Use of retardant mixed with non-potable water is outside of policy.

• The existing approval process addresses retardant mixed with potable water only.
  
  
• The range of quality of non-potable water is wide.
  
  
• Blanket statements are of questionable validity.
  
  

Health Impacts

• Currently approved retardants do not generally contain bactericides.
  
  
• Fertilizer salts are nutrient chemicals for many bacteria.
  • Health concerns for personnel mixing and loading the retardant.
  • Health concerns for firefighters on the fire line near the retardant drop.
  • Health concerns for general public who may be in the area-their property is threatened.

Environmental Concerns

• Possible introduction of bacterial contaminants into the environment.
  • Direct health concerns for wildlife under or near a retardant drop.
  • Impacts on vegetation.
  • Safety of animal consumption of vegetation coated in retardant.
  • Impacts of drops into waterways - beyond that of retardant caused problems.
  • Affects on animals/aquatic organisms feeding on/in contaminated waterways.
  • Amphibians may be especially sensitive to contamination of the environment.
  • Potential harm to T&E species.

Effectiveness Concerns

• Effectiveness may decrease if retardant salts are consumed by bacteria.
  
  
• The balance of phosphate to sulfate salts may change causing unpredictable effectiveness.

Stability Concerns

• Gums may be depleted, i.e. the retardants may lose the cohesive effects of the gum thickener..

Visibility Concerns

• Decreased viscosity will impact the visibility of the retardant because the higher viscosity holds colorant in suspension.
  
  
• Iron eating bacteria may cause decreased visibility as iron oxide colorant is consumed.

Corrosion Effects

• There are common bacteria that cause increased corrosion. Some of these are specialized to consume sulfates or thrive in a sulfate-rich atmosphere.
  
  
• Bacteria colonies can act as a patch, decreasing solution mobility and holding retardant in contact with a single portion of a tank. The chemistry in that micro-environment may be significantly different from the overall tank contents.