Registered pesticides that become chemical weapons--a rose by any other name is still a rose

    I am going to shift focus from biological threats to the Chemical Weapons Convention and the prohibition against the use of chemical weapons in warfare, because of a recent tragedy.  The dual use of many useful chemicals makes the CWC much less effective in preventing fatalities than it might be. On Aug 9, 2014 two more needless deaths were caused by aluminum phosphide, a precursor to a chemical weapon.
     The recent deaths of two children in Dubai due to the use of a chemical used as a precursor in chemical warfare -- aluminum phosphide -- was not due to maliciousness but due to gross negligence.  It is used as an agricultural fumigant and not intended to be used as a pesticide. When it comes in contact with moisture or dropped in water, it produces phosphine, a gas that was related to phosgene a primary chemical weapon in World War I. It is illegal to use in Dubai but the underground pesticide market is still a threat. It is also a problem in developing countries like India.  But if you think this happens only outside of the U.S., think again. In 2010, two young girls in Utah were also killed in an application of aluminum phosphate at or in their home.  Illegal use of pesticides by unregistered or grossly negligence applicators can still occur.
    The efforts to regulate this pesticide by EPA have led to limiting the use of this chemical to fumigating for agricultural uses, only, and not for home pesticide use. In 2000, the U.S. EPA signed an MOA (Memorandum of Agreement) with pesticide registrants to amend its registration to put more restrictions on the use and labeling of the product. The FIFRA statute considers economics as part of the balance of risk management in deciding on registrations. Notice of importation of a pesticide is required by FIFRA and in Nov 2011 EPA took enforcement action against an illegal importation of 25 tons of pesticide including 50,000 pounds of aluminum phosphide from China.
    This chemical can still be used for residents killing of rodents in burrows and some of the risk extends to and beyond the area in use to the neighborhood.  Aluminum phosphide is identified as a risk among chemicals in Houston.  The Department of Homeland Security lists aluminum phosphide in a sabotage/contamination category of "Chemicals of Interest" but stops short of listing it as a CWC precursor.  Because it is regulated under FIFRA, it can escape the CWC list of prohibited chemical weapons, like chlorine for swimming pools, but it is nonetheless, a deadly chemical weapon.
    I believe that FIFRA works and to take into account the usefulness of aluminum phosphide as a fumigant to protect billions of people from rodents eating the same grain we eat is going to prevent a illness and deaths.  Unfortunately, situations like this should call for more urgency to fund research to find better substitutes for aluminum phosphide. But have we made the administrative process for registering pesticides so difficult that we are willing to accept these needless deaths, in exchange for the uncertainties in testing a new or better substitute?  Incentives are needed to replace these pesticides with safer ones, and modeling toxicological risks could speed up the registration process without increasing the risks to the public. It is time to revisit FIFRA.