March 24, 2021
Administrator Michael Regan
U.S. Environmental Protection Agency, Washington, DC 20460
We are writing to inform you that tests ordered by Public Employees for Environmental Responsibility (PEER) have found per-and polyfluoralkyl substances (PFAS) in the pesticide Permanone 30-30 used by Maryland and other states in their mosquito control programs. PEER and the Maryland Pesticide Education Network conducted these tests because of concern about the use of PFAS in pesticides and herbicides, either as surfactants, propellants, dispersants and/or anti-foaming agents, and because of concerns about PFAS contamination from manufacturing processes and leaching from storage containers.
Permanone 30-30 is used across the country to kill mosquitos and other insects. It is extremely toxic to fish and aquatic invertebrates.
Our tests revealed that Permanone 30-30 contains 3500 parts per trillion (ppt) of Perfluorooctanoic acid (PFOA) and approximately 630 parts per trillion of hexafluoropropylene oxide dimer acid (HFPO-DA), a GenX replacement for PFOA. Because of its health dangers, many manufacturers have voluntarily phased out the production of PFOA, and EPA currently has a lifetime health advisory of 70 ppt for PFOA. The Member State Committee (MSC) of the European Chemicals Agency has identified HFPO-DA, its salts and acyl halides as substances of very high concern due to their probable serious effects on human health and the environment.
EPA recently stated on its website that it “considers any level of PFAS to be potentially toxicologically significant.”
Based on these results, we ask EPA to immediately conduct its own testing of Permanone 30-30, the containers used to store Permanone, and the company’s manufacturing process. We are also asking EPA to immediately develop a regime that would require manufacturers to test different pesticides and herbicides on the market for PFAS and make those findings public. In addition, the synergistic effects of combined pesticides and PFAS must be studied and addressed. Finally, we are asking EPA to release to the public any currently held information about registered pesticides with any PFAS as an active or inert ingredient and any information you have about any containers that may be made with PFAS.
Source: PEER: 202-265-7337 ext 109, twhitehouse@peer.org,
www.peer.org | MPEN: 410-849-3909 ext. 1,
berlin@mdpestnet.org, www.mdpestnet.org,
3_24_21-EPA-Regan-PEER-Ltr-Permanone.pdf