Page
1
of
3
UNITED
STATES
ENVIRONMENTAL
PROTECTION
AGENCY
WASHINGTON,
D.
C.
20460
OFFICE
OF
PREVENTION,
PESTICIDES
AND
TOXIC
SUBSTANCES
April
1,
2004
Memorandum
Subject:
Lower
Risk
Pesticide
Chemical
Focus
Group's
Assessment
for
Carbon
Dioxide
Tolerance
Reassessment
From:
Mark
Perry
Product
Reregistration
Branch
Special
Review
and
Reregistration
Division
(
7508C)

Through:
Linda
Propst,
Branch
Chief
Product
Reregistration
Branch
Special
Review
and
Reregistration
Division
(
7508C)

To:
Lower
Risk
Pesticide
Chemical
Focus
Group
Kathryn
Boyle,
Co­
Chair
Kerry
Leifer,
Co­
Chair
Registration
Division
(
7505C)

The
following
is
the
Lower
Risk
Pesticide
Chemical
Focus
Group's
science
assessment
for
carbon
dioxide
(
PC
Codes
016601,
800029).
The
purpose
of
this
review
is
a
reassessment
of
the
exemption
from
the
requirement
of
a
tolerance
under
40CFR
180.1049.
This
assessment
summarizes
available
information
on
carbon
dioxide.
In
performing
this
assessment,
EPA
has
relied
on
a
peer­
reviewed
evaluation
performed
by
the
Food
and
Drug
Administration
(
FDA).

Carbon
Dioxide
(
CO
2)
is
an
odorless,
colorless,
noncombustible
gas.
Under
ordinary
conditions
of
temperature
and
pressure,
the
gas
is
one
and
one
half
times
as
dense
as
air,
and
is
moderately
soluble
in
water,
dissolving
at
about
a
1:
1
ratio
by
volume.
At
0.03%,
it
is
the
fourth
most
abundant
gas
in
the
Earth's
atmosphere
and
is
an
essential
component
of
plant
and
animal
respiration.
Animals
exhale
carbon
dioxide
as
a
metabolic
byproduct,
and
plants
use
carbon
dioxide
by
converting
it
to
sugars
and
other
forms
of
energy
through
photosynthesis.
In
the
human
body,
carbon
dioxide
is
involved
in
several
vital
functions,
including
the
regulation
of
Page
2
of
3
respiration,
the
maintenance
of
acid­
base
balance,
the
liberation
of
oxygen
to
tissue
and
is
an
endproduct
of
carbohydrate
and
fat
metabolism.
The
average
adult
produces
more
than
500
grams
of
carbon
dioxide
per
day,
under
resting
conditions.

Carbon
dioxide
has
many
commercial
uses.
Its
most
well
known
use
is
in
the
production
of
carbonated
beverages.
It
is
also
used
in
water
softening,
manufacturing
of
aspirin,
as
a
propellant
in
aerosol
cans
and
in
the
coffee
packaging
process.
Solid
carbon
dioxide,
or
dry
ice,
is
used
as
a
refrigerant.
Carbon
dioxide
is
obtained
for
commercial
use
from
chemical
fermentation,
from
the
burning
of
limestone
or
carbonaceous
fuels,
and
from
natural
springs
and
wells.
As
a
pesticide
active
ingredient,
carbon
dioxide
is
used
indoors
as
a
fumigant
to
control
insects
in
stored
food
and
feed
by
displacing
oxygen
in
the
container's
atmosphere.
It
does
not
accumulate
in
treated
raw
agricultural
commodities,
but
rather
diffuses
into
the
atmosphere
following
application.
Currently
there
are
four
registered
end­
use
products
containing
carbon
dioxide
as
the
active
ingredient,
as
well
as
one
experimental­
use
and
one
Special
Local
Needs
registration.
As
a
pesticide
inert
ingredient
carbon
dioxide
is
used
as
an
aerosol
propellant.

The
Office
of
Pesticide
Programs
published
its
Carbon
and
Carbon
Dioxide
Reregistration
Eligibility
Decision
(
RED)
Document
in
September
of
1991.
The
RED
considers
the
many
vital
functions
which
carbon
dioxide
performs
in
the
human
body
as
well
as
the
available
acute,
subchronic
and
chronic
studies
performed
on
carbon
dioxide.
That
document
acknowledged
that
exposure
to
relatively
high
levels
of
carbon
dioxide
may
result
in
serious
health
effects
and
even
death
through
asphyxiation.

The
Food
and
Drug
Administration
(
FDA)
has
classified
carbon
dioxide
as
Generally
Recognized
As
Safe
(
21CFR
184.1240)
as
a
direct
food
additive.
The
1979
FDA
evaluation
of
carbon
dioxide,
entitled
"
Evaluation
of
the
Health
Aspects
of
Carbon
Dioxide
as
a
Food
Ingredient,"
also
considers
the
essential
role
of
carbon
dioxide
in
the
human
body
and
the
available
toxicity
data.
This
evaluation
found
that
although
data
relating
directly
to
carbon
dioxide
safety
as
a
food
ingredient
were
not
available,
"
there
is
substantial
evidence
that
the
amount
of
carbon
dioxide
ingested
with
foods
is
negligible
compared
with
that
produced
normally
by
the
body."
The
Evaluation
also
states
that
"[
c]
arbon
dioxide
also
has
been
administered
experimentally
without
ill
effects
in
amounts
orders
of
magnitude
greater
than
from
possible
food
sources."
The
FDA
evaluation
goes
on
to
conclude
that
"
there
is
no
evidence
in
the
available
information
on
carbon
dioxide
that
demonstrates,
or
suggests
reasonable
grounds
to
suspect,
a
hazard
to
the
public
when
it
is
used
at
levels
that
are
now
current
or
that
might
reasonably
be
expected
in
the
future."

Based
on
the
available
information
on
carbon
dioxide,
its
expected
use
pattern,
its
safe
history
of
use
as
a
food
additive,
and
its
essential
role
in
human
metabolism
and
respiration,
there
is
a
reasonable
certainty
of
no
harm
from
exposure
to
carbon
dioxide
through
its
use
in
pesticides.
Furthermore,
there
is
no
concern
for
potential
sensitivity
to
infants
and
children.
As
with
all
chemicals,
carbon
dioxide
must
be
used
safely
according
to
good
manufacturing
or
good
agricultural
practices.
The
Agency
believes
that
exposure
to
levels
of
concern
of
carbon
dioxide
are
unlikely
as
a
result
of
its
use
in
pesticide
products,
and
would
be
most
appropriately
addressed
through
the
use
of
protective
equipment,
adequate
ventilation,
and
labeling,
not
through
the
establishment
of
tolerance
exemptions.
Page
3
of
3
References:

U.
S.
Environmental
Protection
Agency
(
EPA),
1991.
Reregistration
Eligibility
Document
(
RED),
Carbon
and
Carbon
Dioxide.

U.
S.
Food
and
Drug
Administration
(
FDA),
1979.
Evaluation
of
the
Health
Aspects
of
Carbon
Dioxide
as
a
Food
Ingredient.
Prepared
by
Life
Sciences
Research
Office,
Federation
of
American
Societies
for
Experimental
Biology.
