Michelle Bogner – Laboratory Directors’ LiaisonPESTICIDE PRODUCT INTEGRITY ACTIVITIES

FORMULATION TESTINGIn Section 13, FIFRA Program for Compliance Assurance and Enforcement, Part A, Pesticide Product Integrity, under the description, the guidance states:“For this focus area, regions would be expected to monitor compliance against four prongs of product integrity: (1) product registration, (2) label/labeling compliance, (3) composition compliance and (4) product efficacy, (apply in cases dealing with the on-going antimicrobial testing program (ATP)).”In Region 5, laboratories were asked for their ability to test formulation samples for not only active ingredients, but also for inert ingredients and any possible contaminants as part of the third prong for product integrity. None of the labs currently have this capability.

FORMULATION TESTINGInert ingredients are defined by EPA as any substance (or group of structurally similar substances if designated by the Agency), other than an “active” ingredient, which is intentionally included in a pesticide product. www2.epa.gov/sites/production/files/2014-05/documents/faqs.pdfPesticide products may contain more than one inert ingredient; however, federal law does not require that these ingredients be identified by name or percentage on the label.

INERTSACETONEBACILUS THURINGIENSISCOCONUT SHELLSDIATOMACEOUS EARTHETHANOLGRAPHITEHYDROCHLORIC ACIDISOBUTANELACTIC ACIDMETHYL ESTERS OF FATTY ACIDSOLEIC ACIDPROPANEROSINSOYBEAN FLOURTALCVERMICULITEWINTERGREEN OILXANTHANZINC OXIDE

CONTAMINANTSOld school – Thin Layer ChromatographyNew school – High-resolution Mass Spectometry