pesticide formulations. Only five of the original 50 List 1 inerts—di-n-octyl adipate; ethylene glycol monoethyl ether; 1, 2-benzenedicarboxylic acid, bis(2-ethylhexyl) ester; 1, 4-benzenediol; and nonylphenol—are now permitted in nonfood-use pesticide formulations (EPA 2011). In 2011, EPA released a searchable on-line database of inerts that are approved for use in pesticide formulations (EPA 2012h). The database includes three sets of inert ingredients: those approved for food and nonfood use, for nonfood use only, and for fragrance use.
Some inerts used in pesticide formulations are complex mixtures, for example, petroleum-based solvents and tallow-based surfactants. Petroleum hydrocarbon solvents can contain many individual compounds, and the compositions of the solvents vary substantially, depending on the distillation process and on the sources and types of the crude oil used to derive the petroleum distillates (ATSDR 1999). Similarly, surfactants based on tallow (animal fat) are highly complex mixtures whose compositions vary on the basis of the source of the animal fat and the manufacturing processes used to render the animal fat and process the tallow (Kosswig 1994; Brausch and Smith 2007; Katagi 2008).
In some cases, applications of multiple pesticide formulations and tank mixtures might not present difficulties in the exposure analysis beyond those associated with applications of a single compound. If components of a tank mixture or formulation do not substantially affect the fate and transport of other components, the exposure analysis methods used for single chemicals can be applied to tank mixtures. In cases in which additives, such as surfactants, could affect the fate and transport of active ingredients in a formulation, uncertainties in exposure analysis could be substantial unless the effect of additives can be quantified in exposure modeling. Many inerts are designed to affect the behavior of an active ingredient after application. For example, surfactants or penetrating agents are often used in applications of herbicides. Surfactants and penetrating agents might have little or no phytotoxicity at the concentrations used in most herbicide applications, but their ability to enhance absorption can enhance the efficacy of herbicides (Denis and Delrot 1997; Liu 2004; Tu and Randall 2005). Surfactants can also alter the persistence and mobility of active ingredients in soil and water (Katagi 2008); similarly, microencapsulation can retard transport in soil. Prolonging residence time can enhance the efficacy of pesticide active ingredients in soil (Beestman 1996).
The environmental-fate properties of inerts often differ from the corresponding properties of a pesticide’s active ingredients. Consequently, inerts and active ingredients partition differentially in the environment (water, sediment, soil, and air) and do so at differing rates. Individual constituents in complex inerts also have different environmental-fate properties, so components of the inerts also partition at different rates and to different extents. Little information is available on the environment fate and differential partitioning of complex inerts. Although a relatively standard set of tests are required on the environmental fate of most active ingredients, testing requirements are less stringent for inerts.