Nalco, Inc.’s Request that EPA Reconsider Its Registration for Ammonia 

Products as Precursors to Chloramine used in Water Treatment and Provide 

Assurance that there is No Risk of Enforcement During The Reconsideration 

and Any Necessary Transition Period 

December 4, 2007 

Ammonia and ammonium compounds (hereinafter referred to collectively as ammonia) 

have for well over 50 years been used in connection with chlorine in water treatment. EPA, 

including the Office of Pesticide Programs (OPP) has been aware of, and acknowledged this 

practice. This longstanding practice was based upon EPA’s historic position that ammonia does 

not require registration under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA). 

In a recent decision, however, EPA registered ammonia when it is used to generate chloramines 

in situ for pulp and paper mill slimicide uses. See EPA Reg. No: 1448-432 for Buckman 

Laboratories, Inc., (March 6, 2007). The registration was granted without prior notice to the 

regulated community, apparently without consideration within the Agency of the rationale for 

EPA’s historic position and for a change in that position, or of the potential impact of this 

precedent-setting decision on the many users of chlorine for water treatment. 

As explained below, Nalco submits that EPA should reconsider its decision to register 

ammonia used in connection with chlorine in water treatment. Ammonia does not require 

registration for a broad range of reasons: 

• Ammonia does not have antimicrobial activity. In fact, ammonia is a 

nitrogen source and can actually promote microbial growth. If its addition is 

not closely controlled, ammonia and its production of chloramines can 

interfere with the ability of chlorine to disinfect water effectively. 

• The addition of ammonia to chlorine-based water treatment systems is not 

needed for the in situ generation of an antimicrobial active ingredient. The 

addition of ammonia is intended to sequester or otherwise temper the activity 

of the pesticidally active chlorine compounds in the water. The antimicrobial 

activity is provided by chlorine, which is registered and therefore controlled 
by EPA. Therefore, it is inappropriate to view chloramines as a separate new 

active ingredient. 

• EPA historically and currently does not require registration of compounds 

used in conjunction with pesticide active ingredients for the same purpose that 

ammonia is used with chlorine in water treatment systems. There are 

numerous examples of compounds that interact chemically with pesticide 

active ingredients to enhance, sequester or otherwise impact the performance 

of the active ingredient, including, for example, cyanuric acid used to stabilize 

chlorine in swimming pools. These are viewed as unregulated adjuvants. 

Similarly, activators for in situ generation of both chlorine dioxide and 

brominated water treatment compounds are unregulated. 

• The registration also is puzzling from a procedural perspective. AD took 

credit for registering ammonia as a “new use for an existing active 

ingredient.” However, it is possible chloramines should be considered as new 

active ingredients, since EPA purports that ammonia is precursor to 

chloramines. Putting aside the fact that EPA has known about these 

compounds since the Agency was formed, there is no indication that the 

Agency has taken steps to register chloramines as a new active. In the event 

EPA believes it really is seeking to control the new unregistered active 

ingredient, chloramines, registration of ammonia remains inappropriate. As in 

the case of chlorine dioxide, which is generated in situ, only the precursor that 

contributes the active ingredient should be regulated by EPA. For chlorine 

dioxide, that is sodium chlorite or sodium chlorate, as demonstrated by the 

recent Chlorine Dioxide RED. For chloramines, only the chlorine source 

could similarly require registration. Since chlorine already is registered, it is 

inconsistent with longstanding practice to also register the non-active portions 

of an in situ generated active. 

• Further from a procedural perspective, pursuant to FIFRA § 3(c)(4) and 40 

CFR § 152.102, the Agency is required to publish in the Federal Register a 

notice of receipt of each application that proposes a new use. There is no 

record of any such publication. Further, FIFRA § 3(c)(4) and 40 CFR § 

152.102 require that the Agency publish a notice of issuance in the Federal 

Register after registration, summarizing the regulatory conclusions, conditions 

for submission of any missing information, and responding to comments on 

the notice of application. There is no record of any such publication. 

Both the process and substance of the ammonia registration are flawed. For these 

reasons, Nalco respectfully suggest that EPA should re-evaluate its position with regard to 

registration of ammonia used with chlorine in water treatment and withdraw as improperly 

granted the registration it has granted. While that reevaluation continues, to avoid further 

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disrupting those markets that use ammonia in connection with chlorine based water treatment, as 

well as other chemistries and technologies that might be impacted, Nalco requests EPA to 

promptly issue a public statement making clear that both unregistered and registered products 

may be used in compliance with FIFRA. EPA also should provide assurance that, once a final 

decision is made, vendors and users of subject chemistries and technologies will have an 

adequate period of time to come into compliance. 

I. The Chemistry of Chlorine in Antimicrobial Water Treatment 

Chlorine chemistry in water systems is complex and dynamic. Chlorine is highly 

reactive. In water systems, use of chlorine results in multiple competing reactions modified by 

temperature, pH, the chlorine:nitrogen ratio, other compounds present in the water, and many 

other factors. In chlorine-based water disinfection systems, there is both “free chlorine” (which 

refers to the sum of the concentrations of hypochlorous acid and hypochlorite ions) and “residual 

chlorine” (which refers to chlorine by-products, including chloramines, as well as many other 

chlorine-containing compounds).

The objective in water treatment is to maintain an adequate level of the free chlorine 

(hypochlorous acid and hypochlorite ions) for long enough to obtain appropriate biocidal 

efficacy. “Many inorganic and organic molecules that occur in raw water exert a “demand” i.e., 

a capacity to react with and consume the disinfectant. Therefore, higher “demand” waters 

require a greater dose to achieve a specific concentration of the active species of disinfectant. 

This demand must be satisfied to ensure adequate biocidal treatment.” (NRC 1980) 

One of the normal reaction by-products that occur in water treatment with chlorine 

compounds is formation of nitrogen-chlorine compounds, referred to as chloramines. For 

example, several chloramines form in chlorinated swimming pool water as the chlorine reacts 

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with perspiration, oils, and urine from swimmers. See American Chemistry Council, 2006 at 

www.americanchemistry.com/s_chlorine/science_sec.asp?CID=1270&DID=4750&CTYPEID=1

13&css=print; See also In the Matter of N. Jonas & Co., Inc., 1978 WL 14270 at Findings of 

Fact para. 25 (1978). The term “chloramines” refers to a large and diverse group of both organic 

and inorganic compounds containing both nitrogen and chlorine. Formation and dissolution of 

chloramine species are highly variable and dependent upon relative concentrations, pH, 

temperature and other factors. Many of these residual, chloramine forms of chlorine are 

completely inactive as biocides. Some of the residual chloramine forms of chlorine retain some 

of the chlorine efficacy, albeit in a reduced manner. As EPA has recognized, 

“The sanitizing properties or oxidizing effects of chlorinating agents such as chlorine, can 

be either associated with hypochlorous acid or with the hypochlorite anion. . . . The most 

common redox reactions are: (a) oxidation of reduced inorganic matter, such as iron(II), 

manganese(II), nitrite, and sulfide; (b) reactions with ammonia and organic nitrogen 

(formation of chloroamines); (c) reactions with phenols; (d) reactions with an acetyl 

group to form chloroform; (e) addition to double bonds (Snoeyink et al., 1980).” 

(EPA/OPP, 1995.Free residual chlorine is often used as a measure of the effectiveness of 

chlorination, which in turn is also a measurement of the available chlorine in solution 

(Wojtowicz, 1978). There are many chlorine by-products that are formed as a result of 

chlorination of organic compounds. Chloroamines, for example, are formed as a result of 

chlorination of amines in the effluent stream or receiving body of water.” (EPA/OPP, 

1995. RED for Chlorine Gas, page 23) 

As long ago as the early 1900’s, it was recognized that modifying conditions to favor the 

formation of certain of the natural chloramine reaction by-products can reduce the need for free 

chlorine. These chloramines sequester chlorine, rendering it less reactive but retaining some 

level of efficacy. See EPA Guidance Manual for Alternative Disinfectants and Oxidants, EPA 

815-R-99-014, at §6.3.1 (April 1999). This stabilized or sequestered chlorine allows less free 

chlorine to be added to the system while still meeting the disinfectant demand. See Id. at §6. 

Adjusting the dynamics of the system by modifying the nitrogen:chlorine balance typically is 

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accomplished by adding ammonia compounds as a nitrogen source. (However, in all cases, 

biocidal activity is a result of the chlorine, not the ammonia or amine component.) 

With recent increased concern over disinfection by-products in drinking water and the 

requirement for water treatment systems to minimize the levels of by-products of concern (such 

as bromodichloromethane and dibromo and dichloro acetic acids), it has become more common 

to push the systems toward increased stabilized chlorine forms such as chloramines. Those 

stabilized forms of chlorine are less reactive than free chlorine and therefore result in the 

formation of fewer of the disinfection by-products of concern. However, because the stabilized 

forms of chlorine are less reactive, they also are much less effective as biocides (25-100 times 

less effective than free chlorine). (EPA 1999. Guidance Manual for Alternative Disinfectants 

and Oxidants, NRC 1997). 

As numerous EPA sources have noted, chloramines do not enhance the pesticidal 

properties of chlorine compounds. While studies have shown that “[c]hlorine is an extremely 

effective disinfectant for inactivating bacteria,” “chloramine is considered a weak biocide in 

comparison to free available chlorine, requiring exposure times of 25 to 100 times greater than 

chlorine to achieve comparable inactivation.” See Controlling Disinfection By-Products and 

Microbial Contaminants in Drinking Water, EPA/600/R-01/110, 3-8 (December 2001). Also see

EPA, OPP 2001, The incorporation of water treatment effects on pesticide removal and 

transformations in Food Quality Protection Act (FQPA) Drinking Water Assessments, Office of 

Pesticide Programs Science Policy, EPA-HQ-OPP-2007-0790-0001 at 

www.epa.gov/oppfead1/trac/science/water_treatment.pdf. Rather, the purpose of forcing greater 

levels of these by-products is to extend the period of antimicrobial activity in the dynamic 

system and to minimize generation of other by-products by reducing the reactivity of chlorine. 

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In all cases where chloramines are being generated, however, the chlorine component is 

what is biocidal and required for disinfections, and that chlorine component must be available 

(i.e., not deactivated or entirely tied up in stable compounds). In the residual chloramine form, 

chlorine is essentially sequestered, becoming less reactive. Any biocidal activity is associated 

solely with the chlorine, regardless of whether it is in the “free” or the “residual” form.

II. Ammonia Is Not a Pesticide and Does Not Contribute to the Pesticidal Activity of 

Sodium Hypochlorite or Other Chlorine-Based Water Disinfectants 

Under FIFRA, a pesticide product must be registered with the U.S. Environmental 

Protection Agency (EPA) before it can be sold or distributed in the United States. 7 U.S.C. 

§136(a)(5). A pesticide product is “a pesticide in the particular form in which the pesticide is, or 

is intended to be, distributed or sold.” 40 CFR §152.3. A pesticide means “any substance or 

mixture of substances intended for preventing, destroying, repelling, or mitigating any pest.” 

FIFRA §2(u). Pesticide active ingredients are those “ingredient[s] which will prevent, destroy, 

repel, or mitigate any pest.” FIFRA §2(a)(1). 

Ammonia does not meet the definition of a pesticide. In fact, ammonia is a compound 

that promotes the “growth of . . . bacteria” rather than its inactivation. See EPA Guidance 

Manual; Alternative Disinfectants and Oxidants (April 1999). Excess ammonia in any compound 

acts as a “nutrient and causes the growth of nitrifying bacteria, which convert the excess 

ammonia to nitrates and nitrites.” Id. For example, “[n]itrification adversely impacts the 

effectiveness of chloramine by increasing chloramine demand, depleting chloramine residuals 

and thus allowing bacterial regrowth.” See Simultaneous Compliance Guidance Manual for the 

Long Term 2 and Stage 2 DBP Rules, EPA 815-R-07-017 (March 2007). Too great an amount of 

ammonia “may lead to increased vulnerability to contamination” as opposed to greater bacterial 

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inactivation. Id. Whereas pesticides “deprive[] bacteria of source nutrients,”1

 ammonia acts as a 

nutrient for bacteria. 

Thus, ammonia does not contribute to the pesticidal activity of sodium hypochlorite or 

other chlorine-based water disinfectants. It therefore is not a pesticide. 

Ammonia is added to water systems treated with chlorine to sequester free chlorine, 

typically resulting from hypochlorous acid or chlorine gas. See Reregistration Eligibility 

Decision; Chlorine Gas, EPA 738-R-99-001, available at

http://www.epa.gov/oppsrrd1/REDs/4022red.pdf. See also, Controlling Disinfection ByProducts and Microbial Contaminants in Drinking Water, EPA/600/R-01/110, 3-8 (December 

2001). Hypochlorous acid is highly reactive, reacting with any and all organic material. See

Controlling Disinfection By-Products and Microbial Contaminants in Drinking Water, 

EPA/600/R-01/110 (December 2001). This is problematic in some industrial systems, especially 

pulp and paper mills, because of the extremely high organic content of the pulping liquor. If the 

reactivity is not controlled, the systems have extremely high chlorine demands, requiring 

multiple input points in the papermaking process. Such reactivity can be controlled by 

generating chloramines. See 63 Fed. Reg. 15676 (March 31, 1988) (Chloramine “reduce[s] 

disinfectant demand ... to reduce disinfectant levels”). 

The sequestering activity of ammonia has become an essential tool for many municipal 

drinking water treatment facilities to reduce disinfectant by-products. EPA finalized its Stage 2 

Disinfectants By-Product (DBP) in 2001. The Rule requires that drinking water treaters 

eliminate certain DBPs and control the levels of all DBPs. Chloramine compounds “react more 

 1 In the Matter of N. Jonas & Co., Inc., 1978 WL 14270 (July 27, 1978) (Statement by 

Brown, Chief of the Disinfectants Branch, Registration Division, Office of Pesticide Programs, 

EPA). 

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slowly than free chlorine and as a result, they form fewer DBPs.” See Simultaneous Compliance 

Guidance Manual for the Long Term 2 and Stage 2 DBP Rules, EPA 815-R-07-017 (March 

2007). See also, epa.gov, Information about Chloramine in Drinking Water, available at

http://www.epa.gov/safewater/disinfection/chloramine/; Controlling Disinfection By-Products 

and Microbial Contaminants in Drinking Water, EPA/600/R-01/110, 3-8 (December 2001), 

available at http://www.epa.gov/ord/NRMRL/pubs/600r01110/600r01110 completedocument.pdf. 

Also see EPA, OPP 2001, The incorporation of water treatment effects on pesticide removal and 

transformations in Food Quality Protection Act (FQPA) Drinking Water Assessments, Office of 

Pesticide Programs Science Policy, EPA-HQ-OPP-2007-0790-0001 at 

www.epa.gov/oppfead1/trac/science/water_treatment.pdf. 

As numerous EPA sources have noted, the use of chloramines does not enhance the 

pesticidal properties of chlorine compounds. While chlorine is “an extremely effective 

disinfectant for inactivating bacteria”2, chloramine is “a weak biocide in comparison to free 

available chlorine, requiring exposure times of 25 to 100 times greater than chlorine to achieve 

comparable inactivation.”3 The pesticidal activity of chloramine is a result of the residual 

activity of the chlorine. Thus, ammonia does not increase the efficacy of chlorine. Rather, 

ammonia reduces reactivity by prolonging the period of time that chlorine, either as free chlorine 

 2

 EPA Guidance Manual; Alternative Disinfectants and Oxidants (April 1999), available 

at http://www.epa.gov/safewater/mdbp/word/alter/chapt_2.doc

3

 Controlling Disinfection By-Products and Microbial Contaminants in Drinking Water, 

EPA/600/R-01/110, 3-8 (December 2001) (Many bacteria “exhibit[] greater resistance to 

inactivation by []chloramine compared to free chlorine.”); South Coast Chemical, Inc., 2 E.A.D. 

139 (March 11, 1986) (The formation of chloramines in a swimming pool is a sign of “excessive 

proliferation of bacteria and their metabolic by-products”). 

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or as residual chlorine (chloramines), is available for treatment. Ammonia therefore does not 

meet the definition of a pesticide as defined under FIFRA Section 2. 

III. Ammonia Is Not a Precursor for In Situ Generation of a Pesticide 

Based upon the label language it approved, in granting the ammonia registration EPA 

apparently has adopted the position that ammonia is used to generate a variety of chloramine 

compounds that it contends are the pesticidally active ingredients used to disinfect water. 

Putting aside the Agency’s failure to follow its own procedure for registration of a new precursor 

or a new use of an existing active ingredient, the position the Agency apparently took is factually 

incorrect. Ammonia is not used to generate the pesticide active ingredient for water treatment. 

Sodium hypochlorite (or other chlorine compounds such as chlorine gas) is pesticidally active 

itself. When added to water, sodium hypochlorite forms hypochlorous acid, an extremely 

reactive compound that is responsible for the efficacy of chlorine compounds as antimicrobial 

agents. There is no need for addition of any other compound to produce or generate a 

pesticidally active compound. As explained above, adding ammonia to form chloramine tempers 

the reactivity of chlorine, reducing its effectiveness but allowing longer residence time. Any 

antimicrobial activity of chloramine is the result of the chlorine, which is registered. Therefore, 

the registration of ammonia as a “precursor” to chloramine is inappropriate. 

EPA registers pesticide precursors only in circumstances where registering the precursor 

is the only means by which the Agency could regulate the production and use of pesticides 

generated at the point of application. Therefore, EPA registers precursors when they are the 

“only logical chemical[s] through which the use of a pesticide can be regulated.” In the Matter 

of South Coast Chemical, Inc., 2 E.A.D. 139 (March 11, 1986). For example, chlorine dioxide is 

a registered pesticide used as a drinking water disinfectant and for other pesticidal uses. See

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Reregistration Eligibility for Chlorine Dioxide, EPA 738-R-06-007 (August 2006). Chlorine 

dioxide is a gas and is not sold commercially in that form. It is registered as a stabilized aqueous 

formulation for some uses. More typically, it is generated in situ from stable precursor 

compounds. Its precursors, sodium chlorate and sodium chlorite are registered by EPA, because 

this is the only possible means to regulate the generation and antimicrobial uses of chlorine 

dioxide from those precursors, which themselves are not active. Id. at 16 (“For chlorine dioxide 

generation, both sodium chlorate and sodium chlorite are used as precursor materials in the water 

disinfection process. Sodium chlorite is more commonly used than sodium chlorate.”).

Importantly, only these precursors require registration. The “activator” used with sodium 

chlorite, is recognized on the registered label but does not require registration. Activators can 

include, “acetic, citric, phosphoric, sulfuric, hydrochloric or other equivalent acids”, DuPont 

Anthium Dioxcide, EPA Reg. No. 9150-2 (05/30/2007), “chlorine gas” or “a combination of a 

hypochlorite solution and an acid,” Drew Generox 750, Chlorine Dioxide Precursor for 

Microbial Control in Water and Wastewater and on Hard Surfaces, EPA Reg. No. 1757-315 

(07/19/2007); See, e.g., selected labels for sodium chlorite and chlorine dioxide products at 

Attachment 1; Significantly, the labels do not call for use of a registered activator, and all of 

these compounds are unregistered. 

A similar situation exists with respect to certain bromine compounds used in water 

treatment. For example sodium bromide is a registered precursor which calls for the use of an 

activator. See Reregistration Eligibility Decision for Inorganic Halides, Case 4051 (Sep. 1993) 

(“The sodium bromide solution usually is mixed with activators such as chlorine gas, calcium 

hypochlorite [ ], sodium hypochlorite [ ], potassium monopersulfate [ ], and ozone.”). “Sodium 

bromide per se is a stable salt with no pesticidal activity.” Id. at 10. When mixed with an 

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activator, “the active disinfectant, [ ] hypobromous acid,” is produced. Id. “[H]ypobromous acid 

is an effective microbiological control treatment,” “oxidiz[ing] organic and inorganic material 

present in effluent water.” Id. As with chlorine dioxide chemistry, there is no requirement that 

the activator be registered, and it would be inappropriate to do so. See, e.g. at Attachment 2 

Albermarle Sanibrom 40 Biocide, EPA Reg. No. 3377-25 (09/12/2002) (Sodium bromide is the 

active ingredient to be activated by sodium hypochlorite or chlorine gas to produce hypobromous 

acid); Nalco H-940, EPA Reg. No. 1706-217 (11/04/2003) (Sodium bromide is the active 

ingredient in the formation of hypobromous acid to be activated by chlorine gas or sodium 

hypochlorite); Nalco 93NF152, EPA Reg. No. 1706-181 (07/03/2003) (Sodium bromide is the 

active ingredient to be activated by chlorine gas or sodium hypochlorite). 

Chlorine used as an active ingredient in water treatment is registered by EPA and is 

applied directly to the water system. The in situ reaction with ammonia only stabilizes or 

sequesters the chlorine. To the extent reaction products with ammonia or other substances retain 

antimicrobial activity, it is due to the chlorine. Therefore, chloramine is not an in situ active for 

which a precursor must be registered. 

EPA has approved a label claim that registered ammonia is a precursor to “chloramines.” 

However, chloramines are not registered active ingredients, nor has the Agency at any time 

evaluated their potential risks to man and the environment as a pesticidal active ingredient, 

except potentially within the assessment of chlorine compounds as part of the total chlorine. 

There is, however, no specific identification of any assessment of risks due to chloramines. Nor 

has the Agency published any notices of its intent to register chloramines as active ingredients in 

pesticide products. Consistent with the Agency’s assessment of in-situ generated compounds, 

the Agency registers the appropriate precursor but also registers the in-situ form as an active 

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ingredient and assesses the risks of the actual pesticidally active ingredient. That is the approach 

the Agency has taken with the hydroxymethyldimethyl hydantoins which are being assessed on 

the precursor form as well as on the basis of the actual active ingredient formaldehyde. It also is 

the approach taken by the Agency is its assessment of products producing chlorine dioxide in 

situ. EPA’s failure to follow its own procedures in this situation renders the registration invalid. 

Even if chloramines were (inappropriately, in Nalco’s view) considered by EPA to be a 

new, in situ, active ingredient, the registration of chlorine would satisfy FIFRA, in the same way 

that the registration of one precursor does for chlorine dioxide or bromine compounds. The 

“precursor” approach therefore does not support its registration. 

IV. EPA’s Decision to Require Registration of Ammonia Is Inconsistent with the 

Agency’s Position on Other Chemicals that Perform Similar Functions 

EPA has known for decades that ammonia compounds have been used in conjunction 

with chlorine products to sequester free chlorine in water treatment systems and, prior to the 

Buckman registration, never required registration of these compounds. The Agency’s historical 

position on ammonia was not only with its policy that activators need not be registered, as 

explained above, but also consistent with its position on other chemicals that performed similar 

functions, such as pool stabilizers. For example, cyanuric acid is a chlorine stabilizer that 

prevents the “destruction of residual chlorine by sunlight,” thereby making chlorine more 

effective as an antimicrobial in swimming pools.4

 Cyanuric acid has never been required to be 

 

(Continued...) 

4 See Cantu, R., O. M. Evans, L. J. Wymer, A. P. Dufour, and F. K. Kawahara, 

“Determination of Cyanuric Acid in Swimming Pool Waters Using Phenyl and Confirmatory 

Porous Graphitic Carbon Columns,” Analytical Chemistry 73(14):3358-3364, (2001), abstract

available at http://cfpub.epa.gov/ordpubs/nerlpubs/recordisplay.cfm?deid=65053; See also 

Jacques Steininger, “PPM or ORP: Which Should be Used?,” available at 

http://www.energistx.com/water/ppmorp.pdf (Only 10 to 15 percent of chlorine residuals were 

destroyed in two to three hours with the addition of cyanuric acid as opposed to 90 percent 

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registered as a pesticide under FIFRA.5

 A review of inert ingredient listings provides numerous 

other examples of compounds with similar abilities to interact with a pesticide active that EPA 

has not required to be registered. For example, products which do not require registration as 

active ingredients include: stabilizers (e.g. diethanolamine), sequestrants (e.g. disodiumzinc 

ethylenediaminetetraacetatedihydride), synergists (e.g. ammonium carbamate). See Attachment 

3 for a partial listing. Note that each of these is an unregulated adjuvant if sold separately. 

In fact, the Agency has recognized that the chemistry of sodium bromide results in 

formation of nitrogen-bromine compounds, similar to that for the nitrogen-chlorine chemistry 

(“Another mode of dissipation of hypobromous acid in waste water is via reaction with ammonia 

to form bromamines.” See Reregistration Eligibility Decision for Inorganic Halides, Case 4051 

(Sep. 1993)). The position taken by the Agency in relation to chlorine compounds has not been 

considered in relation to sodium bromide or many other compounds where analogous situations 

exist. 

EPA Office of Pesticide Programs has long recognized that separately added adjuvants 

are used with pesticides and that such separately added adjuvants are not subject to regulation 

under FIFRA (see, for example, 70 FR 31401, June 1, 2005; “EPA is aware that inert ingredients 

are also contained in pesticide adjuvant products which are not subject to registration under 

FIFRA. The Agency does not keep records of currently used adjuvants or their ingredients.”). 

 

without cyanuric acid); See e.g. IntheSwim’s Stabilizer, available at

http://www.intheswim.com/Pool-Chemicals/Water-Balancing-Pool-Chemicals/StabilizerConditioner/. 

5

 Cyanuric acid can be reacted with chlorine compounds to form chlorinated 

isocyanurates. In this case, the compounds are pesticidally active in and of themselves, while 

retaining stabilizer characteristics. When these compounds are sold, they must be registered 

pesticides, as is appropriate for any compound that is pesticidally active.

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When those compounds are a component of a pesticide product (as an inert, or other, ingredient), 

then those compounds are regulated under FIFRA and, if used on food or feed, under FFDCA. 

Long-established regulations for exemptions from tolerance for inert ingredients in pesticide 

products at 40 CFR 180.910 and 180.920, for example, include multiple ammonia based 

compounds identified as sequestrants, synergists, buffers and intensifiers, as are other types of 

compounds (See Appendix 3). Stabilizers for chlorine-based products are well-known. As an 

example, the State of California, which regulates adjuvants, maintains a data base containing 288 

different products registered as adjuvants to chlorine-based swimming pool products, including 

compounds such as muriatic acid, cyanuric chlorine stabilizers, potassium monopersulfate, and 

others (See Appendix 4). These compounds are not regulated by EPA, nor are they required to 

be registered. 

This is clearly stated by EPA in its guidance on pesticide product labeling in relation to 

co-packaging of pesticidal and non-pesticidal adjuvants (“The regulation at 40 CFR 152.3(t) 

states that the "pesticide product" includes the package intended to be distributed or sold. EPA 

has jurisdiction over the packaging and labeling of any "non-pesticide" which is part of the 

package. This means that the Agency reviews and accepts or disapproves of the non-pesticide 

that is packaged with the pesticide. The reviewer examines the non-pesticide labeling to 

determine whether it contains any language that conflicts with the pesticide label, but the 

reviewer does not actually stamp the non-pesticide label. An example of such a non-pesticide 

would be an activator (such as potassium permanganate) which accompanies a pesticide (sodium 

bromide). EPA reviews the labels for both products, but stamps only the accepted pesticide label, 

noting any problems or changes needed for the non-pesticide label.” See EPA Label Review 

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Manual, Chapter 18, Section IIA, available at www.epa.gov/oppfead1/labeling/lrm/chap18.htm). 

EPA has been well aware that ammonia is used as a production aid in water treatment, 

without identifying any need for its registration. “A typical system for surface water treatment 

generally consists of pre-settling, coagulation/flocculation (sediment removal), granular filtration 

(sediment removal), corrosion control (pH adjustment or addition of corrosion inhibitors), and 

disinfection (J.M.M. Consulting Engineers, 1985; Faust and Aly, 1999; USEPA, 1989). It is 

important to note there are many variations on this common sequence, regarding points of 

addition of a wide variety of chemicals (e.g., chlorine, ammonia, ozone, coagulants, filter aids, 

PAC, etc.).” See EPA, OPP 2001, The incorporation of water treatment effects on pesticide 

removal and transformations in Food Quality Protection Act (FQPA) Drinking Water 

Assessments, Office of Pesticide Programs Science Policy, EPA-HQ-OPP-2007-0790-0001 at 

www.epa.gov/oppfead1/trac/science/water_treatment.pdf. 

Ammonia used in connection with chlorine in water treatment is an adjuvant. As EPA 

implicitly acknowledged in the TRAC process, there is no rational basis for requiring registration 

of ammonia compounds when literally dozens of other compounds used in a similar manner are 

not required to be registered. 

V. EPA Should Articulate a Rule of Decision Regarding When Registration is 

Required and Assess the Impact of that Rule Before Implementing It 

 In evaluating whether to reverse the Agency’s long-held position and require registration 

of ammonia used in connection with chlorine-based water treatment, OPP should understand and 

articulate a rule of decision and understand the implications and impact of that rule on users of 

chemicals and technologies that are, or may be interpreted as being, subject to it. As explained 

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above, the decision to register ammonia is contrary to the precedent set with chlorine dioxide, 

sodium bromide, all technologies that use unregistered activators, chlorine stabilizers for 

swimming pools, adjuvants that react with the registered pesticides and inert ingredients that 

serve the same function. If EPA continues to assert that ammonia used in chlorine based water 

treatment requires registration, the rationale for such a decision needs to be clearly articulated. 

This rationale should be subject to public comment – and possibly a Science Advisory Panel 

Hearing, to ensure that it is defensible. 

 The practical implications of any rule of decision also should be evaluated by EPA. Will 

it apply only to ammonia used in chlorine based water disinfection, or will the logic also affect 

other chemistries and technologies. The Agency also should evaluate whether any changes it 

makes to current practice will be addressing a problem – or will they simply be creating 

additional work for the Agency and expanding the regulated community to entities or chemistries 

not previously subject to FIFRA. 

The economic impact of any decision to extend registration requirements also should be 

understood. The current situation, in which the one registrant of ammonia is threatening EPA 

enforcement against users of similar systems in pulp and paper mills using unregistered ammonia 

compounds, is creating confusion in the marketplace. ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||| 

||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||| 

The impact on the drinking water treatment industry also will be massive. By EPA’s own 

estimate, at least 68 million people are served by systems that deliberately add ammonia 

compounds to chlorine-based water treatment to create chloramines. This industry is entirely 

- 16 -
unaware that the entire industry will need to obtain registrations for the products it uses, or that it 

has been operating in violation of FIFRA since registrations were first granted. 

Similarly, any rule of decision EPA devises likely will impact other chemistries and 

technologies. It seems likely that chlorine dioxide and sodium bromide activators will have to be 

registered. (The absurdity of this is highlighted by the fact that when EPA acted as the Remedial 

Action Contractor to eliminate anthrax from the Hart Senate Office Building, it used registered 

sodium chlorite and unregistered activators to generate the chlorine dioxide gas on site.) The 

rule of decision also may well include chlorine stabilizers for swimming pools and adjuvants that 

act as synergists, stabilizers, or have other functional reactions with an active ingredient. The 

economic impact of requiring all of these products to be registered should be carefully assessed 

by EPA. 

VI. EPA Should Make Clear and Public that it is Reevaluating its Position, and that the 

Both Unregistered and Registered Ammonia Compounds Can be used in Chlorine 

Based Water Treatment Systems Until this Process is Complete 

Regardless of the EPA’s decision as to whether ammonia used in connection with 

chlorine-based water treatment, there is an urgent need to communicate to the marketplace that 

the status quo can continue without fear of enforcement until the issue gets resolved. There is a 

real need for reassurance to users and sellers of unregistered adjuvants that they will not be 

subject to enforcement and will be afforded an opportunity to come into compliance with any 

new interpretation or requirements. No regulatory purpose will be served by continuing to 

compel the regulated community to remain uncertain as to whether it is in compliance. EPA 

should make a public announcement that it is evaluating this issue, and that until that is 

completed, both unregistered and registered sources of ammonia or other activators or adjuvants, 

can be used and will be considered in compliance with FIFRA. 

- 17 -
VII. Conclusion 

In sum, ammonia does not have independent antimicrobial activity, nor does it increase 

the efficacy of chlorine compounds. Rather, ammonia prolongs the availability of chlorine, 

either as free chlorine or as chloramines. EPA has consistently held that products that provide 

this type of stabilization function for pesticides are not required to be registered under FIFRA. 

The decision made by EPA cannot have considered the chemistry of ammonia in chlorine water 

treatment systems, the full range of products used in a manner similar to ammonia in chlorinebased systems, the policy implications of the decision, the impact on a wide range of active 

ingredients and industries, or the procedural issues attendant to registration of a new active 

ingredients. The registration decision was incompletely considered. In light of more complete 

information, as set forth above, registration of ammonia for use in chlorine based water treatment 

is inconsistent with FIFRA, agency practice and EPA’s procedural regulations. Nalco therefore 

respectfully suggests that EPA re-evaluate its recent decision with regard to registration of 

ammonia used with chlorine in water treatment and withdraw the registration. During the 

pendency of that review, Nalco urges EPA to promptly notify those affected by the ammonia 

registration and its reevaluation that both unregistered and registered ammonia may be sold and 

used, and that the Agency is committed to providing adequate notice of any decision that will 

require widespread registration. 

- 18 -
APPENDIX I 


























APPENDIX II 







APPENDIX III 
Appendix 3 

Listing of Tolerance Exemptions for Other (Inert) Components of Pesticide Products Where The 

Tolerance Identifies Reactivity 

40 CFR 180.910 (inerts, pre and post harvest 

Inert Ingredient Limits Uses 

Acetic acid catalyst 

Ammonium carbamate Synergist in aluminum phosphide 

formulations 

Ammonium chloride Intensifier when used with 

ammonium nitrate as a dessicant 

or defoliant. Fire suppressant in 

aluminum phosphide and 

magnesium phosphide 

formulations 

Ammonium hydroxide Solvent, cosolvent, neutralizer, 

solubilizing agent 

Ammonium thiosulfate Intensifier when used with 

ammonium nitrate as desiccant or 

defoliant 

Calcium chloride Stabilizer 

1,2-Dihydro-6-ethoxy-2,2,4-

trimethylquinolene 

Not more than 0.02% of pesticide 

formulation 

Antioxidant 

Disodium zinc 

ethylenediaminetetraacetate 

dihydride 

Sequestrant 

Dodecylbenzenesulfonic acid, 

amine salts 

Release rate regulator in 

pheromone formulation 

Ethylenediaminetetraacetic acid 3% of pesticide formulation Sequestrant 

Ethylenediaminetetraacetic acid, 

tetrasodium salt 

5% of pesticide formulation Sequestrant 

Hydrochloric acid Solvent, neutralizer 

Hydroxyethylidine diphosphonic 

acid (HEDP) (CAS Reg. No. 

2809–21–4) 

For use in antimicrobial pesticide 

formulations at not more than 1 

percent 

Stabilizer, chelator 

Magnesium chloride Safener 

Magnesium sulfate Solid diluent, carrier, safener 

Oxalic acid No more oxalic acid should be 

used than is necessary to chelate 

calcium and in no case should 

more than 2 lb oxalic acid per 

acre be used 

Calcium chelating hard water 

inhibitor 

Potassium hydroxide Neutralizer 

Potassium phosphate Buffer 

Propyl gallate Antioxidant 

Sodium hydroxide Neutralizer 

Sodium hexametaphosphate Surfactant, emulsifier, wetting 

agent, suspending agent, 

dispersing agent, buffer 
Appendix 3 

40 CFR 180.910 (inerts, pre and post harvest 

Inert Ingredient Limits Uses 

Sodium silicate Surfactant, emulsifier, wetting 

agent, stabilizer, inhibitor 

Sodium sulfite Stabilizer 

Sulfuric acid (CAS Reg. 

No.7664–93–9) 

pH Control agent 

Thiosulfuric acid, disodium salt, 

anhydrous. (CAS Reg. No 7772–

98–7) 

Dechlorinator, reducing agent 

40 CFR 180.920 (pre harvest use only) 

Inert Ingredient Limits Uses 

Adenosine (CAS Reg. No. 58–

61–7) 

Maximum of 0.5% of 

formulation 

Synergist 

Aluminum sulfate Safener adjuvant 

Ammonium nitrate (CAS Reg. 

No. 6484–52–2) 

Adjuvant/ intensifier for 

herbicides 

Ammonium polyphosphate (CAS 

Reg. No. 68333–79–9) 

Sequestrant, buffer, or surfactant 

Boric acid Sequestrant 

Camphor (CAS Reg. No. 76–22–

2) 

Not more than 5% weight to 

weight (w/w) of pesticide 

formulations 

Deodorant, melting point 

adjustment 

Carbonic acid, dipotassium salt 

(CAS Reg. No. 584–08–7) 

Buffering agent 

Carbonic acid, dipotassium salt, 

trihydrate (CAS Reg. No. 18662–

52–7) 

Buffering agent 

Cysteine (CAS Reg. No. 52–90–

4) 

Maximum of 0.5% of 

formulation 

Synergist 

Diammonium phosphate (CAS 

Reg. No. 7783–28–0) 

Buffer, surfactant 

Diethanolamine Stabilizer, inhibitor for 

formulations used before crop 

emerges from soil 

Diethylene glycol Deactivator, adjuvant for 

formulations used before crop 

emerges from soil 

Diethylene glycol and diethylene 

glycol monobutyl, monoethyl, 

and monomethyl ethers 

Deactivator for formulations used 

before crop emerges from soil, 

stabilizer 

Dipropylene glycol monomethyl 

ether 

Stabilizer 

Ethylene glycol Antifreeze, deactivator for all 

pesticides used before crop 

emerges from soil and in 

herbicides before or after crop 

emerges 

- 2 - 
Appendix 3 

40 CFR 180.920 (pre harvest use only) 

Inert Ingredient Limits Uses 

Folic acid (CAS Reg. No. 59–

30–3) 

Maximum of 0.5% of 

formulation 

Synergist 

Gluconic acid (and sodium salt) Sequestrant 

Glutamine (CAS Reg. No. 56–

85–9) 

Maximum of 0.5% of 

formulation 

Synergist 

Maleic acid and maleic 

anhydride 

For pesticide formulations 

applied to apples with a 

minimum preharvest interval of 

21 days 

Stabilizer 

Methionine (CAS Reg. No. 59–

51–8) 

Maximum of 0.5% of 

formulation 

Synergist 

Nicotinamide (CAS Reg. No. 

98–92–0) 

Maximum of 0.5% of 

formulation 

Synergist 

α-Pinene Not more than 2% of formulation 

by weight 

Stabilizer 

Potassium dihydrogen phosphate Buffering agent 

Pyridoxine (CAS Reg. No. 65–

23–6) 

Maximum of 0.5% of 

formulation 

Synergist 

Sodium metaborate Sequestrant 

Tetrapotassium pyrophosphate 

(CAS Reg. No. 7320–345) 

Not to exceed 10% of Sequestrant, anticaking agent, 

conditioning agent 

Triethylene glycol Deactivator 

Tryptophan (CAS Reg. No. 73–

22–3) 

Maximum of 0.5% of 

formulation 

Synergist 

40 CFR 180.930 (Use on Animals) 

Inert Ingredient Limits Uses 

Acetic acid Catalyst 

- 3 - 
APPENDIX IV 
Appendix 4. 

Listing of CDPR-Registered Adjuvants as Water Modifiers 

(Listing as of November 30, 2007) 

I. Output Reporting 

Query Parameters 

Sites: ADJUVANT: WATER MODIFIER(99008) 

Active Chemicals only

288 product labels match. 

There are too many products to list for individual product selection.If you want to see all 

of them in detail, select a format and press Run Report. Depending on the number of 

products this may be a very large report. You may want to go back and make your search 

criteria more specific. 

• ACTIVE (04/20/04) - ADVANTAGE PLUS ( 74849-50001-AA ) 

• ACTIVE (08/09/04) - ALKALINITY BOOSTER ( 69470-50004-AA ) 

• ACTIVE (03/04/05) - ALKALINITY INCREASER ( 41760-50013-AA ) 

• ACTIVE (07/17/06) - ALKALINITY UP ( 42291-50010-AA ) 

• ACTIVE (02/22/91) - ALL CLEAR ALKALINITY ( 9215-50004-AA ) 

• ACTIVE (07/02/91) - ALL CLEAR CYANURIC CHLORINE STABILIZER ( 9215-

50006-AA ) 

• ACTIVE (04/07/88) - ALL CLEAR DRY ACID ( 9215-50003-AA ) 

• ACTIVE (07/09/91) - ALL CLEAR OXIDIZER NON CHLORINE SHOCK ( 9215-

50005-AA ) 

• ACTIVE (05/12/92) - ALL CLEAR SPA ALKALINITY ( 9215-50012-AA ) 

• ACTIVE (05/12/92) - ALL CLEAR SPA DRY ACID ( 9215-50011-AA ) 

• ACTIVE (01/06/93) - ALL CLEAR SPA OXIDIZER NON CHLORINE SHOCK ( 9215-

50007-AA ) 

• ACTIVE (07/23/92) - ALL CLEAR SPA SODA ASH ( 9215-50008-AA ) 

• ACTIVE (01/29/04) - ALL CLEAR YELLOW ELIMINATOR ( 9215-50013-AA ) 

• ACTIVE (01/11/88) - ALL-CLEAR SODA ASH ( 9215-50001-AA ) 

• ACTIVE (07/16/07) - AMS PREMIUM LIQUID (1051169-50002-AA ) 

• ACTIVE (07/07/05) - ANTIFOAM D ( 70227-50003-AA ) 

• ACTIVE (06/19/07) - ANTIFOAM K ( 70227-50001-AA ) 

• ACTIVE (08/04/04) - AQUA BALANCE CHLORINE FREE OXIDIZER ( 1677-50006-

AA ) 

• ACTIVE (09/14/04) - AQUA BALANCE MURIATIC ACID ( 1677-50007-AA ) 

• ACTIVE (09/22/04) - AQUA BALANCE PH PLUS ( 1677-50009-AA ) 

• ACTIVE (07/14/04) - AQUA BALANCE POOL CONDITIONER ( 1677-50004-AA ) 

• ACTIVE (09/22/04) - AQUA BALANCE PURE COMFORT BASE BLEND ( 1677-

50010-AA ) 

• ACTIVE (07/14/04) - AQUA BALANCE SPF-3050 ( 1677-50005-AA ) 

• ACTIVE (09/22/04) - AQUA BALANCE TOTAL ALKALINITY ( 1677-50008-AA ) 
Appendix 4 

• ACTIVE (11/04/97) - AQUA CHEM BALANCED FOR CLEAN POOLS ALKALINITY 

PLUS ( 67262-50018-ZA ) 

• ACTIVE (04/09/04) - AQUA CHEM BALANCED FOR CLEAN POOLS MUSTARD 

FREE ( 67262-50022-AA ) 

• ACTIVE (05/24/94) - AQUA CHEM BALANCED FOR CLEAN POOLS PH ADD 

SODA ASH ( 67262-50009-AA ) 

• ACTIVE (05/24/94) - AQUA CHEM BALANCED FOR CLEAN POOLS PH 

DECREASER DRY ACID ( 67262-50002-AA ) 

• ACTIVE (05/26/94) - AQUA CHEM BALANCED FOR CLEAN POOLS SHOCK AND 

SWIM ( 67262-50007-AA ) 

• ACTIVE (06/20/94) - AQUA CHEM BALANCED FOR CLEAN POOLS STABILIZER 

( 67262-50004-AA ) 

• ACTIVE (07/11/05) - AQUA CHEM MURIATIC ACID ( 10897-50032-AA ) 

• ACTIVE (10/17/94) - AQUA CHEM PH DECREASER - MURIATIC ACID ( 67262-

50003-AA ) 

• ACTIVE (02/05/97) - AQUA ONE GO BROM ( 7364-50016-AA ) 

• ACTIVE (09/26/07) - AZURE NON-CHLORINE SHOCK OXIDIZER ( 75217-50001-

AA ) 

• ACTIVE (04/12/07) - AZURE PH DECREASER ( 69470-50009-AA ) 

• ACTIVE (04/12/07) - AZURE PH INCREASER ( 69470-50008-AA ) 

• ACTIVE (04/12/07) - AZURE STABILIZER & CONDITIONER ( 69470-50010-AA ) 

• ACTIVE (10/30/87) - B'S POOL SUPPLY MURIATIC ACID ( 55487-50001-AA ) 

• ACTIVE (02/16/05) - BAQUA SPA PH DECREASER (1050607-50063-AA ) 

• ACTIVE (02/16/05) - BAQUA SPA PH INCREASER (1050607-50064-AA ) 

• ACTIVE (03/21/06) - BAQUA SPA TOTAL ALKALINITY INCREASER (1050607-

50080-AA ) 

• ACTIVE (02/16/05) - BAQUACIL PH DECREASER (1050607-50071-AA ) 

• ACTIVE (02/16/05) - BAQUACIL PH INCREASER (1050607-50072-AA ) 

• ACTIVE (05/05/06) - BB5 NATURAL (1051161-50001-AA ) 

• ACTIVE (08/12/96) - BIOGUARD BALANCER BALANCE PAK 100 ( 5185-50004-ZA 

) 

• ACTIVE (09/10/96) - BIOGUARD BALANCER BALANCE PAK 200 ( 5185-50002-ZA 

) 

• ACTIVE (07/14/97) - BIOGUARD BALANCER LO'N SLO ( 5185-50001-ZA ) 

• ACTIVE (08/12/96) - BIOGUARD BALANCER STABILIZER 100 ( 5185-50003-ZA ) 

• ACTIVE (06/24/98) - BIOGUARD OXIDIZER OXYSHEEN ( 5185-50006-ZB ) 

• ACTIVE (11/12/97) - BREAK-THRU S321 (1051059-50003-AA ) 

• ACTIVE (02/16/05) - BRILLIANCE FOR SPAS OXIDIZER (1050607-50067-AA ) 

• ACTIVE (03/21/06) - BRILLIANCE FOR SPAS TOTAL ALKALINITY INCREASER 

(1050607-50079-AA ) 

• ACTIVE (02/16/05) - BRILLIANCE PH DECREASER (1050607-50065-AA ) 

• ACTIVE (02/16/05) - BRILLIANCE PH INCREASER (1050607-50066-AA ) 

• ACTIVE (08/03/05) - BROMIDE STARTER ( 71822-50002-AA ) 

• ACTIVE (09/15/05) - BRONC MAX ( 2935-50174-AA ) 

• ACTIVE (05/18/04) - CAL-AGRA SPREADER-90 (1051080-50031-AA ) 

- 2 - 
Appendix 4 

• ACTIVE (03/21/06) - CHLORINE FREE BAQUACIL TOTAL ALKALINITY 

INCREASER (1050607-50082-AA ) 

• ACTIVE (05/24/94) - CHLORINE STABILIZER ( 67262-50015-AA ) 

• ACTIVE (05/02/05) - CLEARVIEW PH DOWN ( 75538-50001-AA ) 

• ACTIVE (05/02/05) - CLEARVIEW PH UP ( 75538-50002-AA ) 

• ACTIVE (02/23/06) - CLEARVIEW WATER CONDITIONER ( 75538-50003-AA ) 

• ACTIVE (03/18/03) - CONDITIONER ( 11411-50016-AA ) 

• ACTIVE (07/17/02) - CORN FOAM ( 64898-50001-AA ) 

• ACTIVE (06/25/07) - CUT-RATE ( 2935-50179-AA ) 

• ACTIVE (05/21/04) - CYGNET PLUS (1051114-50001-AA ) 

• ACTIVE (10/28/97) - DESERT STAR MURIATIC ACID ( 58008-50001-AA ) 

• ACTIVE (01/14/03) - DRY ACID ( 11411-50015-AA ) 

• ACTIVE (06/17/04) - DUPONT OXONE ( 71654-50001-AA ) 

• ACTIVE (03/11/03) - E Z CLOR CONDITIONER STABILIZER ( 71141-50002-AA ) 

• ACTIVE (01/04/88) - E-Z CLOR ALKALINITY UP ( 42177-50001-AA ) 

• ACTIVE (08/08/91) - E-Z CLOR CLOR SAVE ( 42177-50004-AA ) 

• ACTIVE (01/30/96) - E-Z CLOR O2 SHOCK ( 42177-50008-AA ) 

• ACTIVE (01/04/88) - E-Z CLOR PH DOWN ( 42177-50003-AA ) 

• ACTIVE (01/04/88) - E-Z CLOR PH UP ( 42177-50002-AA ) 

• ACTIVE (09/18/03) - EASYCARE SOFTRISE PH & ALKALINITY INCREASER ( 

62852-50001-AA ) 

• ACTIVE (09/18/03) - EASYCARE SOFTSHOCK ( 62852-50004-AA ) 

• ACTIVE (06/22/04) - EQUINOX STABILIZER-15 ( 6836-50002-AA ) 

• ACTIVE (10/29/85) - ESBRO MURIATIC ACID ( 11011-50001-AA ) 

• ACTIVE (06/14/06) - EXSPOR ACTIVATOR CONCENTRATE ( 1677-50012-AA ) 

• ACTIVE (01/02/91) - FRESH & CLEAN CYAUNURIC ACID ( 9215-50002-ZA) 

• ACTIVE (09/11/06) - FRESH 'N CLEAR EZ DOSE ( 11411-50018-AA ) 

• ACTIVE (09/10/02) - FRESH WATER MPS CHLORINE-FREE OXIDIZER ( 73081-

50001-AA ) 

• ACTIVE (09/10/02) - FRESH WATER PH/ALKALINITY DOWN FOR SPAS ( 73081-

50002-AA ) 

• ACTIVE (09/10/02) - FRESH WATER PH/ALKALINITY UP FOR SPAS ( 73081-

50003-AA ) 

• ACTIVE (04/16/96) - GLB ALKALINITY UP ( 7364-50015-AA) 

• ACTIVE (05/09/94) - GUARDEX ALKALINITY INCREASER ( 10305-50028-AA ) 

• ACTIVE (05/09/94) - GUARDEX DRY ACID ( 10305-50030-AA ) 

• ACTIVE (03/03/99) - GUARDEX PH ANCHOR ( 10305-50045-ZA ) 

• ACTIVE (05/09/94) - GUARDEX PH INCREASER ( 10305-50036-AA ) 

• ACTIVE (05/09/94) - GUARDEX SUPER OXIDIZER ( 10305-50038-AA ) 

• ACTIVE (07/09/97) - HASA ALKALINITY UP ( 10897-50001-AA) 

• ACTIVE (08/11/97) - HASA DRY ACID ( 10897-50010-AA) 

• ACTIVE (11/18/02) - HASA HI-TEMP SPA BROMINE RESERVE ( 10897-50030-AA ) 

• ACTIVE (07/09/97) - HASA HI-TEMP SPA PH INCREASER ( 10897-50002-AA) 

• ACTIVE (05/02/97) - HASA MURIATIC ( 10897-50008-AA) 

• ACTIVE (07/26/67) - HASA POOL CONDITIONER ( 10897-50006-AA) 

• ACTIVE (07/29/97) - HASA SODA ASH ( 10897-50009-AA) 

- 3 - 
Appendix 4 

• ACTIVE (04/17/02) - HASA SODIUM BROMIDE ( 10897-50028-AA ) 

• ACTIVE (01/24/06) - HRR ENHANCER (1051158-50001-AA ) 

• ACTIVE (04/15/02) - HTH ALKALINITY PLUS BALANCER (1050607-50044-AA ) 

• ACTIVE (03/21/06) - HTH BROM-START (1050607-50038-ZA ) 

• ACTIVE (04/15/02) - HTH PH INCREASER SPA (1050607-50046-AA ) 

• ACTIVE (04/15/02) - HTH PH MINUS BALANCER (1050607-50041-AA ) 

• ACTIVE (04/15/02) - HTH PH PLUS BALANCER (1050607-50043-AA ) 

• ACTIVE (04/15/02) - HTH POOLIFE ALKALINITY PLUS BALANCER (1050607-

50051-AA ) 

• ACTIVE (04/15/02) - HTH POOLIFE BROM START SPA (1050607-50045-AA ) 

• ACTIVE (04/15/02) - HTH POOLIFE CLEAR IT SPA (1050607-50047-AA ) 

• ACTIVE (04/15/02) - HTH POOLIFE PH MINUS BALANCER (1050607-50048-AA ) 

• ACTIVE (04/15/02) - HTH POOLIFE PH PLUS BALANCER (1050607-50050-AA ) 

• ACTIVE (04/15/02) - HTH POOLIFE STABILIZER & CONDITIONER BALANCER 

(1050607-50049-AA ) 

• ACTIVE (01/22/04) - HTH POOLIFE YELLOWRID (1050607-50062-AA ) 

• ACTIVE (02/16/05) - HTH SPA CLEAR-IT WITH THERAPEUTIC MINERAL SALTS 

(1050607-50068-AA ) 

• ACTIVE (02/16/05) - HTH SPA PH DECREASER (1050607-50069-AA ) 

• ACTIVE (02/16/05) - HTH SPA PH INCREASER (1050607-50070-AA ) 

• ACTIVE (04/15/02) - HTH STABILIZER & CONDITIONER BALANCER (1050607-

50042-AA ) 

• ACTIVE (01/22/04) - HTH YELLOWRID (1050607-50061-AA ) 

• ACTIVE (07/18/02) - HYDROCHLORIC ACID 15% ( 70567-50002-AA ) 

• ACTIVE (07/18/02) - HYDROCHLORIC ACID 31% ( 70567-50001-AA ) 

• ACTIVE (07/18/02) - HYDROCHLORIC ACID 7% ( 70567-50003-AA ) 

• ACTIVE (03/15/05) - HYDROTECH SHOCKRIGHT ( 10305-50080-AA ) 

• ACTIVE (08/18/99) - ICA A-30 ( 33980-50002-AA ) 

• ACTIVE (04/18/06) - INSTANT POOL WATER CONDITIONER ( 45729-50001-AA ) 

• ACTIVE (05/05/89) - INTER VALLEY POOL SUPPLY MURIATIC ACID ( 58232-

50001-AA) 

• ACTIVE (03/09/79) - KEM TEK CHLORINE STABILIZER ( 7616-50030-AA) 

• ACTIVE (03/02/88) - KEM TEK PH MINUS ( 7616-50035-AA) 

• ACTIVE (10/01/98) - KEM TEK PH PLUS ( 7616-50039-AA ) 

• ACTIVE (02/04/99) - KEM TEK SPA KEM PH MINUS ( 7616-50040-AA ) 

• ACTIVE (06/08/05) - KEM TEK SWIMMING POOL MURIATIC ACID ( 7616-50044-

AA ) 

• ACTIVE (11/24/03) - KEM TEK YELLOW RELIEF ( 7616-50043-AA ) 

• ACTIVE (09/20/72) - KEMKLOR MURIATIC ACID ( 7616-50018-AA ) 

• ACTIVE (04/20/06) - LD ACTIVATOR CONCENTRATE ( 1677-50011-AA ) 

• ACTIVE (08/06/97) - LEISURE TIME LIQUID SPA DOWN ( 41760-50008-AA) 

• ACTIVE (06/22/98) - LEISURE TIME LIQUID SPA UP ( 41760-50010-AA) 

• ACTIVE (07/11/94) - LEISURE TIME OZ ( 41760-50006-AA) 

• ACTIVE (11/07/01) - LEISURE TIME RENEW ( 41760-50011-AA ) 

• ACTIVE (09/06/06) - LEISURE TIME RENEW TABS ( 41760-50015-AA ) 

• ACTIVE (10/27/88) - LEISURE TIME SODIUM BROMIDE ( 41760-50005-AA) 

- 4 - 
Appendix 4 

• ACTIVE (04/11/05) - LEISURE TIME SPA DOWN ( 41760-50014-AA ) 

• ACTIVE (07/23/98) - LESLIE'S CONDITIONER ( 11411-50006-AA ) 

• ACTIVE (07/23/98) - LESLIE'S DRY ACID ( 11411-50009-AA ) 

• ACTIVE (05/08/01) - LESLIE'S SWIMMING POOL SUPPLIES MURIATIC ACID ( 

7616-50042-AA ) 

• ACTIVE (03/23/07) - LESLIE'S SWIMMING POOL SUPPLIES SPA PH UP ( 11411-

50019-AA ) 

• ACTIVE (11/16/04) - MARQUIS SPAS JUST WHAT YOU NEED PH & ALKALINITY 

DOWN ( 50983-50002-AA ) 

• ACTIVE (11/16/04) - MARQUIS SPAS JUST WHAT YOU NEED PH & ALKALINITY 

UP ( 50983-50001-AA ) 

• ACTIVE (11/16/04) - MARQUIS SPAS JUST WHAT YOU NEED SPA SHOCK ( 

50983-50003-AA ) 

• ACTIVE (01/31/07) - NALCO 03PO125 ( 1706-50006-AA ) 

• ACTIVE (03/28/88) - NEO-CONDITIONER ( 33980-50001-AA ) 

• ACTIVE (11/17/06) - NEW BEGINNING (1051157-50003-AA ) 

• ACTIVE (05/26/94) - NON-CHLORINE ( 67262-50014-AA ) 

• ACTIVE (03/03/99) - OMNI PH ANCHOR ( 10305-50045-AA ) 

• ACTIVE (06/12/84) - OMNI PH DECREASER ( 10305-50004-AA ) 

• ACTIVE (05/24/84) - OMNI PH INCREASER ( 10305-50001-AA) 

• ACTIVE (06/04/84) - OMNI POOL CHLORINE STABILIZER ( 10305-50002-AA) 

• ACTIVE (01/08/90) - OMNI QUICK CLEAR ( 10305-50027-AA) 

• ACTIVE (05/11/88) - OMNI SPA SHOCK TREATMENT ( 10305-50010-AA) 

• ACTIVE (03/19/84) - OMNI TOTAL ALKALINITY INCREASER ( 10305-50003-AA) 

• ACTIVE (05/04/83) - OXY-BRITE ( 7364-50001-AA ) 

• ACTIVE (11/16/06) - OXY-SPA NON-CHLORINE SHOCK FOR SPAS, HOT TUBS & 

POOLS ( 82043-50001-AA ) 

• ACTIVE (08/23/06) - PACIFICLEAR NO CHLOR ( 75377-50001-AA ) 

• ACTIVE (07/09/03) - PERAFORCE ( 50600-50001-AA ) 

• ACTIVE (07/03/07) - PERFECT PH ( 42291-50015-AA ) 

• ACTIVE (09/26/07) - PH BALANCE ( 41760-50017-AA ) 

• ACTIVE (03/19/07) - PH BALANCE PLUS ( 41760-50016-AA ) 

• ACTIVE (08/09/04) - PH DECREASER ( 69470-50002-AA ) 

• ACTIVE (01/22/86) - PH DOWN ( 7364-50004-AA) 

• ACTIVE (05/24/94) - PH DOWN ( 67262-50016-AA ) 

• ACTIVE (04/25/06) - PH DOWN ( 42291-50012-AA ) 

• ACTIVE (08/09/04) - PH INCREASER ( 69470-50001-AA ) 

• ACTIVE (01/22/86) - PH UP ( 7364-50002-AA ) 

• ACTIVE (05/24/94) - PH UP ( 67262-50017-AA ) 

• ACTIVE (04/25/06) - PH UP ( 42291-50011-AA ) 

• ACTIVE (05/30/03) - PH/ALALINITY DOWN FOR SPAS ( 67528-50003-AA ) 

• ACTIVE (03/14/02) - PH/ALKALINITY DOWN ( 7364-50021-AA ) 

• ACTIVE (02/14/02) - PH/ALKALINITY UP ( 7364-50022-AA ) 

• ACTIVE (05/30/03) - PH/ALKALINITY UP FOR SPAS ( 67528-50002-AA ) 

• ACTIVE (09/24/02) - PHREE & CLEAR ( 10772-50006-AA ) 

• ACTIVE (10/14/04) - PHT SAPHEN ( 7001-50012-AA ) 

- 5 - 
Appendix 4 

• ACTIVE (02/16/05) - POOL BREEZE POOL CARE SYSTEM NON-CHLORINE 

OXIDIZER (1050607-50075-AA ) 

• ACTIVE (02/16/05) - POOL BREEZE POOL CARE SYSTEM PH DECREASER 

(1050607-50073-AA ) 

• ACTIVE (02/16/05) - POOL BREEZE POOL CARE SYSTEM PH INCREASER 

(1050607-50074-AA ) 

• ACTIVE (02/16/05) - POOL BREEZE POOL CARE SYSTEM STABILIZER AND 

CONDITIONER (1050607-50077-AA ) 

• ACTIVE (10/03/06) - POOL CARE: SHOCK OXIDIZER ( 71654-50008-AA ) 

• ACTIVE (09/22/06) - POOL CARE: PH AND TOTAL ALKALINITY DECREASER ( 

71654-50002-AA ) 

• ACTIVE (09/22/06) - POOL CARE: PH INCREASER ( 71654-50003-AA ) 

• ACTIVE (09/22/06) - POOL CARE: TOTAL ALKALINITY INCREASER ( 71654-

50004-AA ) 

• ACTIVE (01/11/02) - POOL SEASON ALKALINITY INCREASER ( 10305-50071-AA 

) 

• ACTIVE (01/11/02) - POOL SEASON CONDITIONER ( 10305-50074-AA ) 

• ACTIVE (01/20/05) - POOL SEASON CONDITIONER ( 71141-50003-AA ) 

• ACTIVE (01/11/02) - POOL SEASON NON-CHLORINE SHOCK ( 10305-50072-AA ) 

• ACTIVE (02/01/02) - POOL SEASON PH DECREASER ( 10305-50075-AA ) 

• ACTIVE (01/11/02) - POOL SEASON PH INCREASER ( 10305-50073-AA ) 

• ACTIVE (11/16/06) - POOL SEASON PH MINUS ( 42177-50013-AA ) 

• ACTIVE (10/18/94) - POOL TIME PH DECREASER MURIATIC ACID ( 67262-50013-

AA ) 

• ACTIVE (03/21/06) - POOLBREEZE POOL CARE SYSTEM TOTAL ALKALINITY 

INCREASER (1050607-50078-AA ) 

• ACTIVE (03/21/06) - POOLIFE EXCLUSIVE POOL CARE COLLECTION 

ALKALINITY PLUS BALANCER (1050607-50081-AA ) 

• ACTIVE (02/16/05) - POOLIFE EXCLUSIVE POOL CARE COLLECTION NONCHLORINE OXIDIZER (1050607-50076-AA ) 

• ACTIVE (09/15/06) - POOLIFE EXCLUSIVE POOL CARE COLLECTION PH MINUS 

BALANCER (1050607-50087-AA ) 

• ACTIVE (09/15/06) - POOLIFE EXCLUSIVE POOL CARE COLLECTION PH PLUS 

BALANCER (1050607-50086-AA ) 

• ACTIVE (02/03/04) - PRISTINE POWER ( 64962-50002-AA ) 

• ACTIVE (04/18/07) - PRO BUPHER ( 71058-50004-AA ) 

• ACTIVE (10/13/00) - PRO GUARD PH DECREASER ( 5185-50019-AA ) 

• ACTIVE (02/27/07) - PROGUARD NON-CHLORINE SHOCK-OXIDIZER ( 5185-

50028-AA ) 

• ACTIVE (02/27/07) - PULSAR SUNSCREEN 20 STABLIZER (1050607-50088-AA ) 

• ACTIVE (06/19/07) - PUROLYTE PLUS (1051157-50004-AA ) 

• ACTIVE (04/18/06) - QUANTUM ALKALINITY UP ( 58307-50001-AA ) 

• ACTIVE (04/18/06) - QUANTUM PH DOWN/POOLS ( 58307-50004-AA ) 

• ACTIVE (04/18/06) - QUANTUM PH UP ( 58307-50005-AA ) 

• ACTIVE (04/18/06) - QUANTUM PH-DOWN LIQUID ( 58307-50007-AA ) 

• ACTIVE (04/18/06) - QUANTUM STABILIZER ( 58307-50002-AA ) 

- 6 - 
Appendix 4 

• ACTIVE (01/17/96) - REGAL ALKALINITY PLUS ( 42177-50001-ZA) 

• ACTIVE (01/30/96) - REGAL OXY-KLEAR ( 42177-50008-ZA) 

• ACTIVE (01/23/96) - REGAL PH MINUS ( 42177-50003-ZC ) 

• ACTIVE (01/17/96) - REGAL PH PLUS ( 42177-50002-ZB) 

• ACTIVE (01/31/96) - REGAL POOL STABILIZER ( 42177-50004-ZD ) 

• ACTIVE (10/05/95) - RENDEZVOUS ACTIVATE ( 7364-50013-AA ) 

• ACTIVE (04/16/96) - RENDEZVOUS ALKALINITY UP ( 7364-50014-AA) 

• ACTIVE (06/22/98) - RENDEZVOUS BROMA START ( 7364-50019-AA) 

• ACTIVE (04/16/96) - RENDEZVOUS PH DOWN ( 7364-50011-AA) 

• ACTIVE (06/07/05) - RENDEZVOUS PH MAGIC ( 7364-50023-AA ) 

• ACTIVE (04/16/96) - RENDEZVOUS PH UP ( 7364-50010-AA) 

• ACTIVE (08/06/97) - RENDEZVOUS SPA DECREASE ( 7364-50017-AA ) 

• ACTIVE (12/09/97) - RENDEZVOUS SPA INCREASE ( 7364-50018-AA ) 

• ACTIVE (11/13/01) - RENEWAL (MINERAL SPRINGS) ( 5185-50022-AA ) 

• ACTIVE (06/24/02) - SANI-CLOR NON-CHLORINE SHOCK ( 10897-50027-AA ) 

• ACTIVE (10/26/98) - SEACO PH BUFFER #2 ( 67799-50001-AA ) 

• ACTIVE (10/10/06) - SEAKLEAR CHLORINE-FREE SHOCK ( 72083-50002-AA ) 

• ACTIVE (10/10/06) - SEAKLEAR SPA - SODIUM BROMIDE FOR SPAS & HOT 

TUBS ( 72083-50003-AA ) 

• ACTIVE (05/30/03) - SHOCK OUT FOR SPAS ( 67528-50001-AA ) 

• ACTIVE (08/20/87) - SHOCKTRINE ( 8959-50006-AA) 

• ACTIVE (06/08/93) - SIERRA MURIATIC ACID ( 8996-50001-AA ) 

• ACTIVE (09/15/71) - SODIUM HYDROXIDE, 30% SOLUTION (CAUSTIC SODA) ( 

8764-50032-AA ) 

• ACTIVE (08/09/01) - SOFTCARE PH DOWN ( 74157-50002-AA ) 

• ACTIVE (08/09/01) - SOFTCARE PH UP ( 74157-50001-AA ) 

• ACTIVE (01/24/03) - SPA ALKALINITY INCREASER ( 41760-50012-AA ) 

• ACTIVE (09/22/06) - SPA CARE: PH DECREASER ( 71654-50005-AA ) 

• ACTIVE (09/22/06) - SPA CARE: SHOCK OXIDIZER ( 71654-50006-AA ) 

• ACTIVE (09/22/06) - SPA CARE: SHOCK OXIDIZER IN WATER-SOLUBLE 

POUCHES ( 71654-50007-AA ) 

• ACTIVE (02/21/03) - SPA CLEAR ALKALINITY INCREASER ( 10305-50076-AA ) 

• ACTIVE (05/09/01) - SPA CLEAR OXY SHOCK ( 10305-50056-AA ) 

• ACTIVE (07/17/01) - SPA CLEAR PH BUFFER ( 10305-50062-AA ) 

• ACTIVE (05/09/01) - SPA CLEAR PH DECREASER ( 10305-50054-AA ) 

• ACTIVE (05/08/01) - SPA CLEAR RELEASE ( 10305-50058-AA ) 

• ACTIVE (03/06/80) - SPA DOWN ( 41760-50002-AA) 

• ACTIVE (11/24/98) - SPA ESSENTIALS ACCESSORY SPA SHOCK FOR SPAS & 

HOT TUBS ( 10305-50040-ZA ) 

• ACTIVE (04/06/99) - SPA ESSENTIALS BALANCER ALKALINITY INCREASER 

FOR SPAS & HOT TUBS ( 10305-50009-ZA ) 

• ACTIVE (06/01/99) - SPA ESSENTIALS BALANCER PH DECREASER FOR SPAS & 

HOT TUBS ( 10305-50006-ZA ) 

• ACTIVE (07/22/99) - SPA ESSENTIALS BALANCER PH INCREASER FOR SPAS & 

HOT TUBS ( 10305-50043-ZA ) 

• ACTIVE (11/30/79) - SPA KEM PH PLUS ( 7616-50033-AA) 

- 7 - 
Appendix 4 

• ACTIVE (11/03/04) - SPA SPECIALTIES BY ROBARB BROM A SPA ACTIVATOR 

AND SHOCK ( 42291-50001-AA ) 

• ACTIVE (11/03/04) - SPA SPECIALTIES BY ROBARB PH DOWN ( 42291-50008-AA 

) 

• ACTIVE (05/14/04) - SPA SPECIALTIES BY ROBARB PH UP ( 42291-50009-AA ) 

• ACTIVE (07/13/04) - SPA SPECIALTIES BY ROBARB SPA PH DOWN ( 42291-

50006-AA ) 

• ACTIVE (07/13/04) - SPA SPECIALTIES BY ROBARB SPA PH UP ( 42291-50005-

AA ) 

• ACTIVE (01/04/00) - SPA TIME NON-CHLORINE SHOCK ( 67262-50020-AA ) 

• ACTIVE (08/07/00) - SPA TIME PH STABLE ( 67262-50021-AA ) 

• ACTIVE (11/14/79) - SPA UP ( 41760-50001-AA) 

• ACTIVE (05/26/94) - SPA-TIME NON-CHLORINE SHOCK TREATMENT ( 67262-

50012-AA ) 

• ACTIVE (05/24/94) - SPA-TIME PH DOWN ( 67262-50011-AA ) 

• ACTIVE (05/24/94) - SPA-TIME PH UP ( 67262-50010-AA ) 

• ACTIVE (07/28/00) - SPAGUARD BALANCER PH DECREASER ( 5185-50018-AA ) 

• ACTIVE (04/29/03) - SPAGUARD OXIDIZER SPA SHOCK ( 5185-50023-AA ) 

• ACTIVE (06/29/99) - SPATIME SPA PREP ( 67262-50019-AA ) 

• ACTIVE (09/12/06) - SPECTRUM NT8002 ( 74655-50001-AA ) 

• ACTIVE (07/17/06) - STABILIZER ( 42291-50013-AA ) 

• ACTIVE (08/09/04) - STABILIZER & CONDITIONER ( 69470-50003-AA ) 

• ACTIVE (02/11/05) - STABILIZER & CONDITIONER ( 10305-50079-AA ) 

• ACTIVE (04/26/01) - SUN CONDITIONER ( 10305-50050-AA ) 

• ACTIVE (01/23/02) - SUN POOL ALKALINITY PLUS ( 10305-50070-AA ) 

• ACTIVE (04/26/01) - SUN POOL MINUS ( 10305-50048-AA ) 

• ACTIVE (04/26/01) - SUN POOL PLUS ( 10305-50049-AA ) 

• ACTIVE (04/26/01) - SUN SUN-BRITE NON-CHLORINE SHOCK TREATMENT ( 

10305-50052-AA ) 

• ACTIVE (09/10/87) - SUNNYSIDE MURIATIC ACID ( 7135-50001-AA ) 

• ACTIVE (12/01/03) - SUNSCAPE MURIATIC ACID ( 8996-50002-AA ) 

• ACTIVE (04/14/98) - SUPERIOR POOL PRODUCTS CONDITIONER STABILIZER ( 

71141-50001-AA ) 

• ACTIVE (02/06/81) - SWIMMING POOL ACID ( 7616-50011-AA ) 

• ACTIVE (06/07/00) - SWIMMING POOL STABILIZER & CONDITIONER ( 10305-

50047-AA ) 

• ACTIVE (09/09/04) - SYNTHEX PCA 63 ( 52467-50017-AA ) 

• ACTIVE (06/28/88) - TC MURIATIC ACID ( 56388-50001-AA) 

• ACTIVE (07/13/99) - TERRA CAL L ( 51032-50001-AA ) 

• ACTIVE (05/24/94) - TOTAL ALKALINITY INCREASER ( 67262-50018-AA ) 

• ACTIVE (05/07/03) - TOTAL ALKALINITY INCREASER ( 10305-50078-AA ) 

• ACTIVE (02/27/04) - TRUE VALUE MURIATIC ACID (1051146-50001-AA ) 

• ACTIVE (07/17/06) - ULTRA QUICK SWIM ( 42291-50014-AA ) 

• ACTIVE (10/25/05) - VANTAGE NON-CHLORINE SHOCK ( 69681-50001-AA ) 

• ACTIVE (11/30/06) - VANTAGE PH MINUS ( 69681-50003-AA ) 

• ACTIVE (11/30/06) - VANTAGE PH PLUS ( 69681-50002-AA ) 

- 8 - 
Appendix 4 

• ACTIVE (06/05/03) - YELLOW OUT ( 8908-50001-AA ) 

- 9 -