Meeting to Discuss Measures To 

Reduce The Potential For Accidental 

Ingestion Risks of Paraquat End-Use 

Products

August 6, 2014

Monty Dixon, Jerry Wells

Paraquat Dichloride

DRAFT FOR DISCUSSION WITH EPA ON AUGUST 6, 2014
Background

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● Paraquat dichloride has been utilized as a broad spectrum herbicide in the

United States since first registered in 1964.

● Paraquat provides unique benefits:

- Valuable weed resistance management tool for growers.

- Rapid mode of action allows for use as a harvest aid.

- Very strong binding to soil with biological inactivation thus making it an important part of 

conservation tillage systems, especially no-till systems.

● Paraquat has successfully completed multiple EPA reviews ensuring that

continued registration would not pose unreasonable adverse effects on humans

and the environment.

● Transfer of paraquat products into containers (deliberate misuse) that may be

confused for beverage containers has resulted in unintentional consumption of

the transferred material with some fatal incidents.

● Formulation changes including the addition of a dye and olfactory alerting

agents have been made to reduce the likelihood of accidental ingestion

exposures.

● An emetic is included to lessen the impact if an accidental ingestion were to

occur.

DRAFT FOR DISCUSSION WITH EPA ON AUGUST 6, 2014
Paraquat Registration Review

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● Registration Review Docket opened 21 Dec 2011

● EPA has received comments from concerned health care providers

regarding the number of fatalities associated with ingestion of paraquat

dichloride containing products.

- California physician 30 July 2013

- American Association of Poison Control Centers (AAPCC) 7 Oct 2013

● Syngenta provided information requested by EPA

● EPA provided a list of potential mitigation options to be considered in

advance of the meeting with Technical Registrants

DRAFT FOR DISCUSSION WITH EPA ON AUGUST 6, 2014
Current Label Warnings and Restrictions

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● Paraquat dichloride is a Restricted Use Pesticide

- Can only be purchased by certified applicator

- May only be used by Certified Applicator or person under direct supervision

- May only be used for uses covered by Certified Applicators Certification

● Restrictions explicitly stated in bold print on Front Panel of Label

- NEVER PUT INTO FOOD, DRINK OR OTHER CONTAINERS

- DO NOT USE OR STORE IN OR AROUND THE HOME

- DO NOT REMOVE THE CONTENTS EXCEPT FOR IMMEDIATE USE

- KEEP OUT OF REACH OF CHILDREN

● Front Panel also prominently displays:

- DANGER/PELIGRO

- POISON

- Skull and Crossbones

DRAFT FOR DISCUSSION WITH EPA ON AUGUST 6, 2014
● Safety statements/requirements should be presented in both English and 

Spanish

- Possibility of inclusion in EPA’s Spanish label pilot initiative

● Revise Front Panel Restriction Section to include blue text:

• NEVER PUT INTO FOOD, DRINK OR OTHER CONTAINERS

• IF SWALLOWED, TAKE IMMEDIATE ACTION AS PRESCRIBED IN FIRST AID SECTION 

SYMPTOMS ARE PROLONGED AND PAINFUL AND MAY LEAD TO DEATH

• DO NOT USE OR STORE IN OR AROUND THE HOME

• DO NOT REMOVE THE CONTENTS EXCEPT FOR IMMEDIATE USE

• FAILURE TO COMPLY WITH THESE REQUIREMENTS IS A VIOLATION OF FEDERAL 

LAW AND MAY RESULT IN PERMANENT SERIOUS INJURY INCLUDING DEATH

● Include a “Hang tag” that provides restrictions to prevent illegal transfer.

● Include a Warning Sticker on product caps (English & Spanish)

- STOP! Do not pour this product into a food, drink or other container. Ingestion could

lead to death.

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Proposed Additional Warnings and Notifications

DRAFT FOR DISCUSSION WITH EPA ON AUGUST 6, 2014
● Paraquat dichloride can only be purchased by Certified Applicator

- Propose industry develop a paraquat training module to be made available for use in

State Certified Applicator training.

• Emphasis on the importance of safe handling and storage of paraquat products. Highlight 

that product is not to be transferred to any other containers and such transfer is considered 

an illegal act.

• Demonstration of case histories of accidental exposures and fatal outcomes

• Documentation that the user understands the requirements for safe handling and storage of 

paraquat products and the dangers of failing to do so.

● Counter cards that provide information on the safe storage and handling of paraquat

products intended to reduce the potential for the illegal transfer that could lead to an

accidental ingestion to be included in box and available at distributor/dealer.

● A requirement that each purchaser sign a document at the time of purchase certifying they

understand their responsibility for adherence to the safety restrictions that are in place to

prevent unintentional exposure.

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Proposed Additional Stewardship and Education Actions for Discussion

DRAFT FOR DISCUSSION WITH EPA ON AUGUST 6, 2014
● Recovery of Old/Leftover Pesticide

- Industry to encourage users to utilize local pesticide pickup programs (e.g. Clean

Sweep Program) to collect and dispose of unused/unwanted paraquat products

• If no local program is available, work with distributors to recover unwanted

paraquat products for proper disposal

• The return of Old/Leftover pesticide would be a voluntary process

● Syngenta will continue to have child-resistant caps on all non-bulk packaged paraquat

products

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Registrant Initiated Stewardship Actions and Education

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● Increase Brightness Of Color And Add A Dying Agent

- The market place contains beverages in such a wide range of colors that it may not be

possible to create a change in the color of the paraquat products that would uniquely

identify an incorrectly labelled container as containing something other than a

beverage.

Discussion of Additional Measures Proposed By EPA For Consideration

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● Formulation Change From Liquid To Dry Flowable Or Water Dispersible Granular

- A solid formulation would have the potential to reduce the chance of an accidental

oral ingestion from mistaken identity with beverages but not necessarily with

foodstuffs

- A solid formulation would have the potential to increase manufacturing and 

mixer/loader occupational inhalation risks due to the possibility of airborne particles.

- Water Soluble Packaging (WSP) could reduce potential exposure to airborne particles.

• WSP are only practical for small scale operations such as back-pack sprayers and 

are not feasible for paraquat applications in US agricultural production.

• Rips or cuts to WSPs would create potential for airborne particulate exposure.

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Discussion of Additional Measures Proposed By EPA For Consideration

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● Change In Odorant-stronger, More Persistent

- All paraquat products should continue to include a component that creates an odor to

alert an unsuspecting person that the product should not be consumed.

- Historically, the previous strong odorant in paraquat formulations was reported to

cause headaches and nausea in occupational workers handling large volumes of the

product.

- Fatal accidental ingestion exposures have occurred despite the presence of strong,

unpleasant odorants in paraquat formulations.

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Discussion of Additional Measures Proposed By EPA For Consideration

DRAFT FOR DISCUSSION WITH EPA ON AUGUST 6, 2014
● Lowering % Active Ingredient In End-use Products To 5%

- A reduction of the paraquat concentration in end-use products would require greater

volumes of the reduced concentration product to treat the same area.

• Reduction from 30.1% to 5% product increases paraquat product volume

requirements 6X

• This would not be practically feasible:

- 6X Transport Requirements (more trucks, railcars, containers)

- Onsite storage (6X number of bulk tanks, or non-bulk material)

• Significantly more containers from which product may be illegally 

decanted

- Mixing loading and clean-up activities would be increased

• Example: Alfalfa application rate (1 lb ai/A) currently requires 0.5

gal/A of a 30.1% product but would require 3 gal/A of a 5% product.

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Discussion of Additional Measures Proposed By EPA For Consideration

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Transporation of Increased Volumes of Diluted Product

30.1%

Product

5%

Product

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Impact of Dilution on Distributors Storage Volumes

30.1%

Product

5%

Product

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On Farm Storage and Disposal Impact Of Diluted Products

30.1%

Product

5%

Product

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● 30.1% product contains 2 lb ai/gal thus 100 gal product to treat 200 A.

● 5% product contains 0.3 lb ai/gal thus 600 gal product to treat 200 A.

Example: To Treat 200 A of Alfalfa @ 1 lb ai/A

250 gallon

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● A significantly diluted product may still have the potential to result in a fatal outcome or

severe long-term health effects from an accidental ingestion.

● Reinforces the importance of preventing the circumstances (transfer to beverage or other

container) that can result in accidental ingestion.

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Additional Measures Proposed By EPA For Consideration

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Conclusion

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● Transfer of paraquat products into containers (deliberate misuse) that

may be confused for beverage containers presents the highest potential

for unintentional consumption of the transferred material with potential

for fatalities.

● Formulations include a dye, emetic and alerting agents to address

accidental ingestion exposures.

● Incorporation of the proposed additional stewardship measures are

made to further decrease the potential for accidental ingestion

exposures by reducing the potential that paraquat products would be

transferred into a container that may be mistaken for a beverage.

DRAFT FOR DISCUSSION WITH EPA ON AUGUST 6, 2014
Discussion

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