July 21, 2005

Submission to:
National Research Council Committee:
Toxicologic Risk of Fluoride in Drinking Water; BEST-K-02-05-A
c/o Susan Martel <smartel@nas.edu>

From:
Ellen Connett
Fluoride Action Network Pesticides Project
82 Judson Street, Canton NY 13617
Email: pesticides@fluoridealert.org
Tel: 315-379-9200

Addendum to Part 2. "Inerts" used in Pesticides. New Source of Fluoride Exposure.

Excerpts from the National Organic Program Standards
Online at http://www.ams.usda.gov/nop/NOP/standards/FullText.pdf

List 4 Inerts:

page 246. Subpart G Administrative The National List of Allowed and Prohibited Substances Description of Regulations General Requirements ...
-- page 248. The NOSB has also provided recommendations for the use of synthetic inert ingredients in formulated pesticide products used as production inputs in organic crop or livestock operations. The Environmental Protection Agency (EPA) regulates and maintains the EPA Lists of Inert ingredients used for pesticide. In this final rule, EPA Inerts List 1 and 2 are prohibited, EPA List 3 is also prohibited unless specifically recommended as allowed by the NOSB, and EPA List 4 Inerts are allowed unless specifically prohibited.
-- In this final rule, only EPA List 4 Inerts are allowed as ingredients in formulated pesticide products used in organic crop and livestock production. The allowance for EPA List 4 Inerts only applies to pesticide formulations.

page 251. National List - Changes Based On Comments
page 253. ... Livestock Production: ... EPA List 4 inert ingredients as synthetic inert ingredients for use with nonsynthetic substances or synthetic substances allowed in organic livestock production.

page 255. National List - Changes Requested But Not Made
page 256. (2) Use of EPA List 4 Inerts. The proposed rule allowed EPA List 4 Inerts to be used as synthetic inert ingredients with allowed synthetic active ingredients in crop production. Some commenters stated that certain substances among the EPA List 4 inerts should not be allowed in organic production. Some commenters went further and recommended that the allowance for synthetic inert ingredients should be limited to the subset of materials that the EPA designates as List 4A. We do not agree with these commenters and have retained the allowance for all inerts included on EPA List 4. List 4 inerts are classified by EPA as those of “minimal concern”and, after continuing consultation with EPA, we believe there is no justification for a further restriction to List 4A. If commenters believe that a particular List 4 inert should not be allowed in formulated products used in organic production, they can petition the NOSB to have that substance prohibited.

page 351. § 205.2 Terms defined.
page 357-358. Inert ingredient. Any substance (or group of substances with similar chemical structures if designated by the Environmental Protection Agency) other than an active ingredient which is intentionally included in any pesticide product (40 CFR 152.3(m)).

pag 427 § 205.601 Synthetic substances allowed for use in organic crop production.
page 430. (7) Liquid fish products ...
(m) As synthetic inert ingredients as classified by the Environmental Protection Agency (EPA), for use with nonsynthetic substances or synthetic substances listed in this section and used as an active pesticide ingredient in accordance with any limitations on the use of such substances.

page 431. § 205.603 Synthetic substances allowed for use in organic livestock production.
page 433. Milk replacers - without antibiotics, as emergency use only, no nonmilk products or products from BST treated animals ...
e) As synthetic inert ingredients as classified by the Environmental Protection Agency (EPA), for use with nonsynthetic substances or a synthetic substances listed in this section and used as an active pesticide ingredient in accordance with any limitations on the use of such substances.