounds.
GUIDELINES FOR RATING PESTICIDES IN TABLE J-l
Production Rating Scale
Production
(am Ib/vear AI) Rating
Toxicity, Acute
LD50
< 1
1-4
5-14
15-29
30-49
50-99
100-200
> 200
0
+1
+2
+3
+4
+5
+6
+7
> 2,000
500-2,000
50-500
<50
0
1
2
3
J-2
-------
TABLE J-l
PESTICIDE PRIORITY RATING
I
U>
Charactcriatic
w
'reduction or Impo
Totel
+7
i
•
* c
3'"
+4
Agricultural Uaa
tl
a nit
Governmental Uae
±i
Use
• •
i i
i °
3 ?
i :
1 !
±1 ^
Eiwlron«ntal Concern
Toxicity, Manmali,
Acute
±3
Toxicity, Special
t4
Toxiclty, Birda
±i
Toxiclty, Plah
±i
Toxiclty, Invert.
±i
Per»istance
i±
BioBtgniflcaclon
±2
Environ. Mobility
±1
H Ida Spectrum
Activity
±1
•g
ReguUtlon Dlacun
±3
Regulatory
Interest
^
3
;
i
•0
R
S
S
•
•
a
3
|
41
3
m
£
2 i
e 2
Toxaphene
DOT
Chlordane
Aldrin
Mathoxychlor
Heptachlor
Dicofol
Endrlo
EadoKjlfin
Chlorobenzilate
Lladana and MIC
ODD
Carbaryl
Carbofuran
HatalkaaMte
Hethomyl
AUlcarb
Mathvl Parachlon
Malathlon
Parachlon
Dlazinon
Diaulfoton
phorate
Hoaocrotophoa
Cblopyrifoi
Azlnphoa-aiethy 1
•enaulCothlon
Drfonate®
Ethlon
Round
Carbophenthlon
Kalad
DUMthoate
Abate"
Olchlorvoa (DOVP)
Dlcrotophos
Inar.taalc Ar>*nate«
5
4
3
2
2
2
1
1
1
1
1
0
5
2
2
1
1
4
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2
2
2
2
2
"" " """ "~
0
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I
0
1
0
0
i
0
i
0
0
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0
0
0
2
0
0
0
Q
2
0
1
Q
4
0
~ ~ 0
3
1
2
3
1
3
1
2
2
2
2
2
3
3
3
3
3
3
2
3
2
3
3
3
0
3
3
2
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1
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1
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Q
0
2
~ ~ 3 ~
0
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_0_
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~ 2
a
0
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~ 0
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~ 0
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0
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3
2
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7
6
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u
4
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-3
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26 2
14
30 1
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12
16
4
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7
24 6
20 8
13
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18 10
20 9
20 7
11
5
1O
7
8
4
1
4
4
3
2
1
10
1
7
" Is" 10
-------
TABLE J-l (Continued)
Part • - Herbicide*
Production at
Characteriitic
lacing ' x
Seal* V
r*«icii>'^s>^
L Production or Inport,
p tottl
8w
i"
M
U Agricultural Ua*
ad Ua*
3
1 I
f 1
I i
-12 ±1
Cavironacntel Concern
9
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|t Toxiclty, Bird*
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h.
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&
+1
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|J. Per*i*tence
g
3
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fr
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±1 *JL
U Regulation Dl*cu**ed
Begulatory
. Intereat
2
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U No Available Alcamat
lu»
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+4
Other Criteria
IDecreaxd U*t Forecea
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<
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f!
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Propachlor
Alachlor
COM
Propanil
DlpheoMld
2,4-D
2.4.S-T
Dlcaaba
2.3.»-TBA
DCPA
Cndothall
Trifluralioi
Dlnoieb
HSU
MM*
CacodjHc A^d
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Diuron
Pluoemturon
Liwiron
•utylate
EPTC
Vamolete
ChorprophOB
TCA
JJe£pho* ,.
Chlorate- (orate
ttmnaium Sulfaaate
Sodiue Araeaite
1
4
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26 1
IS 10
13
18 S
8
s
5
6
22 2
u
7
13
IS 9
6
8
6
9
20 4
13
8
21 3
a
s
1* 7
16 8
6
7
6
10
12
s
3
13
a
10
8
18 6
8
9
-------
TABLE J-l (Continued)
Part C - fungicide* and Wood Preservative!
Production and U«e
Environmental Concern
Regulatory
intercut
Other Criteria
Oi
J
Characteristic §• • «
\ f) C • m
X • a :a
\ M ^
\ ° 3 :: "S •=
\ §fi §=> S I
Rating \ Jj S u - S
Scale \ 3 - S 3 £
V. \ fS .*-*«<«
P..Uc7de\ N! - 33
*^S\^+7 +4 +3 +2
Creosote 7 All
Coal Tars 6 A 0 0
Petroleum Oils 6 320
Jnorjsnlc Sulfur 6 030
Inorganic Coppera 4 221
Organo Coppera 1 310
Mercurial! 0 300
Chromates 2 400
FentacK'loropnenor ~ ~f ~ ~ ~4~ ~ 0 0
Trlchlorophenol 3 400
Pentachloronitro
Captan 0 0
Captafol 0 0
£olpet 0 0
Maneb 0 0
Hetham 0 0
Zlnel) 0 0
Zlraai 0 0
Ferbam 0 0
Nebam 0 0
Nleclde* 0 0
Pol/ram 0 0
Thlram 1 0
PETD 0 _0_
Dodlns 0 0
Benomyl 20 0
Dlnoc.p 00 0
.
Home and Cardea Ue
Export and Other U
Toxiclty, naanali,
Acute
+ 1 -1 +3
0 0 1
2 2 1
000
_ I _ 2 _<>_ _
002
002
1 0 3
002
1 0 2
0 0 1
£ 2 '
1 0 0
1 0 0
i 2 o
1 -1 0
1 O 1
1 -1 0
1 0 1
1 0 0
1 0 2
0 0 I
0 0 J
1 0 1
2 2_ l
1 0 1
1 0 0
1 O 1
Toxiclty, Special
Toxiclty, Blrda
+4 +1
A 0
A 0
0 0
0 0
0 0
0 0
0 1
1 0
A 0
3 0
1 0
2 0
1 0
1 2
4 0
0 0
4 0
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0 0
A 0
0 0
4 0
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_2 2 _
0 0
0 0
1 0
i
*-«
u
* -*4
o
f-l
+ 1 +1
1 1
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0 0
0 0
0 0
0 0
0 0
0 0
0 0
0 0
0 0
0 0
0 0
0 0
0 0
0 0
0 0
0 0
0 0
Persistence
Biomagnlflcation
+4 +2
2 1
_ 1 2 _
1 2
0 0
2 0
1 0
4 2
3 0
3 0
2 0
1 0
0 0
0 0
_ 2-2 _
I 0
0 0
0 0
0 0
0 0
0 0
0 0
0 0
1 0
_2 2_
0 0
0 0
0 0
Environ. Hobllity
Wldt Speccna
Activity
+ 1 +1
0 1
0 0
0 1
0 0
1 0
0 0
1 1
0 0
0 0
0 0
0 0
0 0
0 0
o 2
0 0
0 0
0 0
0 0
0 0
0 O
0 0
0 0
0 0
0 0
0 0
0 0
0 0
"8 3
Ragulaclon Discuss
Likely to be Cance
+ 3 -3
0 0
1 0
0 0
_ 2 _ _<>_
0 0
0 0
0 0
3 -3
0 0
0 0
0 0
1 °
2 0
0 0
_ 2 _ _o_
3 0
0 0
2 0
0 0
0 0
2 0
0 0
2 0
0 0
0 0
0 0
0 0
0 0
C *4
S a
"Wasteful" Use Pat
No Available Alter
+3 +3
1 3
_ _!_ 2 .
0 I
0 0
0 0
0 0
0 0
2 2
0 3
0 1
0 1
0 1
0 0
2_2_
0 0
0 0
0 0
0 0
0 0
0 0
0 0
0 0
0 0
_ 2 2
0 0
0 0
0 0
U M
• •
3 3
Increaaed Use For*
Decreaaed Uae Fore
+4 -4
0 0
0 0
0 0
0 0
0 0
0 0
1 0
0 -3
1 0
1 0
1 0
0 0
2 0
1 0
1 0
1 0
0 0
0 0
0 0
0 0
0 0
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1 0
0 0
0 0
1 0
1 0
0 0
•
-4 O.
A Leading Product
Important Crou
+8
8
4
2
4
8
0
4
A
A
8
4
2
8
4
A
a
4
2
0
0
0
0
0
A
0
6
6
2
2
Croup Already Well
Represented
Special Conslderat
-5 t5
0 1
-5 0
-3 0
0 0
0 0
-3 0
0 0
0 -2
_ a _ _o_
0 0
0 0
0 0
0 0
0 0
2 o
O 0
0 0
0 0
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0 0
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0
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it
4>
3
M
£
2 i
fi a
37 1
10 J
17 10
IS
21 S
5
20 6
17 10
_ 17_ 10
32 2
19 8
13
22 3
10
8
22 4
10
12
5
3
11
3
10
10
3
12
12
7
-------
TABLE J-l (Concluded)
Part D - Fu»l«
tic
Dlehlorobeniene
Methyl troaldc
Dlchloropropene
Propane
Echyl«n« Dlbronlda
Dlbroaochloropropane 2
Carbon Dleulflde-
Tetreehlorlde
Ethylene Dlchlorlde 2
jUchloronitroethmne O
Naphthalene
Echylena Oxlde-
_ CarbonJUoxlde l_
Aluolnun rhoiphide
Calcium Cyanide
Sulfuryl Fluoride
Production
(^Production or taport,
1 Total
S
3
3
3
2
2
2
.0
2
"o
0
0
I
* *
s;
!k_
3
2
0
3
0
2
2
_*__
1
_2
1
2
a
S
3
te
tl
I
2
2
0
1
1
~0~
_0_
1
0
«"* "•«
1
9
3
±2
i
0
0
0
0
0
_o
0
0
0
0
0
I
3
1
±i
i
0
1
1
0
0
I ~
0 ~
0
0
I
44
o
1
ii
HI
0
0
0
0
0
0
0 _
0 ~
2_
0
0
0
i.
w
x|
u
o
4*3
1
3
2
2
1
1
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0
_0
~3
3
1
|+.Toxicity. Special
0
0
0
0
0
0
0
0 _
0 ~
0 _
0 ~
0
0
Environ
£.Toxlclty, Slrde
0
0
0
0
0
0
0
0
«£ «
0
s_
0
0
0
£
m
u>
X
u
1
±i
0
0
0
0
0
0
0
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0
0
0
0
•encal
liloxlclty, Invert.
0
0
0
0
0
0
0
~o
_0
~0
0
0
Concern
«
u
|
A.
1
0
o
0
0
0
1
o~
0 ~
0
0
K> lloaagnlClcatlon
0
0
0
0
0
0
0
0 ~
0 ~
0
0
Regulatory
|i Environ. Mobility
0
0
0
0
0
0
0
~0
0
0
2,
U U
5*
0
1
0
0
0
0
0
0 ~ ~
T~~
1
0
•
S
« 1
O I/
5
«* Z
±2 o_
0 0
0 0
0 0
0 0
0 0
0 0
0 0
2 _ _°_ _
o o
2 _ _P_ _
0 0
0 0
0 0
S.
=3
M
?
12
0
a
0
0
0
0
0
0 ~
~ 0 ~
0
0
IwNo Available Alternat:
1
0
0
0
0
0
0
0 ~
2_
0
0
0
1*. Increaaed Uee Forecaei
|*-Decreaeed Ute Forecaei
1 0
1 0
0 0
1 0
1 0
0 0
0 0
V ~0~ ~
_o__p
0 0~~
0 -1
1 0
e
u
«.
c
•*4
•a
J
5
8
5
4
0
0
0
_o_
~
-------
TABLE J-2
SUMMARY OF RATINGS
Group
Rank
1
2
3
4
5
4
' 6
7
8
9
10
Insecticides
Chlordane
Toxaphene
Aldrln
Methyl Parathlon
Ma lath Ion
Carbaryl
Disulfoton
Carbofuran
Diazinon
Inorganic Arsenates
Total
30
26
25
25
25
24
20
20
20
18
Herbicides
Atrazine
2,4-D
MS MA
Trlfluralln
Alachlor
Chlorates
Bromacil
Diuron
Dlcamba
Simazine
Total
26
22
21
20
18
18
16
16
15
15
Fungicides
and
Preservatives
Creosote
PCP
Captan
Maneb
Inorganic Coppers
Organo Tins
Coal Tars
TCP
Chroma tes,
Petroleum Oils,
Mercurials (Tie)
Total Fumlgants
37 Dichlorobenzene
32 Methyl Bromide
22 Ethylene Dibromlde
22 Dichloropropene-propane
21 Aluminum Phosphide
20
20
19
17
Total
21
20
14
13
12
Parathion (Tie)
-------
TABLE J-3
PESTICIDES RECOMMENDED FOR STUDY
Pesticide Rating Total Type
1 Creosote 37 F
2 Pentachlorophenol 32 F
3 Chlordane 30 I
4 Toxaphene 26 I
5 Atrazine 26 H
6 Aldrin 25 I
7 Methyl Parathion 25 I
8 Malathion . 25 I
9 2,4-D 24 H
10 Carbaryl 24 I
11 Captan 22 F
12 Maneb 22 F
13 MSMA 21 H
14 Dichlorobenzene 21 Fu
15 Methyl Bromide 20 .Fu
16 Trifluralin 20 H
17 Diazinon 20 T
18 Disulfoton 20 I
19 Carbofuran 20 I
20 Parathion 18 I
21 Alachlor 18 H
22 Chlorates 18 H
23 Bromacil 16 H
24 Diuron • 16 H
25 Copper or organotin compounds (21)*/ F
I - Insecticide; H - Herbicide; F - Fungicide; Fu - Fumigant.
a/ The copper (and similarly the tin, chromium and mercury) fungicides
require special consideration because no single chemical compound
is involved.
J-8
-------
Toxicity* Special
Carcinogenic, teratogenic or mutagenic properties of the pesticide or
its impurities reported*
Toxicity
Toxicity to birds, fish or invertebrates resulting from normal use pat-
terns.
Persistence
The following scale has been used where possible, but persistence varies
with conditions and data are often unavailable*
Time
(months for 75-100%)
Disappearance
< 1 0
1-3 1
3-10 2
10-18 3
> 18 4
Biomagnification* wide spectrum activity and the categories under regula-
tory interest are largely self-explanatory. The "no alternatives available"
implies that no effective, economical substitute pest-control method is now
available for one or more major uses of the named pesticide*
The "increased" and "decreased use forecast" columns consider restric-
tions on competitive products and regulatory actions as well as normal mar-
ket potential.
The column, "A leading product is an important group," considers not only
the chemical class but also the use pattern* The highest rating is given to a
product that is a leading example of an important group in which no single
member is otherwise highly rated.
Special Considerations
DDT—
The decision to cancel most uses of DDT in the U.S. has already been made
by EPA in a special ruling.
J-9
-------
Aldicarb—
Pure aldicarb is the most toxic of major pesticides, but is marketed only
as a 10% granular formulation.
Methyl parathion—
The substitution of methyl parathion for the less toxic DDT on cotton has
necessitated a farm worker retraining program*
Disulfoton—
This product is especially representative of a large class of very toxic
agricultural insecticides.
Parathion—
The reentry controversy requires special considerations.
2,4,5-T-
The production of 2,4,5-T has dropped greatly since its military use was
halted and in addition, presently produced material contains little or none
of the objectionable chloro-dioxins formerly produced as an impurity.
Creosote—
The environmental aspects of this heavily used pesticide have been little
studied. Much creosote-treated wood is placed in close contact with water.
Mercurials—
The objectionalbe use of alkyl mercury fungicides for seed treatment has
been cancelled.
Dichlorobenzene—
Much of this chlorinated hydrocarbon is placed directly into wastewater
via lavatory use* and into the air we breathe at home and at work. Studies of
the environmental aspects are negligible to date, and the conventional method
used for analysis of chlorinated hydrocarbon pesticides in water does not
normally detect dichlorobenzene. It has, however, been detected in the blood
of workers exposed to it regularly and appears to accumulate in fatty tissues
like other chlorinated hydrocarbons.
A fundamental question of the definition of the word pesticide is raised
when one considers the lavatory use of dichlorobenzene (e.g., does it
kill organisms that cause odors?). Disinfectants are increasingly listed
with pesticides in some government statistics.
J-10
-------
APPENDIX K
ALTERNATIVE METHODOLOGY FOR SELECTING PLANT SITES
K-l
-------
This section of the report presents an alternate methodology and as-
sociated information base which could be used to select the best plant sites
for detailed source assessment. The methodology used entailed both a subjec-
tive and objective approach to the problem. Once the major subjective assump-
tions had been made and the known objective criteria had been assembled, the
number of pesticide plants was reduced to 25 candidates using a rating sys-
tem developed for this study. A "least number" of candidate plants that would
give a suitable sample for source assessment was then sought from this group
using further subjective and objective considerations. The "least number"
of plants selected was 12. Those plants are:
1. Monsanto, Anniston, Alabama
2. Montrose, Torranee, California
3. Hercules, Brunswick, Georgia
4. Eli Lilly, Lafayette, Indiana
5. Monsanto, Muscatine, Iowa
6. Ciba-Geigy, St. Gabriel, Louisiana
7. Dow, Midland, Michigan
8. American Cyanamid, Linden, New Jersey
9. Stauffer, Perry, Ohio
10. Ou Pont, LaPorte, Texas
11. Union Carbide, Institute and South Charleston, West Virginia
12. Ansul, Marinette, Wisconsin
Although these 12 plants are believed to be representative of the air
emissions problems and controls of the entire pesticide industry, we must
emphasize that the wide range of production processes leaves any small sample
inadequate to some degree.
The discussion which follows shows in detail how and why these 12
plants were chosen and is divided into the following sections.
. Selection Methodology: A Subjective and Objective Approach
. Estimated Total Production and Toxicity Rating of Pesticides by
Chemical Group
K-2
-------
. Identification of Pesticide Manufacturers and the Rating System
. Selection and Discussion of the 25 Best Candidate Pesticide
Plants
. Selection of the Least Number of Candidate Pesticide Plants
METHODOLOGY: A SUBJECTIVE AND OBJECTIVE APPROACH
The methodology used to select individual candidate pesticide plants in-
volves both a subjective and an objective approach. The subjective assump-
tions are valid only in general* Because the pesticide industry is very di-
verse in production processes, pollution control technologies, chemical in-
put materials, chemical process equipment, and other important parameters
which affect the pollution potential of a given plant, the subjective assump-
tions will not be true in every case*
The subjective approach to the selection of individual candidate pesti-
cide plants makes assumptions about the relative pollution potential of one
plant in comparison to other plants. The only parameters considered in the
assumptions are those for which quantitative data are currently available.
The major subjective assumptions made in this analysis are:
. A pesticide plant has a greater pollution potential as the total
volume of pesticides produced at that plant increases.
* A/!!«Cide Pl8nt haS a 8reater Pollution potential as the number
of different individual active ingredients produced increases.
. The greater the toxicity of the pesticide(s) produced at a pesticide
plant, the more serious the pollution potential of that plant.
The assumptions are used to determine which plants have the greatest pollu-
tion potential and therefore, are the best candidates for detailed source
oeeaeemanf- _
assessment
The objective approach to the selection of individual pesticide plants
compares plants to each other on the basis of the currently available quanti-
tative data on both manufacturers and formulators. The criteria which have
been quantified are:
• Total estimated production volumes of the major pesticides.
* Toxicity of individual pesticides.
• Chemical classification of the pesticides.
K-3
-------
• Identification of plant sites which manufacture pesticides and of
plant sites which manufacture the major pesticides.
• Number of individual pesticides and number of individual major pesti-
cides produced at each plant*
Unfortunately few or no quantitative data are available for the approxi-
mately 5,600 pesticide formulation plants in the United States. No information
is available on the volume of pesticide products formulated at each plant, or
on the type of pesticide products which are formulated at each plant.* With-
out this information, it is virtually impossible to select two or three
representative candidate plants for detailed source assessment. In addition,
the pesticide formulation industry is so diverse with respect to types of
pesticide products formulated, process equipment and techniques employed, and
other important criteria that source assessment of one or more plants, se-
lected on the basis of available data, would reveal very little about the
pollution problems of this major segment of the pesticide industry.
Therefore, the pesticide plants selected in this study for detailed
source assessment are all manufacturers of the active pesticide ingredients.
Even this selection poses a considerable problem since about 140 manufactur-
ing plants are currently operating, and many of these plants would be good
candidates for detailed source assessment.
The methodology used to select the candidate plants relies on the three
subjective assumptions and the five quantitative criteria given above. First,
the estimated production volume, toxicity rating, and chemical group designa-
tions of the major pesticides are given. Second, the 139 pesticide manufactur-
ing plants and the 73 pesticide manufacturing plants which produce the major
pesticides are identified; and the number of individual pesticides and num-
ber of individual major pesticides produced at each plant are given. These
statistics are used to rank the priority of assessing each plant in a rating
system developed for this study. Third, the best 25 candidate plants deter-
mined from the rating system and the minor pesticides produced at each plant
are listed. Finally, the least number (12) of plants are selected from the
group of 25 taking into consideration all of the quantitative data given and
subjective assumptions made, as well as other considerations where appro-
priate.
Information on the types and quantities of pesticides formulated by each
formulation plant are being submitted to EPA in accordance with Section
7 of the 1972 Amendments of the Federal Insecticide, Fungicide, and
Rodenticide Act. However, this information has not been made available
to the MRI project team.
K-4
-------
The detailed methodology used in this study is examined in the follow-
ing discussions.
ESTIMATED TOTAL PRODUCTION AND TOXICITY RATING OF PESTICIDES BY CHEMICAL
GROUP
The first important consideration in selecting individual candidate pes-
ticide plants is to select those plants which produce the pesticides made in
the largest quantities, the most toxic pesticides, and the pesticides repre-
sentative of the pesticide industry. Therefore, the first step in the selec-
tion process is to review the quantitative data on the pesticides themselves.
Table K-l summarizes data previously given in this report. The table
shows the estimated 1974 UoS, production of major individual synthetic or-
ganic pesticides and the toxicity rating of each pesticide. In addition, the
pesticides are presented in 11 separate groups (with subdivisions for the
organophosphates and carbamates). Ten of these groups (A through J) contain
individual pesticides that are similar in chemical composition and that are
produced by similar production techniques. The llth group (K) is a miscel-
laneous category. The pesticides listed in Table K-l are those that are pro-
duced in the largest quantities in each group, and shall hereafter be referred
to as the "major pesticides.1'
The toxicity rating for each pesticide is derived from the toxicity data
previously given. These ratings were determined as shown in Table K-2.
One important point should be noted regarding Table K-l. In Group H, the
usage of chlordane, aldrin, endrin, and heptachlor have recently been re-
stricted in the United States. Current and future production of pesticides
in this group will probably be low due to current EPA restrictions on pesti-
cides in this group unless a suitable export market exists.
IDENTIFICATION OF PESTICIDE MANUFACTURERS AND THE RATING SYSTEM
The list of pesticide manufacturers operating in 1975 is given in Table
K-3. This list shows 139 pesticide manufacturing plants and is, to the best
of our knowledge, complete. Each plant listed is given both by location and
by company ownership* This table also shows the number of individual active
ingredients produced at each plant, the number of major pesticides produced
at each plant, and the rating of each plant. All of the information in the
table, except the ratings, was obtained from SRI (1976).
Table K-4 , based upon SRI (1976) data, was constructed to
show which plants and how many produce the major pesticides. This table shows
that 73 plants produce the major pesticides, that 26 major pesticides are pro-
duced at only one plant, and that 30 of the plants produce more than one major
pesticide.
K-5
-------
TabU K-l. ESTIMATED U.S. PRODUCTION AND TOXXCITY RATINGS OF MAJOR
INDIVIDUAL SYNTHETIC ORGANIC PESTICIDES, BY CATEGORY, IN 1974
Group
designation Chemical group
A Chlorinated hydrocarbons
B Organophoaphates
(I) Phosphates
(2) Phoaphorothloaeas
(3) Phoaphorodithioates
C Carbamatas
(1) Carbamatas
(2) Thiocarfaaoates
<3) Olthiocarbamates
0 Trlasines
E Anilides
F OrtanoertenicaU and
organoise tallies
Pesticide
Toxaphene
DOT
2,4-D acid, esters, salts
PCP and sodium salts
Trichlorophenols
Dichloropropene
Chloramben
OBCP
Sodium TCA
All others
Monocrotophos
Methyl parathion
Parathion
Dlasinon
Fensulfothlon
Malathioa
Disultoton
Phorate
Marpho*
All others
Carbaryl
BUJC®
Carboruran
M« thorny!
Aldicarb
Benoayl
Butylate
EPTC
Vemolate
Manab
Ziaab
Maban
All others
Atrasine
Slaasine
Ptopatina
All others
Propachlor
Alachlor
Propanil
Butachlor
MSMA
DSMA
Cacodylic acid
Copper naphthaaates
All Bothers
Estimated 1974
production
(oil lion Ib)
110 .
°®/
5S/
32*
23
24
22
20
13
77
460
7 .
31s
17
12
6
30
10
10
3
-22
200
38
10
10
10
3
4
a
6
3
12
7
3
vo
130
110
13
10
-12
130
43
40
15
-12
110
33
10
3
2*
_J
33
Approximate percentage
of production
In each zrouo
24
13
12
11
6
6
3
4
3
16
100
4
23
9
6
3
13
3
3
2
26
100
39
7
7
7
3
2
3
4
3
8
3
3
7
100
73
10
7
-IS
100
41
36
14
_2
100
64
18
3
3
-IS
100
Toxicity
rating
2
2
2
3
I
2
1
2
1
-
3
4
4
2
4
1
3
4
2
-
2
2
3
3
4
0
I
I
1
1
1
2
.
1
I
0
-
1
I
1
1
.
I
1
1
*
K-6
-------
Table K-i (concluded)
Group
designation
Chemical Krouo
Pesticide
Other nitrogenous compound* Captan
COAA
Maleic hydrasid*
Mlcralln
Piclor im
Captafol
Folpet
All other*
Diane-based
Ureas and ur sells
Nitrated hydrocarbon*
All others
Chlordan*
Aldrin
Endrin
Heptachlor
EndosuUan
All other*
Brcoacil
Diuron
Flueoeturon
Llnuron
Terbaxil
All others
TriUuralin
Chloroplcrln
Oinoseb
Benefin
All other*
Methyl bromide
Hitcvllaneou*
Total all synthetic organic pesticides
Estimated 1974
production
(million Ib)
20
3
3
3
3
21
70
40
12
10
5
3
3
_7
40
3
3
_4
40
31*'
_Z1
102
Approximate ptrc«nt»g«
of production Toxlclty
In each group retina
29
10
9
4
4
4
100
38
23
7
7
7
100
30
23
13
7
7
100
63
13
7
7
-12
100
30
Too
Source! MB1 estimates (February 1976)
j/ Based upon DDT exports uf 56.4 oillion pounds (1001 basis) in 1974 as reported in The Pestiftide Riviev. 1974 (1973).
^/ Based upon report
-------
Table K-2. PESTICIDE TOXICITY RATINGS
Rating Classification
0 Insignificantly toxic
1 Slightly toxic
2 Moderately toxic
3 Highly toxic
4 Extremely toxic
Oral LD5Q - rats
(mg/kg)
Above 5,000
500-5,000
50-500
5-50
Below 5
K-8
-------
Table K-3. PLANT LOCATION, COMPANY OWNERSHIP, NUMBER OF PESTICIDES PRODUCED,
AND RATING FOR EACH PESTICIDE MANUFACTURING PLANT IN THE U,S. IN 1975
Plant location
Anniston, AL
Cold Creek, AL
Mclntosh, AL
Mobile, AL
Oxford, AL
El Dorado, AR
Jacksonville, AR
Brea, CA
Fremont, CA
Long Beach, CA
Long Beach, CA
Monrovia, CA
Pittsburg, CA
Richmond, CA
Richmond, CA
Torranee, CA
Trona, CA
Boulder, CO
Denver, CO
Denver, CO
Denver, CO
Bethel, CT
Naugatuck, CT
Company
Monsanto
Stauffer
01 in
Shell
Tull
Great Lakes
Transvaal
Thorapson-Hayward
Am-Chem
Niklor
Tenneco
Pennwalt
Dow
Chevron
Stauffer
Montrose
Kerr-McGee
Syntex
Alpha
ASARCO
Shell
R. T. Vanderbilt
Uniroyal
No. of
pesticides
produced
2
9
2
4
1
2
16
2
10
1
1
1
2
4
2
1
1
1
1
1
9
1
1
No. of
pesticides
in Table K-l
produced Rating
2
3
0
1
0
2
2
0
1
1
0
0
2
1
0
1
1
0
0
0
5
1
0
5
5
0
4
0
4
5
0
4
1
0
0
4
4
0
5
1
0
0
0
5
1
0
-------
Table K-3 (continued)
Plant location
Stamford, CT
New Castle, DE
Orlando, FL
Brunswick, GA
Chicago, IL
Chicago, IL
Chicago, IL
Chicago Heights, IL
Marshall, IL
North Chicago, IL
Sauget, IL
East Chicago, IN
Lafayette, IN
Clinton, IA
Ft. Madison, IA
Muscatine, IA
Shenandoah, IA
Kansas City, KS
Kansas City, KS
Pittsburg, KS
Wichita, KS
Carrolton, KY
Geismar, LA
Luling, LA
Company
Northeast Pharmaceutical
Witco
Chevron
Hercules
Glenn
Nor-Am
Ventron
Riverdale
Northwest Industries
Abbott Labs
Monsanto
Du Pont
Eli Lilly
Am-Chem
Chevron
Monsanto
Imperial
PBI-Gordon
Thorop son-Hayward
Gulf Oil
Vulcan
M&T Chemical
Uniroyal
Monsanto
No. of
No. of pesticides
pesticides in Table K-i
produced produced Rating
1
1
2
1
1
7
1
10
1
4
3
2
6
1
1
4
1
7
5
2
1
1
2
2
1
0
0
I
0
1
0
1
1
0
1
1
2
0
1
4
1
1
1
0
1
0
1
0
1
0
0
5
0
3
0
4
1
0
5
2
5
0
5
5
1
3
3
0
3
0
1
0
-------
Table K-3 (continued)
Plant location
Norco, LA
Plaquemine, LA
St. Gabriel, LA
St. Gabriel, LA
Orrington, ME
Baltimore, MD
Curtis Bay, MD
Midland, MI
St. Louis, MI
Wyandotte, MI
Minneapolis, MN
Hamilton, MS
Vicksburg, MS
Cadet, MO
Kansas City, MO
Maryland Heights, MO
St. Joseph, MO
St. Louis, MO
St. Louis, MO
Henderson, NV
Bayonne, NJ
Berkley Heights, NJ
Clark, NJ
Clifton, NJ
Campany
Shell
Hercules
Ciba-Geigy
Stauffer
Sobin
FMC
Diamond Shamrock
Dow
Northwest Industries
Pennwalt
McLaughlin Gormley King
Kerr-McGee
Vicksburg
Buckman Labs
Chemagro
Chevron
Am-Chem
Mallinckrodt
Monsanto
Stauffer
White
Kewanee
MOTOMCO
Cos an
No. of
pesticides
produced
1
2
16
3
1
3
1
28
1
2
10
1
3
2
21
2
10
2
1
1
1
1
3
3
No. of
pesticides
in Table K-l
produced Rating
1
0
5
2
1
0
0
7
1
1
0
1
2
0
2
0
1
0
0
0
0
0
0
0
3
0
5
4
1
0
0
5
1
1
4
3
4
0
5
0
4
0
0
0
0
0
0
0
-------
Table K-3 (continued)
Plant location
Edison, NJ
Elizabeth, NJ
Fords, NJ
Great Meadows, NJ
Hawthorne, NJ
Linden, NJ
Linden, NJ
7 Lyndhurst, NJ
£ Montville, NJ
Newark, NJ
Newark, NJ
Newark, NJ
Newark, NJ
New Brunswick, NJ
Somerset, NJ
Somerset, NJ
South Plainfield, NJ
Vineland, NJ
Wood Ridge, NJ
Woodbrldge, NJ
Albany, NY
Ardsley, NY
Central Islip, NY
Niagara Falls, NY
Company
Blue Spruce
Tenneco
Tenneco
Ashland Oil
Merck
American Cyanamid
Du Pont
S. B. Penick
S. B. Penick
Fairmount
Prentiss Drug
Sobin
Troy
Rhodia
Rhodia
W. A. Cleary
Chevron
Vineland
Ventron
American Cyanamid
Chempar
Stauffer
McKenzie
Occidental
No. of
pesticides
produced
13
4
4
2
5
6
3
3
7
1
9
1
7
6
7
8
2
9
13
1
1
3
1
8
No. of
pesticides
in Table K-l
produced Rating
6
0
1
0
0
2
0
0
0
1
3
1
0
0
1
1
0
3
0
0
0
0
0
1
5
0
4
0
0
5
0
0
3
1
5
1
3
3
3
3
0
5
4
0
0
0
0
3
-------
Table K-3 (continued)
Li
Plant location
Middleport, NY
Gastonia, NC
Greensboro, NC
Raleigh, NC
Barberton, OH
Bedford, OH
Dover, OH
Perry, OH
Perry, OH
Portland, OR
Ambler, PA
Bristol, PA
Danville, PA
Delaware Water Gap, PA
Eighty Four, PA
Hanover, PA
Philadelphia, PA
State College, PA
Elgin, SC
Chattanooga, TN
Memphis, TN
Memphis, TN
Mt. Pleasant, TN
Mt. Pleasant, TN
Company
FMC
Uniroyal
Pfizer
Mallinckrodt
PPG
Ferro
Dover
Chevron
Stauffer
Chempar
Am-Chem
Rohm and Haas
Merck
Heico
West Chemical
Alco
Rohm and Haas
Nease
Hardwicke
Northwest Industries
Buckman Labs
Northwest Industries
Mobil
Stauffer
No. of
pesticides
produced
10
1
1
1
2
1
1
2
3
6
22
2
1
1
1
1
8
1
2
1
2
3
3
3
No. of
pesticides
in Table K-l
produced Rating
3
0
0
0
0
0
1
2
2
1
2
0
0
0
0
0
3
0
0
0
0
2
1
2
5
0
0
0
0
0
3
4
5
3
5
0
0
0
0
0
5
0
0
0
0
0
4
4
-------
Table K-3 (concluded)
Plant location
Bayport, TX
Beaumontt TX
Deer Park, TX
Freeport, TX
Greens Bayou, TX
Groves, TX
Houston, TX
LaPorte, TX
Texas City, TX
Hopewe11, VA
Portsmouth, VA
Tacoma, WA
Vancouver, WA
Belle, WV
Nltro, WV
Nitro, WV
Nitro, WV
Institute and South Charleston, WV
Marinette, WI
Milwaukee, WI
Company
Northwest Industries
Northwest Industries
Shell
Dow
Diamond Shamrock
Riverside
Sonford
Du Pont
GAP
Allied
Virginia Chemical
Reichhold
FMC
Du Pont
Chemical Formulators
Pike
Monsanto
Union Carbide
Ansul
Aldrich
No. of
pesticides
produced
1
1
1
3
4
1
1
8
1
1
1
3
1
1
5
4
2
2
5
1
No. of
pesticides
in Table K-l
produced
0
0
1
2
2
1
0
6
1
0
0
1
1
1
1
1
0
2
4
0
Rating
0
0
3
5
4
3
0
5
3
0
0
2
1
4
3
2
0
5
5
0
-------
The information presented in Tables K-3 and K-4 was used to develop a
rating system for this study to give a priority ranking for the pesticide
manufacturing plants as candidates for detailed source assessment. The rating
system was constructed so that the plants which are selected for source assess-
ment are characterized by the following features.
• They produce the pesticides with the largest total volume.
• They produce the greatest total number of individual pesticides.
• They produce pesticides in as many of the 11 groups as possible.
Thus, the final selection of candidate plants aims at choosing plants which
represent the large volume pesticides, the largest number of individual pes-
ticides, and the largest variety of pesticides by chemical class.
The important variables considered in the rating system, then, and the
effect these variables have on the rating of a plant are:
• The number of individual pesticides produced at a plant. The more
pesticides produced, the higher the rating.
• The number of major pesticides produced at a plant. The more major
pesticides produced, the higher the rating.
• The number of plants which produce a given pesticide. The greater the
number of plants which produce a given pesticide, the lower the rating
for those plants which produce that pesticide when considering that
pesticide alone.
• The total production volume of the pesticides produced by the industry.
The higher the total volume of a pesticide produced by the industry,
the higher the rating of a plant which produces that pesticide.
Each of these variables was considered in constructing a rating scale
from 0 to 5 with 5 as the highest priority rating. Bach plant was given a
rating as shown in Table K-l, and these ratings were generally determined as
follows:
Rating Criteria
0 Plant produces fewer than five pesticides and produces no major
pesticides.
1 Plant produces one pesticide which is a major pesticide whose
estimated total annual production is less than 10 million
pounds at that plant. The pesticide is produced by other
plants which produce more pesticides than the subject plant.
K-15
-------
Tiir NA.IOI nmirric IWAKIC Rinrioc.s, in urn C«I«T. IK i
Toxaphtnt
DOT
Chloranban
Sodlua TCA
Croup B
<1) Honocrotopho*
(*> M*lhyl pa rat hi on
O) MalatMon
DiiuUoton
Mtrphoi
Croup i_C
(1) C.rbaryl
Bux
C.rboiunn
Hethonyl
Aldlearb
B*nonyl
(2) ButyUtl
v«rnolar«
(3) Hancb
Zln.b
HA ban
Croup D
Atrailn.
Sloatln.
Prop* tin*
Uroup E
PropAchlor
AlacMor
Propanll
Butachlor
Cfeup__T
HSHA
DSMft
Cicodyllc «eld
rroup n
Ciptan
CQAA
MileTc hjdrarldt
Mtralln
Plclorio
Captafol
Folptt
' roup H
Aldrln
Endrln
Hcptachlor
End HU Kan
Croup I
Bronte 11
Llnuron
T»rb«fll
Cr«jp_J
TrlfluraHn
Chloroplerin
Olnoi»b
D*n«fln
Hroup^
H«thyl broolda
j
j
j
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b
tt
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11
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6
1
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A
Total Pairlcldti, In Hit,
pioduc«4 »t ••eh plant
Total •!! p«atlctd*i pro-
duced «t ««ch plant
<
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X
•
}
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e
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X
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Rating Criteria
2 Plant produces two to four pesticides, and one major pesticide whose
total annual production is less than 10 million pounds. The major
pesticide is produced by other plants which either produce other
major pesticides or produce a greater number of pesticides than
the subject plant.
3 (a) Plant produces five or more pesticides and one major pesticide
whose total annual production is less than 10 million pounds. The
major pesticide is produced by other plants which produce other
major pesticides also.
(b) Plant produces one to three pesticides, and one is a major pes-
ticide whose total annual production exceeds 10 million pounds.
The major pesticide is produced by other plants which produce
more of the major pesticide or more total major pesticides than
the subject plant.
(c) Plant produces five to nine pesticides and no major pesticides.
4 (a) Plant is the sole producer of one major pesticide whose total
annual production is less than 10 million pounds. Plant may pro-
duce other pesticides also.
(b) Plant produces two major pesticides, and each major pesticide
is either produced by plants with a 5 rating or has an annual
production of less than 10 million pounds and is produced by
other plants also.
-------
SELECTION AND DISCUSSION OF THE 25 BEST CANDIDATE PESTICIDE PLANTS
The 25 best candidate pesticide plants for detailed source assessment
were selected by the rating system just described. Table K-3 shows that 25
plants received a rating of 5, and these plants are the best candidates of
the 139 plants listed based upon the data available and the methodology used
in this study.
The objective in this section is to compare the 25 plants to each other
so that a minimum number of plants emerge as the best candidates of this
group. The best plants selected should produce the high volume pesticides,
the most toxic pesticides, the greatest number of pesticides, and pesticides
which are members of as many of the 11 chemical groups as possible. Obviously,
some trade-offs must be made to limit the number of plants selected.
In order to select the least number of plants from the group of 25, fur-
ther analysis and description of each plant is requisite so that the relative
merits of each plant may be compared to the others. These descriptions give
a list of the minor (or other) pesticides produced at each plant, the chemical
group each of the minor pesticides is a member of, and the number of other
plants which produce each minor pesticide. (Note: Minor pesticides, as used
here, are all pesticides not listed in Table K-l.) The major pesticides pro-
duced at each plant have already been described in detail in Tables K-l and
K-4.
Each plant is listed separately below, and the minor pesticides produced
at each plant are described.
1. Monsanto, Anniston, Alabama
Minor pesticides: None
2. Stauffer. Cold Creek, Alabama
Minor pesticides Group No. of other producers
Carbophenthion (Trithion®) B3 0
Bensulide (Prefar®) B3 0
Cycloate (Ro-Neet®) C2 0
Molinate (Ordrao®) C2 0
Dyfonate® B3 0
Pebulate (Tillam®) C2 0
K-19
-------
3. Transvaal, Jacksonville, Arkansas
Minor pesticides
2,4-DP
2,4-D, n-butoxyethyl ester
2,4-D, n-butyl ester
2,4-D, N,N-dimethyloleyl linoleylamine salt
2,4-D, iso-octyl ester
2,4-D, isopropyl ester
2,2-dichloropropionic acid
2,4,5-T
2,4,5-T, n-butoxyethyl ester
2,4,5-T, n-butyl ester
2,4,5-T, N,N-dimethyloleyl linoleylamine salt
2,4,5-T, iso-octyl ester
2,4,5-T, triethylamine salt
No. of other
producers
Silvex
4. Montrose, Torrance, California
Minor pesticides: None
5. Shell, Denver, Colorado
Minor pesticides
Bladex®
Dichlorvos (Vapona®)
Bidrin®
Mevinphos (Phosdrin®)
Ciodrin®
D
1
6. Hercules. Brunswick, Georgia
Minor pesticides: None
7. Monsanto. Sauget. Illinois
Minor pesticides
Santophen r-
•MM^^B •
A
A
A
A
A
A
A
A
A
A
A
A
A
A
0
3
9
0
9
3
0
1
3
2
0
7
2
1
No. of other producers
0
1
0
1
0
No. of other producers
K-20
-------
8. Eli Lilly, Lafayette, Indiana
Minor pe sticides Group No» of other producers
Dipropalin J 0
Diphenylacetonitrile G 1
Chloroethylmercury F 0
Piperalin (Piprorf®) G 0
9. Chevron. Fort Madison, Iowa
Minor pesticides: None
10. Monsanto, Muscatine, Iowa
Minor pesticides: None
11. Ciba-Geigy, St. Gabriel, Louisiana
Minor pesticides Group No. of other producers
Prometryne (Caprol®) D 0
Igran 80 W® D 0
Chlorazine (Princep® 80 W) D 0
Cloroxuron (Tenoran®) I 1
Chlorophenamidine G 1
Preforan® J 0
Atratrone D 0
Aznetryne (Evil<^) D 0
Chlorobenzilate A 0
Acaralate® A 0
Prometone (Pramitol ) D 0
K-21
-------
Dow, Midland. Michigan
Minor pesticides
Rue Lene®
Dinoseb, alkanolamine salt
2,4-D, n-butoxyethyl ester
2,4-D, butoxypolypropyleneglycol ester
2,4-D, butoxy propyl ester
2,4-D, sec-butyl ester
2,4-D, dimethylamine salt
2,4-D, ethanolamine and isopropanolamine salts
2,4-D, iso-octyl ester
2,4-D, isopropyl ester
2,4-D, sodium salt
Dalapon®
Chlorpyrifos (Dursban®)
Mexacarbate (Zectran®)
Ronnel (Korlan®)
2,4,5-T
2,4,5-T, sodium salt
2,4,5-T, butoxyethanol ester
2,4,5-T, butoxypolypropyleneglycol ester
Silvex
13. Chemagro, Kansas City, Missouri
No. of other
producers
B
J
A
A
A
A
A
A
A
A
A
A
B2
Jl
A
A
A
A
A
0
0
3
0
0
1
8
0
9
3
1
0
0
0
0
1
0
0
0
1
Minor pesticides
Sencor®
Gophacide®
Chlonitralid (Bayluscide®)
Dyrene®
Coumaphos (Co-Ral®)
Demeton (Systox®)
Azinphosmethyl (Guthion®)
Fenthion (Baytex®)
Fenitrothion
Methiocarb (Mesurol®)
Monitor®
Chlorphos (Dylox®)
Ediphenos (Hinosan®)
Methyl demeton (Meta-Systox®)
Morestan®
Propoxur (Baygon®)
Dexon®
Fenamiphos
D
B
J
D
I
B
l
B
B
No. of other producers
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
K-22
-------
14. Blue Spruce, Edison, New Jersey
Minor pesticides Grou
2-(2-butoxyethoxy)ethyl thiocyanate K
Dinoseb, triethano lamina salt J
DNOC J
DNOC, sodium salt J
Thanite K
Rotenone K
Warfarin K
15. American Cyanamid, Linden, New Jersey
Minor pesticides
Famphur (Warbex^)
Dimethoate (Cygon®)
Polyacrylonitrile, hydro lyzed, sodium salt
No. of other producers
B
B
1
1
0
0
2
5
3
No. of other
producers
0
°
1
0
1° • Prentiss Drug. Newark, New Jersey
Minor pesticides Group
L indane
Thiodiphenylamine
Pyrethrum
Rotenone
Methoxychlor
Warfarin
H
G
K
K
A
K
No. of other producers
1
1
3
5
2
3
17. Vineland, Vineland. New Jersey
Minor pesticides
Bis-l,4-bromoacetoxy-2-butene
Cacodylic acid, sodium salt
Methanearsonic acid, calcium acid salt
Methanearsonic acid, dodecyl- and
octyl-anmonium salts
Methylarsine oxide
Methylarsine sulfide
K
F
F
F
F
F
No. of other
producers
0
0
0
1
0
0
K-23
-------
18. FMC, Middleport, New York
Minor pesticides
Dinoseb, ammonium salt (Sinox® General)
Dinoseb, triethanolamine salt (Sinox® PE)
Dichlone
Ferbam
Karbutilate (Tandex®)
Polyram (Polyram®)
Rotenone
19. Stauffer, Perry. Ohio
Minor pesticides Group
PMM K
20. Am-Chem. Ambler, Pennsylvania
Minor pesticides
r
Chloramben, ammonium salt
Amitrole
Amex 820
Ethrel®
Bromoxynil, octanoic acid ester
2,4-DB, dimethylamine salt
2,4-D, n-butoxyethyl ester
2,4-D, n-butyl ester
2,4-D, dimethylamine salt
2,4-D, iso-octyl ester
Coumafuryl
Cantrol
NAA
Rootone®
NAA, ethyl ester
NAA, sodium salt
2,3,6-TBA, dimethylamine salt
2,4,5-T, n-butoxyethyl ester
Fenac®
TIBA
A
G
G
A
A
A
A
A
K
A
K
G
K
K
A
A
A
A
J
J
A
K"
No. of other
producers
0
1
0
1
0
0
5
No. of other producers
No* of other producers
3
1
0
0
0
0
3
9
8
9
2
1
0
0
0
0
2
3
2
1
K-24
-------
21. Rohm and Haas, Philadelphia, Pennsylvania
Minor pesticides Group No. of other producers
Perthane® A 0
Pronamide A 0
Nitrofen (Tot^) J 0
DicofoL (KeLthane®) A 0
Karathane® J 1
22. Dowt Freeport, Texas
Minor pesticides Group No. of other producers
Amitrole (Tordon®) G 1
23. Du Pont, LaPorte, Texas
Minor pesticidejs Group No. of other producers
Monuron (Telvar®) I 0
Metam C3 3
24. Union Carbide^ Institute and South Charleston, West Virginia
Minor pesticides: None
25. Ansul, Marinette, Wisconsin
Minor pesticides Group No. of other producers
Naptalam G 1
All of the information on the 25 plants presented to this point is sum-
marized in Table K-5 for convenient reference. Table K-5 lists each of the
25 plants and shows the following information.
• The pesticides which have an estimated annual production of 25 mil-
lion pounds or more and the plants which produce those pesticides.
• The major pesticides which are either extremely toxic (4 toxicity
rating) or highly toxic (3 toxicity rating), and the plants which
produce those pesticides.
• The 11 chemical groups and plants which produce major pesticides in
those groups, and the plants which produce minor pesticides in those
groups.
K-25
-------
Table K-5. SUMMARY OF IMPORTANT CHARACTERISTICS OF EACH OF THE 25 BEST CANDIDATE PESTICIDE PLANTS FOR DETAILED SOURCE ASSESSMENT
to
Plant
Largest volume
pesticides
Host toxic pesticides
j3
£ c n. c
0 S t> 5
J2 Mo. of major pesticides produced No. of minor pesticides produced
•SSogTJp.S'E'See-o in pesticide groups in pesticide arouns
• «.J3«~Hl}«4««l6
-------
This Cable is important to the selection of the least number of candidate
plants from this group of 25, and this selection is made in the next section.
SELECTION OF THE LEAST NUMBER OF CANDIDATE PESTICIDE PLANTS
All of the 25 plants given in the previous section are excellent candi-
dates for detailed source assessment. The objective of this section of the
report is to eliminate as many of the plants in this group as possible to re-
duce the amount of effort required to perform a suitable assessment of the
pollution problems of the pesticide manufacturing industry. At the same time,
however, the group of pesticide plants selected must be representative of this
industry.
For a suitable representative sample of plants, the following criteria
must be met.
• All pesticides produced in annual quantities in excess of 25 million
pounds should be produced at the selected plants.
• All 11 chemical groups should be adequately represented in the plant
selection. Pesticides which constitute at least 30% of the annual
production volume in each chemical group should be manufactured at
the selected plants. (This excludes Group H, since the major pesti-
cides in this group have restrictions upon their usage and the cur-
rent production volume of this group is very low.)
• Most of the extremely and highly toxic major pesticides should be
produced at the selected plants.
Plants are first selected that produce the large volume pesticides; then plants
are selected to fill the gaps these large volume pesticide producers leave
in the chemical groups. (Some of the groups have no pesticides whose annual
production volume exceeds 25 million pounds--namely, Groups G, H, and I.)
Finally, the most toxic pesticides are reviewed to see how many of them are
produced by the plants selected by the first two criteria.
Large Volume Pesticide Representation
Table K-5 indicates that the 11 large volume (25 million pounds annually
or more) pesticides can be sampled by selecting as a minimum these plants.
• Hercules, Brunswick, Georgia (toxaphene).
• Ciba-Geigy, St. Gabriel, Louisiana (atrazine).
• Montrose, Torrance, California (DDT).
K-27
-------
. Union Carbide, Institute and South Charleston, West Virginia
(carbaryl).
• Dow, Midland, Michigan (2,4-Dj PCPj methyl bromide; trichlorophenols).
• Monsanto, Anniston, Alabama (methyl parathion).
• American Cyanamid, Linden, New Jersey (malathion).
• Eli Lilly, Lafayette, Indiana (trifluralin).
All eight of these plants are selected as candidates for source assessment
in this study for the following reasons.
Hercules, Brunswick, Georgia—
Hercules is the largest producer of toxaphene in the United States. Three
other plants produce toxaphene in annual amounts of about LO million pounds
each, whereas Hercules produces about 75 to 80 million pounds annually. None
of the other three plants is in the group of 25, and to exclude Hercules from
the selection would exclude toxaphene, the largest volume pesticide in the
United States (along with atrazine).
Ciba-Geigy, St. Gabriel, Louisiana--
Ciba-Geigy is the- sole producer of atrazine, as well as the sole producer
of simazine and propazine, and cannot be excluded from consideration without
excluding these three important pesticides, which constitute 90% of the produc-
tion volume in Group 0, the triazines, and have an estimated combined annual
production of 135 million pounds.
Montrose, Torrance, California--
Montrose is the sole producer of DDT, and therefore this plant must be
selected to examine the pollution potential of the manufacture of this high
volume (60 million pounds annual production) pesticide.
Union Carbide, Institute and South Charleston, West Virginia--
Union Carbide is the sole producer of carbaryl and aldicarb. Carbaryl
represents about 40% of the total annual production of carbamates (Group C),
and aldicarb is the most toxic major pesticide in the carbamate group. Union
Carbide cannot be excluded without excluding these two important pesticides.
Dow, Midland, Michigan—
Dow produces four major pesticides that have a combined annual produc-
tion of about 160 million pounds, produces two other major pesticides (DBCP
and dinoseb) that have a combined annual production of about 23 million
pounds, and is the sole producer of sodium TCA that has an estimated annual
production volume of 15 jaillion pounds. This Dow plant also produces 21 minor
pesticides (12 of which are produced only at this plant) that fall into four
different chemical groups.
K-28
-------
Dow produces more major pesticides (7) and more minor pesticides (21)
than any other plant in the United States. This plant cannot be excluded from
consideration without substantially reducing the validity of a source assess-
ment study.
Monsanto, Anniston, Alabama—
Monsanto produces the extremely toxic pesticides parathion and methyl
parathion. The combined annual production of these pesticides is about 70
million pounds or about 35% of the total annual organophosphate production
(Group B). Due to the high volume and high toxicity of these pesticides, a
valid source assessment program should include examination of these pesti-
cides.
Monsanto has the largest capacity (50 million pounds annually) in the
pesticide industry to produce both parathion and methyl parathion and is
chosen as the best plant for studying the pollution potential of the manu-
facture of these pesticides.
American Cyanamid, Linden, New Jersey--
American Cyanamid is one of three plants which produce malathion and is
the sole producer of phorate, an extremely toxic organophosphate pesticide.
Malathion is produced in an estimated quantity of 30 million pounds and phorate
is produced in an estimated quantity of 10 million pounds. These two pesticides
represent 207, of the total annual organophosphate production.
American Cyanamid is chosen over the Blue Spruce, Edison, New Jersey,
and Prentiss Drug, Newark, New Jersey, plants, which are the other producers
of malathion, since the American Cyanamid plant has the largest capacity for
organophosphates (in our estimation) among these plants and is the sole pro-
ducer of phorate.
Eli Lilly, Lafayette, Indiana—
Eli Lilly is the sole producer of trifluralin and benefin, two nitrated
hydrocarbon pesticides (Group J)»' The combined annual production of these two
pesticides is about 28 million pounds or 70% of the total annual production
in Group J. This plant cannot be excluded without excluding trifluralin with
an annual estimated production of 25 million pounds and at the same time ex-
cluding the major pesticides in Group J.
The next discussion examines the chemical group criteria and adds plants
to the select list as needed to fulfill the requirement of sampling enough
plants for an adequate representation of each of the chemical groups.
K-29
-------
Chemical Group Representation
A detailed source assessment of the above eight selected plants will
give suitable and representative data of Groups A, B, C, D, J, and K. These
plants, however, will reveal little about Groups E, F, G, and I. (Group H
is excluded because there are restrictions on the major pesticides in this
group and volume of production is currently low.)
Group E, the anilides, can be adequately assessed by examining only one
plant—Monsanto, Muscatine, Iowa. Monsanto is the sole producer of propachlor,
alachlor, and butachlor. These three pesticides are produced in a total esti-
mated annual quantity of 95 million pounds or about 867. of the total annual
production volume of anilides. Therefore, Monsanto, Muscatine, Iowa, is added
to the select list to give a representative assessment of Group E.
Group F, the organoarsenicals and organoraetallics, can be adequately as-
sessed by examining either Ansul's plant at Marinette, Wisconsin, or Vineland's
plant at Vineland, New Jersey. Both plants produce MSMA, DSMA, and cacodylic
acid. These three pesticides are produced in an estimated total annual volume
of 48 million pounds or about 87% of the total pesticide production in this
group.
The choice between these two plants is close and either of them would
be suitable candidates. Ansul is selected since it produces one other major
pesticide, maleic hydrazide, and this pesticide is in Group G. Thus, Ansul,
Marinette, Wisconsin, is added to the select list to represent Group F.
Group G, other nitrogenous compounds, contains only one pesticide which
is produced in excess of 10 million pounds annually--captan, 20 million
pounds. This pesticide and folpet, another member of this group, are produced
by only two plants and only one of these plants is in the lilt of 25 selected
plants. That plant is Stauffer, Perry, Ohio. Therefore, Stauffer, Perry, Ohio,
is added to the select list to help give a representative assessment of Group
G.
Group I, ureas and uracils, can be adequately assessed by examining
Du Font's plant at LaPorte, Texas. This plant is the sole producer of bromacil,
diuron, and terbacil, and is one of two producers of linuron. These four pes-
ticides are produced in an estimated total quantity of 28 million pounds or
about 70% of the total annual production of ureas and uracils. Therefore,
Du Pont, LaPorte, Texas, is added to the select list to give a representative
assessment of Group I.
The third criterion, assessing most of the extremely and highly toxic
pesticides, is discussed next.
K-30
------- |