This letter is in response to your 30 November 1999 request for information concerning Fyrquel 220

Inquiry #20832

This letter is in response to your 30 November 1999 request for information concerning Fyrquel 220. Specifically you want to know the hazards associated with triphenyl phosphate, a component of the product Fyrquel 220. The Navy uses Fyrquel 220 to generate smoke during fire training exercises, and you are concerned about environmental, safety, and occupational health (ESOH) issues associated with the product. In addition, you also requested information on what the Air Force is using to produce smoke for fire training.

We contacted the fyrquel 220 technical service representative, Akzo Nobel Chemicals, (800) 666-1200, and requested the Material Safety Data Sheet (MSDS) for this product. We reviewed the MSDS, enclosed [NPF 20832.1], and noted that triphenyl phosphate is listed as a marine pollutant per Title 49 Code of Federal Regulations (CFR) Appendix B to Section 172.01, "List of Marine Pollutants," and Section 171.4, “Marine Pollutants,” enclosed [NPF 20832.2]. Examination of Title 49 CFR 171.4(c) reveals that marine pollutant restrictions only applies to shipment aboard naval vessels or on motor vehicles, rail cars, or aircraft when shipped in bulk (i.e. greater than 119 gallons). If transporting the marine pollutant via naval vessel or in bulk, you would be required to comply with Title 49 CFR hazardous material transportation regulations (HMRs).

Further review of the MSDS indicated that the primary exposure route of exposure for personnel using Fyrquel 220 is through skin contact and inhalation. Exposure to Fyrquel 220 may cause respiratory irritation, and, at levels above the permissible exposure limit, may cause cholinesterase inhibition leading to possible headache, nausea, sweating, numbness, salivation, and muscle twitching.

Next, we reviewed the Agency for Toxic Substance and Disease Registry (ATSDR) HazDat database (at World Wide Web [WWW] page http://www.atsdr.cdc.gov/hazdat.html ) and Environmental Protection Agency (EPA) publication 550-B-98-017, Title III List of Lists. Our search revealed that triphenyl phosphate is not regulated under any of the following regulations:

1. Toxic Substance Control Act (TSCA);

2. Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA);

3. Resource Conservation and Recovery Act (RCRA);

4. Clean Air Act (CAA);

5. Emergency Planning and Community Right to Know Act (EPCRA) Sections 302 (Extremely Hazardous Substances) and 313 (Toxic Chemicals);

6. Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA).

The ATSDR HazDat database did provide a “ToxFaq” fact sheet, enclosed [NPF 20832.3] on triphenyl phosphate, classified as a hydraulic fluid. The fact sheet specifically lists “Fyrquel” as typical of the product type represented on the fact sheet. Detailed on the fact sheet are answers to the following questions:

1. What are hydraulic fluids?

2. What happens to hydraulic fluids when they enter the environment?

3. How might I be exposed to hydraulic fluids?

4. How can hydraulic fluids affect my health?

5. How likely are hydraulic fluids to cause cancer?

6. Is there a medical test to show whether I’ve been exposed to hydraulic fluids?

7. Has the federal government made recommendations to protect human health?

We next contacted Master Sergeant (MSgt) Thomas, Deputy Fire Chief of Training, Goodfellow Air Force Base, DSN 477-5423. MSgt Thomas stated that the Air Force is using the ROSCO Model 1500, Fog Machine to generate smoke during fire training exercises.

We searched the 1999 version of the Thomas Register of American Manufactures and the World Wide Web to obtain information concerning the ROSCO 1500 Fog Machine. According to the latest information, the ROSCO 1500 has been discontinued; however, it was replaced by the ROSCO 1600. Our search further revealed that this unit uses a vegetable oil-based fog fluid that is non-toxic even when ingested and is “generally regarded as safe” by the United States Food and Drug Administration (FDA). We have provided ordering information, technical data, and the MSDS for the fog fluid, enclosed [NPF 20832.4].