OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.

January 23, 2001

Mr. Richard D. Nagel
2302 Lake Griffin Rd.
Lady Lake, FL 32159

Dear Mr. Nagel:

Thank you for your November 12 letter to the Occupational Safety and Health Administration (OSHA). Your letter was forwarded to OSHA's [Office of Health Enforcement (OHE)] for a response. You requested information regarding a substance called "Inipol," which was used during the cleanup of the Exxon Valdez oil spill.

Please allow us to provided a brief overview of Inipol's use in this incident. In 1989, to help with the Exxon Valdez oil spill cleanup, the U.S. Environmental Protection Agency (EPA) proposed the use of an oil spill response technology, "bioremediation," to increase the natural rate of oil degradation. Crude oil is a good candidate for bioremediation because even without remediation, the oil eventually degrades through natural environmental processes.

Crude oil decomposes as the result of microbial activity along with exposure to sunlight and air; these processes break the oil down into its basic elements. In theory, the more microbes (bacteria) that work on the breakdown process, the faster the degradation occurs. Bioremediation uses an artificial stimulant to increase the numbers of microbes that work at breaking down the crude oil, thereby helping to speed up the natural process.

The Exxon Valdez oil spill area already had a good population of the correct oil-eating bacteria; the bacterial population simply needed to be increased by adding nitrogen and phosphorus. These elements are most easily provided by spreading fertilizer. Toward this end, the French-manufactured liquid fertilizer, Inipol EAP22, was applied to the oiled beaches.

You asked if there were any side effects from contact with Inipol EAP22 and requested a material safety data sheet (MSDS) for the product. For your information, we have enclosed the material safety data sheet along with the EPA's Technical Product Bulletin #B-10.

According to the MSDS for Inipol EAP22, skin contact and inhalation are the primary routes of occupational exposure; it can be moderately toxic if absorbed through the skin, slightly toxic if inhaled, and can irritate the skin and eyes. High vapor concentrations may irritate the eyes and respiratory tract and may result in central nervous system (CNS) effects including headaches, dizziness, nausea, and drowsiness. Also, prolonged or repeated contact may remove natural oils from the skin, dry the skin, and cause irritation, redness, and rash.

Inipol EAP22, a biological additive, is manufactured by:

Société CECA S.A
12 place de l'Iris - Cedex 54
92062 Paris-la-Défense

A primary American distributor of Inipol EAP22 is:

Elf Atochem North America, Inc.
2000 Market Street, Suite 1900
Philadelphia, PA
Phone: (215) 419-5517



Thank you for your interest in occupational safety and health. We hope you find this information helpful. If you have any further questions, please feel free to contact the Tampa Area Office at (813) 636-1177, the Atlanta Regional Office at (404) 562-2300, or the [Office of Health Enforcement] at 202-693-2190.


Richard E. Fairfax, Director
[Directorate of Enforcement Programs]

[Corrected 6/2/2005]