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Can a chemical be an inert ingredient in one pesticide product and an active ingredient in another?

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Can a chemical be an inert ingredient in one pesticide product and an active ingredient in another?

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It is possible for a chemical to be an inert ingredient in one pesticide product and an active ingredient in another pesticide product. Minimum risk pesticide manufacturers must be extremely careful to never use an inert ingredient from List 4A as an active ingredient unless the ingredient is also on the 25(b) active ingredient list. Examples: Citric acid and several essential oils are examples of minimum risk pesticide ingredients that can be found on both the 25(b) active ingredient list and List 4A. Vinegar is a good example of a minimum risk inert ingredient that can pose a hazard if improperly and illegally used as an active ingredient in an unregulated 25(b) pesticide product. EPA added vinegar (maximum of 8% acetic acid in solution) to List 4A to give manufacturers a safe means of controlling pH in minimum risk pesticide products. When used as an inert ingredient to buffer pH, the quantity of vinegar in a pesticide product is not expected to pose hazards. However, vinegar with a

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