"Acetone, Methyl alcohol (methanol), Sodium hydroxide (lye), Sulfuric acid (not to exceed 10%), Xylene.  These are just ones I can pronounce. "

In a former life our Ag Formulations group reported to me.  Formulations is some very interesting science I am not going to get into.  I have no clue why acetone or methyl alcohol would be on the GRAS list.  As your own body makes both these chemicals in small amounts during normal metabolism and as both are well known to occur naturally in foods we eat I guess I can not get to worked up over spraying a couple of pounds of either per acre.  Those fall into a class of things we never used and off the top I do not know of anyone else that uses them. They may be on the list simply as the result of some grand fathering.  Sodium hydroxide and sulfuric acid are on there probably because someone wished to adjust pH of his formulation to keep from eating hell out of metal spray nozzles.  Case in point.  At one time I wanted to use disodium phosphate as a buffer to lock the pH of a formulation very close to 7.  I did not want it acid to avoid corrosion issues.  I did not want it basic to avoid degradation of my active ingredient.  But, it turned out disodium phosphate at that time was not on the GRAS list for EPA.  It was on the GRAS list for FDA as a food additive.  EPA said they were happy to go thru the hoops to get it added to EPA's GRAS list but that would take about a year to allow the required time for proposal in the Federal Register and get public comments and do required reviews.  EPA did have sodium hydroxide and phosphoric acid on their GRAS list so I asked if I could use those to adjust my pH in the interim until they had disodium phosphate approved.  EPA said sure.  As long as it was done in entirely in solution I had not made disodium phosphate and was legal.  So, that is what we did for a year.

Many formulations are an active dissolved in some solvent with added surfactants that allow the formulation to emulsify in the water used in spraying.  While I do not see methanol or acetone used in this way very often things like xylene or more commonly a heavy aromatic naphtha are used.  Any bottle of 2,4 D ester or any of the emulsifiable organo phosphates you buy has such a solvent in it.  These solvents are typically sprayed at a rate of a pound or two per acre.  They are modestly volatile and evaporate very fast as a result of the thin film coverage.  Is this an air pollutant?  Of course it is.  But, the terpenes and other volatile organics put out per acre of crop often exceed this amount of organics in the air each day.  In some crops exceed it by a very large margin.  Do you know why the Blue Ridge mountains are so named?  That blue haze is due to terpenes from the forests getting degraded via UV from the sun.  How about banning UV?

The facts of life are that you simply can not take an active ingredient and apply it to a crop without additives that allow it to be sprayed.  Get rid of the GRAS list and you just got rid of all practically all pesticides except those that are water souble by themselves which few are.  Maybe glyphosate and the arsenates could be sprayed with no additives and be still be effective at higher application rates.  But, off the top I can not think of any others.  And without surfactants to control spray droplet size and stickers to hold herbicides and fungicides on the target plants and enhance uptake in some cases you would have to spray far higher concentrations of active which would not be desirable either.  Picking on things like sulfuric acid on the list when you have no clue why they are on the list is simply aimed at an getting an emotional response based on ignorance. 

Dick

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