To: U.S. EPA’s Office of Pollution Prevention and Toxics (oppt.ncic@epa.gov)
Comments From: Ellen Connett
Subject: Docket control number OPPTS-50639C

July 9, 2002

Re: Perfluoroalkyl Sulfonates; Proposed Significant New Use Rule
Docket control number OPPTS-50639C

It is disturbing enough that the many chemicals that come under the umbrella of Perfluorooalkyl Sulfonates are persistent, bioaccumulative, and toxic and that humans and wildlife have been the victims as we bear the burden of carrying them within our bodies.

I urge EPA to reconsider its unscientific, unethical, and irresponsible policy of continuing to keep secret the chemicals that are used as “Inerts” in the formulation of pesticide products. As EPA well knows the “Inerts” generally constitute the largest percentage of a pesticidal formulation. This is a policy that disenfranchises the American public and is antithetical to a democratic country. Over the years many of the Perfluoralkyl Sulfonates were included in EPA’s List of Inerts. Will EPA now inform the American public the names of the pesticides they were used in and on which food crops?

The following are questions that I hope EPA will address:

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At least two of the chemicals on the PFOS List are on EPA’s List 3 Inerts. Does EPA still include them on List 3 Inerts? They are:

CAS No. 1652-63-7
PFOS List Name: 1-Propanaminium, 3- [[(heptadecafluorooctyl)sulfonyl]am ino]-N,N,N-trimethyl-, iodide
EPA List 3 Inert name: 3-(((Heptadecafluorooctyl) sulfonyl)amino)-N,N,N- trimethyl-1- propanaminium iodid

CAS No. 1652-63-7
PFOS List Name: 1-Propanaminium, 3- [[(heptadecafluorooctyl)sulfonyl]am ino]-N,N,N-trimethyl-, iodide
EPA List 3 Inert name: 3-(((Heptadecafluorooctyl) sulfonyl)amino)-N,N,N- trimethyl-1- propanaminium iodid

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The insecticide Sulfluramid is registered with the EPA as an Insecticide. Details are:

CAS No. 4151-50-2

PFOS List Name: 1-Octanesulfonamide, N-ethyl- 1,1,2,2,3,3,4,4,5,5,6,6,7,7,8,8,8- heptadecafluoro-

EPA PC Code: 128992

Common Name: Sulfluramid

According to a July 9, 2002, search of the “USEPA/OPP Chemical Ingredients Database Query ” at http://www.cdpr.ca.gov/docs/epa/epachem.htm ,16 products are listed as “Active”; 4 products “Transferred”; and 3 products “Cancelled.” Is this correct? The products are:

9688-134 (Active) CHEMSICO INSECT BAIT A

9688-131 (Active) CHEMSICO ROACH CONTROL SYSTEM CS

1812-451 (Active) FINITRON BRAND SULFLURAMID AB MUP

1812-450 (Active) FINITRON BRAND SULFLURAMID LCA MUP

1812-452 (Active) FINITRON BRAND SULFLURAMID TERMITE MUP

1812-448 (Active) FINITRON BRAND SULFURAMID RB MUP

279-3196 (Active) FIRSTLINE GT PLUS TERMITE BAIT STATION

279-3171 (Active) FIRSTLINE TERMITE BAIT CONTAINER STATION

279-3153 (Active) FIRSTLINE TERMITE BAIT STATION

279-3170 (Active) FIRSTLINE TERMITE BAIT TUBE STATION

279-3154 (Active) FLUORGUARD ANT CONTROL BAITS

1812-327 (Cancelled) GX-071 TECHNICAL

1812-354 (Active) INDOOR ROACH BAIT

499-459 (Active) MICRO-GEN ANT REACTOR

11540-20 (Transferred) MICRO-GEN ANT REACTOR

499-460 (Cancelled) PRO-CONTROL ROACH BAIT

11540-21 (Transferred) PRO-CONTROL ROACH BAIT

4822-508 (Active) RAID DOUBLE CONTROL ANT BAITS

1812-330 (Transferred) RAID MAX ANT BAIT

4822-356 (Active) RAID MAX ANT BAIT

1812-329 (Transferred) RAID MAX ROACH BAIT

4822-355 (Cancelled) RAID MAX ROACH BAIT

1812-348 (Active) VOLCANO ANT BAIT

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It is not clear if the following EPA List 3 Inert is included on the PFOS List:

No CAS No.

EPA List 3 Inert name: 2-[Methyl (polyfluoroalkylsulfonyl ) amino]ethyl methacrylate, polym. w. heptyl methacrylate, butyl methacrylate and N- methylolacrylamide

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Ellen Connett
Editor, Waste Not
82 Judson Street
Canton NY 13617