UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

OFFICE OF CHEMICAL SAFETY AND 

POLLUTION PREVENTION 

MEMORANDUM 

Date: May 6, 2015 

SUBJECT: Aquashade, Acid Yellow 23, and Acid Blue 9, Diammonium Salt: 

Tier I (Scoping) Review of Human Incidents 

PC Code: II 030 I, I I 0302, I I 0303 

Decision No.: 500211 

Petition No.: NA 

DP Barcode: 0427136 

Registration No.: NA 

Regulatory Action: NA 

Risk Assessment Type: NA Case No.: NA 

TXRNo.: NA 

MRID No.: NA 

CAS No.: 2650-18-2, 1934-21-0, 92170-50-8 

40CFR: NA 

FROM: 

THROUGH: 

TO: 

Sharma Recore, Industrial Hygienist 

Toxicology and Epidemiology Branch 

Health Effect Division (7509P) 

and 

Elizabeth Evans, Environmental Protection Specialist 

Toxicology and Epidemiology Branch 

Health Effects Division (7509P) t).· 

David Miller, Acting Branch Chief!/ J ;#!Itt 

Toxicology and Epidemiology Bra c 

Health Effects Division (7509P) 

Uma Habiba, Risk Assessor 

Risk Assessment Branch VII 

Health Effects Division (7509P) 

and 

Carissa Cyran, Chemical Review Manager 

Risk Management & Implementation Branch 1 

Pesticide Re-evaluation Division (7508P) 

Summary and Conclusions 

Ver.Apr. 08 

Based on the low severity of incidents involving aquashade (pc code 11 0303), acid yellow 23 (pc 

code 11 0302), and acid blue 9, diammonium salt (pc code 110301) reported to IDS and the fact 

that no incidents involving aquashade, acid yellow 23, and acid blue 9, diammonium salt were 

reported to SENSOR-Pesticides, there does not appear to be a concern at this time that would 

Page 1 of 4 
warrant further investigation. The Agency will continue to monitor the incident information and 

if a concern is triggered, additional analysis will be included in the risk assessment. 

Detailed Review 

I. ACTION REQUESTED 

This review is intended to fulfill our requirement to docket summaries of incident data that were 

reported to the Agency, as well as to ensure human incident data and the Agricultural Health 

Study (AHS) are part of the problem formulation phase of registration review. Reports of 

adverse health effects allegedly due to a specific pesticide exposure (i.e. , an "incident") are 

largely self-reported and therefore, generally speaking, neither exposure to a pesticide or 

reported symptom (or the connection between the two) is validated or otherwise confirmed. 

Typically, causation cannot be determined based on incident data. However, incident 

information can be an important source of feedback to the Agency: incidents of severe outcome, 

or a suggested pattern or trend among less severe incidents, can signal the Agency to further 

investigate a particular chemical or product. Observational epidemiology studies relate the risk 

of disease, e.g. , cancer, and exposure to an agent such as a pesticide product in the general 

population or specific sub-groups like pesticide applicators. 

II. BACKGROUND 

The dyes erioglaucine (Acid Blue 9 or FD&C Blue No. 1) and tartrazine (Acid Yellow 23 or 

FD&C Yellow No. 5), when combined, act as an aquatic algaecide/herbicide. This aquatic 

herbicide is commonly referred to by the trade name Aquashade. The mixture of erioglaucine 

and tartrazine control the wavelength range of the sunlight spectrum required for photosynthesis, 

thereby inhibiting growth of filamentous algae and submerged aquatic vegetation. It can be used 

in natural or manmade ponds, lakes, fountains, fish farms, and fish hatcheries, and may be 

applied by both professional applicators and homeowners. 

1 

For this evaluation, both the OPP Incident Data System (IDS) and the Centers for Disease 

Control and Prevention/National Institute for Occupational Safety and Health (CDC/NIOSH) 

Sentinel Event Notification System for Occupational Risk-Pesticides (SENSOR) databases were 

consulted for pesticide incident data on the active ingredients aquashade, acid yellow 23, and 

acid blue 9, diammonium salt (pc codes: 110301 , 110302, and 110303). The purpose ofthe 

database search is to identify potential patterns in the frequency and severity of the health effects 

attributed to aquashade exposure. Aquashade is not included in the AHS, and therefore this 

study does not provide information for this report. 

III. RESULTS/DISCUSSION 

a. IDS (Incident Data System) 

1 Reregistration Eligibility Decision For Erioglaucine and Tartrazine (Aquashade *) 

http://www. epa. gov /pes tic ides/reregi strati on/REDs/aq uashade _red. pdf 

Page 2 of4 
OPP's IDS includes reports of alleged human health incidents from various sources, including 

mandatory Federal Insecticide, Fungicide and Rodenticide Act (FIFRA) Section 6(a)(2) reports 

from registrants, other federal and state health and environmental agencies, and individual 

consumers. Since 1992, OPP has compiled these reports in IDS. IDS contains reports from 

across the U.S. and most incidents have all relevant product information recorded. Reports 

submitted to the IDS represent anecdotal reports or allegations only, unless otherwise stated in 

the report. 

IDS records incidents in one of two modules: Main IDS and Aggregate IDS: 

o Main IDS contains incidents resulting in higher severity outcomes and provides 

more detail with regard to case specifics. This system stores incident data for 

death, major and moderate incidents, and it includes information about the 

location, date and nature of the incident. Main IDS incidents involving only one 

active ingredient (as opposed to pesticide products with multiple active 

ingredients) are considered to provide more certain information about the 

potential effects of exposure from the pesticide. 

o Aggregate IDS contains incidents resulting in less severe human incidents (minor, 

unknown, or no effects outcomes). These are reported by registrants only as 

counts in what are aggregate summaries. 

For the Main IDS, from January 1, 2010 to February 12, 2015, there were 0 incidents reported 

involving aquashade or acid blue 9, diammonium salt in the database. There were 4 incidents 

reported involving yellow acid 23. These incidents involved the product Lysol All Purpose 

Cleaner (Reg No. 777-89) and not aquashade2. The symptoms reported were dermal, respiratory 

and ocular. These incidents were classified as moderate severity. 

In Aggregate IDS, from January 1, 2010 to February 12,2015, there were 53 incidents reported 

involving aquashade. These incidents were classified as minor severity. There were 156 

incidents involving acid yellow 23. These incidents all involved Lemon Breeze Scent Lysol 

Brand Disinfectant All Purpose Cleaner (Reg No. 777-89). These incidents were classified as 

minor severity. There were no incidents reported involving acid blue 9, diammonium salt. 

b. SENSOR-Pesticides 

The SENSOR-Pesticides database covers 12 states from 1998-2011 , although reporting varies 

from state to state. Cases of pesticide-related illnesses are ascertained from a variety of sources, 

including: reports from local Poison Control Centers, state Department of Labor workers' 

compensation claims when reported by physicians, reports from State Departments of 

Agriculture, and physician reports to state Departments of Health. Although both occupational 

and non-occupational incidents are included in the database, SENSOR-Pesticides focuses on 

occupational pesticide incidents, and is of particular value in providing that information. The 

state coordinator at each of the 12 respective state Departments of Health conducts case follow2 When Acid Blue 9 and Acid Yellow 23 are combined they act as an aquatic algaecide/herbicide. This aquatic 

herbicide is commonly referred to by the trade name Aquashade. These dyes are also present in other pesticide 

products which were included in this analysis. 

Page 3 of4 
up activities such as obtaining medical records to verify symptoms and severity. Using 

standardized protocol and case definitions derived from poison center reporting, the state 

SENSOR-Pesticide coordinator enters the incident information into the state-based system which 

is sent to NIOSH annually to be aggregated. 

A review of SENSOR-Pesticides 1998-2011 identifies no cases involving aquashade. 

c. Agricultural Health Study (AHS) 

The AHS is a high quality, prospective epidemiology study evaluating the link between pesticide 

use and various health outcomes including cancer. The AHS includes private and commercial 

pesticide applicators and their spouses. If there are AHS findings relevant to a particular 

pesticide going through registration review, the Agency will ensure they are considered in the 

problem formulation/scoping phase of the process and, if appropriate, fully reviewed in the risk 

assessment phase of the process. The AHS includes information on use of 80 different pesticide 

active ingredients commonly used in agriculture. Aquashade is not included in the AHS, and 

therefore this study does not provide information for this report. 

IV. CONCLUSION 

Based on the low severity of incidents involving aquashade (pc code 110303 ), acid yellow 23 (pc 

code 110302), and acid blue 9, diammonium salt (pc code 110301) reported to IDS and the fact 

that no incidents involving aquashade, acid yellow 23, or acid blue 9, diammonium salt were 

reported to SENSOR-Pesticides, there does not appear to be a concern at this time that would 

warrant further investigation. The Agency will continue to monitor the incident information and 

if a concern is triggered, additional analysis will be included in the risk assessment. 

Page 4 of4