United
States
Prevention,
Pesticides
EPA
738­
R­
06­
028
Environmental
Protection
and
Toxic
Substances
July
2006
Agency
(
7508P)

Addendum
to
the
2002
Lindane
Reregistration
Eligibility
Decision
(
RED)
2
Addendum
to
the
2002
Lindane
Reregistration
Eligibility
Decision
(
RED)

Case
No.
315
Approved
by:

______________________
Debra
Edwards,
Ph.
D.
Director,
Special
Review
and
Reregistration
Division
________________________
Date
3
I.
Introduction
This
document
serves
as
an
addendum
to
the
July
2002
Lindane
Reregistration
Eligibility
Decision
document
(
2002
RED).
This
document
addresses
whether
pesticide
products
containing
the
active
ingredient
lindane
are
eligible
for
reregistration
under
the
Federal
Insecticide,
Fungicide,
and
Rodenticide
Act
(
FIFRA)
and
whether
existing
tolerances
for
residues
of
lindane
in
food
and
feed
are
safe
under
the
provisions
of
the
Federal
Food,
Drug
and
Cosmetic
Act
(
FFDCA).

This
RED
Addendum
reflects
the
Agency's
conclusions
on
the
remaining
lindane
seed
treatment
uses
in
light
of
the
information
gathered
since
the
2002
RED.
The
seed
treatment
use
is
a
source
of
human
exposure
to
lindane,
and
it
will
add
to
the
reservoir
of
lindane
already
present
in
the
environment.
EPA
believes
that
dietary
exposure
to
lindane
from
the
seed
treatment
use
may
pose
a
risk
to
nursing
infants
who
consume
breast
milk
contaminated
with
lindane.
EPA,
however,
is
not
able
to
quantify
that
risk
at
this
time
or
determine
whether
current
exposures
result
in
any
harm.
Lindane's
persistent
and
bioaccumulative
nature
is
also
of
concern
to
the
Agency.
In
addition,
the
Agency's
updated
analysis
of
the
seed
treatment
use
indicates
very
minor
benefits
to
growers.
In
light
of
these
factors,
EPA
now
concludes
that
the
six
lindane
seed
treatment
uses
are
ineligible
for
reregistration.

As
of
July
27,
2006,
the
Agency
had
received
requests
from
all
lindane
technical
and
end­
use
product
registrants
to
voluntarily
cancel
all
lindane
product
registrations.
Once
the
cancellation
process
is
complete,
EPA
will
propose
to
revoke
the
existing
lindane
fat
tolerances
pursuant
to
section
408(
l)(
2)
of
the
Food
Quality
Protection
Act
(
FQPA).

II.
Background
In
July
2002,
EPA
issued
a
RED
for
lindane
that
captured
the
Agency's
thencurrent
analysis
of
the
registered
uses
of
lindane
as
well
as
the
existing
tolerances.
The
2002
RED
concluded
in
part
that
existing
tolerances
for
lindane
were
no
longer
needed
as
the
uses
associated
with
those
tolerances
had
all
been
cancelled,
or
voluntary
cancellation
had
been
requested.
The
2002
RED
also
concluded
that
the
current
uses
of
lindane
for
seed
treatment
would
be
eligible
for
reregistration
under
FIFRA
provided
several
conditions
were
met.
First,
EPA
determined
that
a
number
of
changes
to
the
terms
and
conditions
of
registration
of
the
seed
treatment
products
were
necessary
to
prevent
"
unreasonable
adverse
effects
on
the
environment."
These
changes
are
specified
in
the
2002
RED.
Second,
EPA
determined
that
the
use
of
lindane
for
seed
treatment
was
likely
to
result
in
residues
in
raw
agricultural
commodities
derived
from
plants
grown
from
seeds
treated
with
lindane.
Therefore,
new
tolerances
for
the
existing
seed
treatment
uses
were
needed.
Third,
EPA
identified
additional
data
that
were
needed
to
characterize
lindane
metabolites
in
order
to
establish
appropriate
tolerances
for
lindane.
In
summary,
EPA
determined
that
the
currently
registered
lindane
seed
treatment
products
would
be
eligible
for
reregistration
if:
1)
the
registrants
amended
product
labels
to
reflect
the
terms
and
conditions
specified
in
the
2002
RED;
2)
the
registrants
provided
the
metabolism
4
data
set
forth
in
the
2002
RED;
and
3)
EPA
was
able
to
establish
all
required
tolerances
for
residues
of
lindane
in
food.

Following
the
2002
RED,
the
registrants
submitted
revised
labels
for
all
end­
use
products
reflecting
the
risk
mitigation
measures
specified
in
the
2002
RED.
The
Agency
has
reviewed
and
approved
these
labels.
The
registrants
also
submitted
the
required
product
and
residue
chemistry
data,
and
the
Agency
reviewed
these
data
and
found
them
to
be
acceptable.
To
satisfy
generic
data
requirements,
Crompton
(
now
Chemtura)
submitted
a
required
seed
leaching
study;
a
nature
of
the
residue
study,
also
known
as
a
plant
metabolism
study,
originally
required
in
the
1985
Lindane
Registration
Standard
Data
Call­
In
(
DCI);
and
an
anaerobic
aquatic
metabolism
study
to
satisfy
an
anaerobic
soil
metabolism
data
requirement
also
originally
required
under
the
1985
Lindane
Reregistration
Standard
DCI.

The
Agency
has
taken
a
number
of
actions
with
respect
to
lindane
since
the
2002
RED.
EPA
received
and
reviewed
a
number
of
comments
on
the
2002
RED.
EPA
also
revoked
all
current
tolerances
of
lindane,
except
for
fat
tolerances,
because
the
associated
uses
had
been
cancelled
(
70
FR
55282,
Sept.
21,
2005).
EPA
did
not
revoke
the
fat
tolerances
because
residue
data
suggested
that
livestock
that
were
fed
lindane­
treated
seeds
would
bear
residues
of
lindane
in
meat
commodities
(
i.
e.,
fat).
In
February
2006,
EPA
prepared
and
released
for
public
comment
a
document
titled
"
Assessment
of
Lindane
and
Other
Hexachlorocyclohexane
Isomers"
(
2006
Assessment).
This
assessment
provided
information
on
potential
health
effects
of
lindane
as
well
as
its
associated
isomers.

III.
Lindane's
toxicity
The
Agency's
conclusions
regarding
effects
of
lindane
in
humans
are
largely
based
on
studies
in
animals.
Lindane
primarily
affects
the
nervous
system.
In
acute,
subchronic,
and
developmental
neurotoxicity
studies
and
chronic
toxicity/
oncogenicity
studies,
lindane
was
found
to
cause
neurotoxic
effects.
Lindane
also
appears
to
cause
renal
and
hepatic
toxicity.
In
addition,
there
is
evidence
that
lindane
may
act
as
an
endocrine
disruptor.
Moreover,
infants
and
children
are
expected
to
be
more
susceptible
to
the
potential
adverse
effects
of
lindane
than
adults.
In
both
a
developmental
neurotoxicity
study
and
a
2­
generation
reproduction
study,
offspring
demonstrated
increased
susceptibility
to
lindane's
adverse
effects.
The
2002
RED
and
its
supporting
documents
provide
a
detailed
summary
of
lindane's
toxicity.

IV.
Sources
of
Lindane
Exposure
A.
Seed
Treatment
Use
The
seed
treatment
use
is
a
source
of
human
exposure
to
lindane.
There
are
several
possible
routes
by
which
this
exposure
may
occur.
First,
individuals
may
be
exposed
to
lindane
residues
when
eating
plants
grown
from
treated
seeds.
Residue
data
demonstrate
that
the
aerial
portion
of
a
growing
crop
will
uptake
lindane
residues
present
5
on
treated
seed
(
2002
RED,
pp.
44­
45).
Second,
consumption
of
meat
is
a
potential
source
of
lindane
exposure.
It
is
possible
that
livestock
feed
may
be
derived
from
grain
grown
from
lindane­
treated
seed.
EPA
expects
that
livestock
fed
lindane­
treated
seed
will
bear
residues
of
lindane
in
meat
commodities
(
i.
e.,
fat).
USDA
annual
pesticide
monitoring
data
show
one
detection
of
lindane
residues
in
milk
in
1998,
one
detection
in
the
fat
of
poultry
in
2000,
and
three
detections
(
one
from
imported
cows)
in
the
fat
of
livestock
(
e.
g.,
cows)
in
2001
and
2002
(
USDA
Pesticide
Data
Program).
In
addition,
the
USDA's
Food
Safety
and
Inspection
Service
(
FSIS)
detected
lindane
in
the
fat
of
domestic
and
imported
meat
products
in
1998,
1999
and
2000.
For
example,
in
2000,
four
imported
samples
(
three
calf
and
one
pig)
and
16
domestic
samples
(
cow,
sheep,
turkey,
goat,
veal)
contained
lindane.
EPA
acknowledges
these
detections
cannot
be
attributed
solely
to
treated
seeds.

Third,
treated
seeds
are
a
potential
source
of
lindane
in
drinking
water.
Modeling
also
shows
that
lindane
concentrations
in
both
surface
water
and
groundwater
may
reach
environmentally
significant
levels
(
greater
than
the
Maximum
Contaminant
Level
[
MCL]
of
0.2
ppb),
even
when
lindane
is
restricted
to
seed­
treatment
uses
only.
Even
considering
lindane's
very
low
use
rate
for
seed
treatment,
lindane
may
be
expected
to
reach
water
resources
at
environmentally
significant
levels
because
of
its
mobility
and
high
persistence.
Based
on
a
screening­
level
assessment,
lindane
from
seed
treatment
may
reach
water
resources
at
levels
above
the
MCL
of
0.02
ppb
(
U.
S.
EPA
2002
EFED
RED
Chapter
at
p.
3).
This
conclusion
is
based
solely
on
lindane's
use
as
a
seed
treatment
and
does
not
consider
past
uses
of
lindane
(
U.
S.
EPA
2002
EFED
RED
Chapter).
Water
monitoring
data,
to
be
discussed
in
Section
IV.
B.
i.
of
this
addendum,
show
that
residues
of
lindane
are
present
in
surface
water
in
the
United
States.

Exposure
to
lindane
may
also
occur
through
volatilization
from
treated
seeds.
Field
studies
from
Canada
report
an
increase
in
lindane
in
the
atmosphere
in
areas
where
lindane­
treated
seeds
are
used
(
2006
Assessment
at
p.
20).
Due
to
lindane's
persistence
and
mobility,
these
lindane
releases
may
contribute
to
human
exposure
via
any
route.

B.
Other
Sources
of
Exposure
In
addition
to
the
seed
treatment
use,
U.
S.
populations
may
be
currently
exposed
to
lindane
from
several
other
sources.

i.
Past/
historical
uses
Lindane
was
first
registered
in
the
U.
S.
in
the
1940s.
Since
that
time,
lindane
has
been
registered
for
use
on
a
wide
variety
of
fruit
and
vegetable
crops
(
including
seed
treatment),
ornamental
plants,
tobacco,
greenhouse
vegetables
and
ornamentals,
forests,
Christmas
tree
plantations,
log
dips,
livestock
dips,
household
sprays,
domestic
outdoor
and
indoor
use
by
homeowners
(
including
dog
dips,
household
sprays,
and
shelf
paper),
commercial
food
or
feed
storage
areas
and
containers,
wood
or
wooden
structures
sites,
and
human
skin/
clothing
(
a
military
use).
In
1977,
EPA
initiated
a
Rebuttable
Presumption
Against
Registration
(
RPAR)
review
of
lindane,
now
called
a
Special
6
Review,
that
resulted
in
the
cancellation
of
lindane
uses
in
smoke
fumigation
devices
for
indoor
domestic
use.
Following
the
RPAR,
EPA
issued
a
Registration
Standard
for
Lindane
in
September
1985
that
included
a
requirement
for
the
submission
of
additional
data
to
support
lindane
registration
and
to
address
exposure
concerns.
Between
1993
and
1998,
long­
range
transport
and
environmental
concerns
about
lindane
increased;
in
response
to
these
concerns,
lindane
registrants
voluntarily
cancelled
all
registered
uses
of
lindane
in
1998
and
1999,
except
for
seed
treatment
uses
on
19
agricultural
crops
and
a
dog
mange
treatment.
The
dog
mange
use
was
voluntarily
cancelled
in
December
2001.
Finally,
in
2001
and
2002,
the
registrants
voluntarily
cancelled
all
but
the
following
six
lindane
seed
treatment
uses:
barley,
corn,
oats,
rye,
sorghum,
and
wheat.
As
of
2002,
the
only
remaining
agricultural
uses
for
lindane
were
the
six
seed
treatment
uses
that
are
being
addressed
in
this
document.

Any
of
these
past
uses
potentially
result
in
continued
exposures
to
lindane
today
due
to
its
persistent,
bioaccumulative
nature
and
potential
for
long­
range
transport.
Indeed,
as
shown
below,
lindane
has
been
detected
in
a
variety
of
foods
as
well
as
surface
waters.
EPA
cannot
link
these
residue
detections
with
particular
uses
of
lindane.

The
Food
and
Drug
Administration's
Center
for
Food
Safety
and
Applied
Nutrition
(
CFSAN)'
s
Total
Diet
Study
summary
of
residues
from
1991
to
2001
indicates
that
many
food
items
contain
residues
of
lindane
(
http://
www.
cfsan.
fda.
gov/~
acrobat/
tds1byps.
pdf).
The
summary
shows
almost
50
types
of
food
items
in
which
lindane
has
been
detected
at
least
once
between
1991
and
2001.
The
food
items
with
the
most
detects
were
plain
milk
chocolate
candy
bars,
yellow
mustard,
and
commercial
chocolate
chip
cookies.
In
addition,
FDA's
pesticide
residue
monitoring
program
indicates
that,
between
1993
and
2003,
lindane
is
consistently
detected
in
2%
to
3%
of
foods
tested
(
http://
www.
cfsan.
fda.
gov/~
dms/
pesrpts.
html).

The
United
States
Geological
Survey
(
USGS)
National
Water
Quality
Assessment
program
(
NAWQA)
database
includes
373
surface­
water
samples
in
which
lindane
was
detected.
Four
of
these
samples
had
lindane
concentrations
of
0.1
ppb
or
greater,
with
a
maximum
concentration
of
0.219
ppb
detected
in
a
sample
from
the
agricultural
"
Harding
Drain"
in
Stanislaus
County,
California
in
February
2000.
The
samples
were
collected
between
1992
and
2004,
with
199
of
the
samples
with
detections
collected
in
1999
or
later.
The
USGS
classified
115
of
the
samples
with
detections
as
having
come
from
water
bodies
in
areas
of
agricultural
land
use,
101
from
water
bodies
in
mixed
land­
use
areas,
and
49
from
water
bodies
in
urban
land­
use
areas.
Eight
samples
were
classified
as
having
been
collected
from
areas
classified
as
"
other."

ii.
Imported
meats
Lindane
may
currently
be
used
in
other
countries
to
directly
treat
livestock
against
external
parasites.
Because
U.
S.
tolerances
currently
exist
for
lindane
in
livestock
fat,
livestock
or
meat
products
that
have
been
treated
with
lindane
and
containing
lindane
residues
can
be
legally
imported
into
the
United
States.
Approximately
8
percent
of
red
7
meat
and
5
percent
of
animal
fat
consumed
by
the
U.
S.
population
is
imported,
and
red
meat
is
among
the
fastest
growing
U.
S.
imports
(
Jerardo
2003).

iii.
Subsistence
diets
Indigenous
populations
are
exposed
to
lindane
via
consumption
of
subsistence
diets.
As
noted
in
the
2006
Assessment,
indigenous
populations
rely
heavily
on
animal
fats
and
protein
in
their
subsistence
diets.
For
example,
EPA
reported
high
harvest
amounts
of
walrus,
seal
and
whale
for
Alaska
communities.
Residues
of
lindane
and
other
HCH
isomers
are
present
in
these
animals
even
though
they
are
not
in
areas
where
lindane
is
manufactured
or
used.
As
explained
in
Section
V
of
this
addendum,
lindane
and
other
HCH
isomers
are
mobile
once
released
into
the
environment
and
can
be
transported
long
distances.
Lindane
and
other
HCH
isomers
tend
to
accumulate
in
colder
climates,
such
as
the
arctic,
and
concentrate
in
the
food
chain.
Thus
any
manufacture
or
use
of
lindane,
or
other
HCH
isomers,
is
a
potential
source
of
exposure
to
indigenous
populations
(
2006
Assessment
at
pp.
26,
44­
45).

iv.
Pharmaceutical
use
Lindane
is
also
used
as
a
treatment
for
lice
and
scabies.
Individuals
who
use
lindane
pharmaceutical
products
will
be
exposed
to
lindane
in
amounts
that
will
exceed
exposure
from
the
seed
treatment
use.
The
pharmaceutical
use,
though,
is
also
a
source
of
exposure
to
the
general
population.
EPA
believes
that
lindane
from
the
pharmaceutical
use
may
reach
drinking
water
via
"
down
the
drain"
release;
that
is,
lindane
enters
drinking
water
when
individuals
using
the
pharmaceutical
products
wash
off
their
hands/
bodies.
Based
on
information
from
Los
Angeles
County,
California,
EPA
estimated
average
effluent
concentrations
of
lindane
discharged
from
publicly
owned
treatment
works
to
be
0.03
ppb
(
2002
RED
at
p.
23).
In
fact,
California
banned
the
pharmaceutical
uses
of
lindane
due
to
concerns
about
water
contamination
and
acute
neurotoxicity
concerns
from
direct
application.
Although
FDA
has
recommended
that
lindane
be
prescribed
as
a
second
line
treatment
since
1995,
these
products
remain
a
source
of
exposure.

v.
Use
in
foreign
countries
As
far
as
EPA
is
aware,
lindane
is
still
being
used
in
a
few
other
countries.
For
example,
EPA
believes
that
lindane
is
still
used
in
India.
In
addition,
lindane
is
registered
for
use
in
Bolivia,
Burkina
Faso,
Cameroon,
Cape
Verde,
Chad,
Kenya,
Malaysia,
Mali,
Mauritania,
Mexico,
1
Papua
New
Guinea,
Syria,
Tanzania,
Togo,
and
Zimbabwe
(
Lindane
NARAP
Annex
B).
Because
of
lindane's
persistence
and
potential
for
long
range
transport,
EPA
believes
that
releases
of
lindane
in
these
other
countries
could
result
in
exposures
in
the
United
States.
Bailey
et
al.
(
2000)
demonstrated
that
organochlorine
pesticides
including
lindane
can
travel
from
eastern
Asia
to
North
America
in
as
little
as
five
days.

1
Mexico,
however,
has
stated
that
it
intends
to
phase
out
all
uses
of
lindane.
8
V.
Environmental
Fate
Lindane
is
a
persistent
organochlorine
compound
that
is
widely
distributed
in
the
environment
with
a
long
half­
life
in
various
environmental
compartments.
The
presence
of
lindane
and
other
HCH
isomers
(
namely
 ­
and
 ­
HCH)
in
the
environment
and
human
and
wildlife
tissues,
as
well
as
the
environmental
fate
and
exposure
routes
of
lindane,
have
been
documented
in
detail
in
scientific
literature
as
well
as
in
the
Agency's
2002
RED
and
2006
Assessment.
The
fate
characteristics
of
lindane,
including
persistence,
bioaccumulative
potential,
and
potential
for
long­
range
transport,
are
the
key
elements
to
understanding
the
extent
and
scope
of
exposures
associated
with
the
use
of
lindane.
Lindane's
toxicity
in
association
with
these
fate
characteristics
results
in
risks
of
concern
for
the
Agency.
Below
is
a
summary
of
these
concerns.

Based
on
the
submitted
environmental
fate
data,
physical
and
chemical
properties,
lindane
is
a
persistent,
moderately
mobile,
and
relatively
volatile
compound.
Selected
physical­
chemical
properties
of
lindane
are
summarized
in
Table
1.
Lindane
can
migrate
over
a
long
distance
through
various
environmental
media
such
as
air,
water
and
sediment.
Due
to
the
persistent
nature
and
long­
range
transport,
lindane
has
been
detected
in
air,
surface
water,
groundwater,
sediment,
soil,
ice,
snowpack,
fish,
wildlife
and
humans.
The
source
of
these
lindane
detections
is
unclear;
but
it
may
be
the
result
of
a
combination
of
past
widespread
use
in
the
U.
S.
and
other
countries,
lindane's
extreme
persistence,
current
seed
treatment
use,
current
use
in
foreign
countries,
and
use
as
a
pharmaceutical.

Table
1.
Fate
and
Physical­
Chemical
Properties
of
Lindane
Parameter
Value
Molecular
Weight
290.82
Solubility
(
25
oC)
7
mg/
L
Vapor
Pressure
(
25
oC)
9.4
x
10­
6
torr
Henry's
Law
Constant
(
atm­
m3/
mol)
3.5
x
10­
6
@
25
°
C
Hydrolysis
Half­
life
(
pH
5,
7,
9;
25
oC)
Stable,
stable,
43­
53
days
Aqueous
Photolysis
Half­
lives
(
pH
5)
Stable
Soil
Photolysis
Half­
life
Stable
Aerobic
Soil
Metabolism
Half­
lives
980
days
Organic
Carbon
Partition
Coefficients
(
Koc)
1368
mL/
g
(
mean
of
4
soils)

Octanol
 
Water
Partition
Coefficient
(
log
Kow)
3.78
Bioconcentration
Factors
(
BCF)
In
fish
bluegill
sunfish,
780
(
fillet),
2500
(
viscera),
1400
(
whole
fish
tissues)
9
A.
Persistence
Once
released
into
the
environment,
the
primary
process
by
which
lindane
dissipates
is
volatilization
into
the
air,
although
abiotic
and
biotic
degradation
as
well
as
uptake
by
crops
can
also
occur.
However,
lindane
is
resistant
to
abiotic
processes
like
photolysis
and
hydrolysis
(
except
at
high
pH),
and
degrades
very
slowly
by
microbial
actions.
The
hydrolysis
half­
lives
of
lindane
were
reported
to
be
stable
at
pH
5
and
pH
7,
and
 
43
days
at
pH
9
(
U.
S.
EPA
2002
EFED
RED
Chapter).
Since
lindane
does
not
contain
chromophores
that
absorb
light
>
290
nm,
direct
photolysis
is
not
expected
to
occur.
In
an
aerobic
soil
metabolism
study,
lindane
degraded
very
slowly,
with
a
calculated
half­
life
of
980
days
(
U.
S.
EPA
2002
EFED
RED
Chapter).
Since
most
degradation
pathways
occur
slowly,
the
presence
of
degradates
is
generally
low.
Possible
lindane
degradates
could
include
pentachlorocyclohexene,
1,2,4,­
trichlorobenzene,
and
1,2,3­
trichlorobenzene
(
U.
S.
EPA
2002
EFED
RED
Chapter).

Additional
evidence
of
its
persistence
is
the
fact
that
lindane
has
been
found
at
numerous
hazardous
waste
sites
which
have
been
abandoned.
Of
the
1,662
current
or
former
industrial
sites
on
the
National
Priorities
List,
lindane
was
found
in
189
(
ATSDR
1997
at
p.
1).

B.
Bioaccumulation
and
Bioconcentration
Lindane
can
bio­
accumulate
easily
in
the
food
chain
due
to
its
high
lipid
solubility
and
can
bioconcentrate
rapidly
in
microorganisms,
invertebrates,
fish,
birds
and
mammals
(
WHO
1991).
The
octanol­
water
partition
coefficient
(
log
Kow
=
3.78,
Table
1)
for
lindane
indicates
that
it
has
the
potential
to
bioaccumulate.
Lindane
has
potential
to
enrich
in
lipid­
containing
biological
compartments.
However,
lindane
is
a
multimedia
chemical,
existing
and
exchanging
among
different
compartments
of
the
environment
such
as
the
atmosphere,
surface
water,
soil
and
sediment.
In
addition,
temperature,
humidity,
and
other
environmental
properties
may
have
significant
influence
on
environmental
degradation
rates.
These
properties
likely
affect
the
presence
of
lindane
in
the
environment
as
well
as
the
variability
in
the
bioaccumulation,
bioconcentration
and
biomagnification
in
the
various
biological
compartments.
Differences
in
accumulation
are
also
likely
due
to
different
modes
of
uptake,
metabolism
and
sources
of
contamination.

The
estimated
bio­
concentration
factors
(
BCF)
of
lindane
were
780x
in
fillet,
2500x
in
viscera
and
1400x
in
whole
fish
(
U.
S.
EPA
2002
EFED
RED
Chapter).
Although
lindane
may
bioconcentrate
rapidly,
most
data
suggest
that
bio­
transformation,
depuration
and
elimination
are
relatively
rapid
once
exposure
is
eliminated.
After
14
days
of
depuration,
lindane
levels
were
reduced
by
96%
in
fillet,
95%
in
viscera,
and
85%
in
whole
fish.
10
C.
Transport
and
Mobility
Lindane
has
often
been
detected
in
ambient
air,
precipitation,
and
surface
water
throughout
North
America,
and
it
has
also
been
detected
in
areas
of
non­
use
(
e.
g.,
the
Arctic),
indicating
long­
range
transport
of
lindane
occurs.
The
source
of
these
lindane
detections
is
unclear,
but
may
be
the
result
of
a
combination
of
manufacture
(
i.
e.,
release
during
manufacture,
disposal
of
HCH
isomers),
past
widespread
use
in
the
U.
S.
and
other
countries,
its
extreme
persistence,
current
seed
treatment
use,
current
use
in
foreign
countries,
and
the
pharmaceutical
use
of
lindane.
Once
released
into
the
environment,
lindane
can
partition
into
various
environmental
media.
Lindane
present
in
soil
can
leach
to
groundwater,
sorb
to
soil
particulates
and
transport
to
surface
water
via
runoff,
or
volatilize
to
the
atmosphere.
However,
the
Henry's
law
constant
(
Table
1)
of
lindane
suggests
that
volatilization
is
the
most
important
route
of
dissipation
from
water
and
moist
soils
followed
by
aerial
long­
range
transport.
Adsorption
of
HCH
isomers
to
soil
and
sediments
is
generally
a
preferential
partitioning
process
after
volatilization.
Leaching
of
HCH
isomers
through
soil
is
governed
by
their
water
solubility
and
their
propensity
to
bind
to
soil.
The
calculated
Koc
of
lindane
ranges
from
942
to
1798
mL/
g,
with
a
mean
of
1368
mL/
g
for
four
soils
tested
(
U.
S.
EPA
2002
EFED
RED
Chapter).
These
data
suggest
that
lindane
has
low
leaching
potential.
Data
also
indicate
that
lindane
is
expected
to
adsorb
to
suspended
solids
and
sediment
in
water.
Based
on
the
results
of
a
number
of
laboratory
soil
column
leaching
studies
that
used
soils
of
both
high
and
low
organic
carbon
content
as
well
as
municipal
refuse,
lindane
has
low
subsurface
mobility
in
soils
(
Melancon
et
al.
1986,
Reinhart
et
al.
1991).

D.
Volatility
and
Long­
Range
Transport
The
behavior
of
lindane
in
the
environment
is
complex
because
it
is
a
multimedia
chemical,
existing
and
exchanging
among
different
compartments
of
the
environment
such
as
the
atmosphere,
surface
water,
soil
and
sediment.
Volatilization
from
soil
and
surface
waters
is
a
major
dissipation
route
for
lindane.
The
Henry's
law
constant
for
lindane
suggests
that
it
will
volatilize
from
moist
soil
and
surface
water
into
the
air,
although
microbial
and
chemical
degradation
and
uptake
by
crops
can
also
occur
(
Walker
et
al.
1999).
Lindane
can
also
enter
the
air
as
adsorbed
phase
onto
suspended
particulate
matter,
but
this
process
does
not
appear
to
be
a
major
contributor
like
volatilization
(
Walker
et
al.
1999
and
Bidleman
2004).
Brubaker
and
Hites
(
1998)
measured
the
gas
phase
kinetics
of
the
hydroxyl
radical
with
lindane,
and
reported
that
it
has
long
atmospheric
half­
lives
in
air
and,
therefore,
can
be
transported
long
distance.

Once
airborne,
lindane
may
move
into
the
upper
troposphere
for
more
widespread
regional
and
possibly
transcontinental
distribution
as
a
result
of
large­
scale
vertical
perturbations
that
facilitate
air
mass
movement
out
of
the
near
surface.
Also,
it
may
reversibly
deposit
on
terrestrial
surfaces
close
to
the
source
and
still
be
transported
over
large
distances,
even
global
scales,
through
successive
cycles
of
deposition
and
reemission
as
result
of
ambient
temperature
and
latitude
differences
known
as
"
global
distillation
or
fractionation"
(
Wania
and
Mackay
1996
as
cited
in
U.
S.
EPA
2002
EFED
RED
Chapter
at
pp
9­
10).
Recently,
soil
and
air
samples
were
collected
for
11
organochlorine
pesticides
in
northwest
Alabama
to
estimate
soil­
to­
air
fluxes
and
their
contribution
to
the
atmospheric
concentration
(
Harner
et
al.
2001).
The
researchers
concluded
that
the
atmospheric
concentration
of
lindane
in
northwest
Alabama
may
be
due
to
atmospheric
advections
or
regional
sources
rather
than
the
studied
soils.
A
field
study
conducted
by
Waite
et
al.
(
2001)
in
Saskatchewan,
Canada
demonstrated
volatilization
of
lindane
from
fields
planted
with
lindane­
treated
canola
seed.
Waite
reported
that
significant
quantities
(
12­
30%)
of
applied
lindane
volatilize
from
treated
canola
seed
to
the
atmosphere
during
the
growing
seasons
and
have
direct
implications
on
regional
atmospheric
concentrations
of
lindane.
The
study
also
estimated
that
a
range
of
66.4
to
188.8
tons
of
atmospheric
load
of
lindane
occurred
during
1997
and
1998,
following
the
planting
of
canola
in
the
region
of
the
Canadian­
prairies.
Poissant
and
Koprivnjak
(
1996)
reported
that
90%
of
elevated
lindane
concentration
in
the
atmosphere
at
Villeroy,
Quebec
in
1992
was
from
secondary
emissions
of
applied
lindane­
treated
corn,
while
the
rest
was
from
the
volatilization
of
residual
lindane
from
the
previous
year
seed
treatment
(
U.
S.
EPA
2002
EFED
RED
Chapter
at
pp.
8­
9).

Recently,
seasonal
air
concentrations
of
lindane
and
other
HCH
isomers
were
monitored
using
Passive
Air
Samplers
(
PAS)
along
an
urban
to
rural
transect
in
Toronto,
Canada
(
Motelay­
Massei
et
al.
2005).
The
air
concentrations
of
lindane
were
159
pg/
M3
to
1020
pg/
M3
in
the
rural
sites
during
the
spring­
summer
monitoring
period.
A
similar
trend
of
air
concentrations
of
lindane
was
also
observed
by
Hoff
et
al.
(
1992)
in
Ontario,
Canada.
Both
studies
concluded
that
the
continuing
use
of
lindane
during
spring
is
likely
associated
with
higher
concentration
of
lindane
in
the
air
samples.
Analysis
of
1990
to
2001
data
from
the
Integrated
Atmospheric
Deposition
Network
(
IADN)
also
confirmed
that
annual
agricultural
application
was
a
key
variable
in
explaining
the
annual
cycle
of
atmospheric
lindane
concentrations
(
Buehler
et
al.
2004).
Jianmin
et
al.
(
2003)
modeled
lindane
transport
and
deposition
to
the
Great
Lakes
from
usage
areas
in
the
Canada
prairies
and
corn­
belt
regions
of
southern
Ontario
and
Quebec.
Results
showed
that
lindane
transport
to
the
Great
Lakes
during
spring­
summer
came
mainly
from
application
sites
in
the
prairies,
with
minor
contribution
from
the
corn­
belt.
They
compared
the
modeled
concentration
with
the
monitoring
data
of
the
IADN
sites,
which
were
within
50­
134%
of
those
measured
during
summer,
16­
51%
in
fall
and
3­
20%
in
winter.

E.
Surface
Water,
Sediments
and
Groundwater
Lindane
is
moderately
mobile
and
can
migrate
over
a
long
distance
through
various
environmental
media
like
water
and
sediment.
Adsorption
of
lindane
to
soil
and
sediments
is
generally
a
preferential
partitioning
process
after
volatilization.
The
calculated
Koc
of
lindane
ranges
from
942
to
1798
mL/
g,
with
a
mean
of
1368
mL/
g
for
four
soils
tested
(
U.
S.
EPA
2002
EFED
RED
Chapter).
These
data
suggest
that
lindane
has
low
leaching
potential.
Data
also
indicate
that
lindane
is
expected
to
adsorb
to
suspended
solids
and
sediment
in
water.
Lindane
reaches
water
resources
via
surface
runoff
and
through
rain
and
snow
deposition
(
ATSDR
1997
at
p.
190
citing
Tanabe
et
al.
1982;
Wheatley
and
Hardman
1965).
"
For
example,
Lake
Ontario
received
<
2
kg/
year
of
 ­
HCH
because
of
suspended
sediment
loading
from
the
Niagara
River
between
1979
and
1981"
(
ATSDR
1997
at
p.
190
citing
Kuntz
and
Warry
1983).
Studies
also
show
that
the
12
Great
Lakes
received
3.7
to
15.9
metric
tons/
year
of
lindane
through
atmospheric
deposition
(
ATSDR
1997
at
p.
190
citing
Eisenreich
et
al.
1981).
Lindane
has
also
been
detected
in
stormwater
runoff
in
Denver,
Colorado
and
Washington,
D.
C.
(
0.052 
0.1
µ
g/
L)
(
ATSDR
1997
at
p.
190
citing
Cole
et
al.
1984).

VI.
Dietary
Risk
A.
Presence
of
Lindane
in
Breast
Milk
Although
there
currently
are
no
programs
in
the
United
States
for
monitoring
lindane
levels
in
human
breast
milk,
EPA
believes
that
lindane
is
present
in
the
breast
milk
of
at
least
some
nursing
mothers
in
the
United
States.
In
general,
lindane
is
very
persistent
and
highly
soluble
in
fat
or
fatty
tissue.
Therefore,
it
has
the
potential
to
bioaccumulate
in
the
food
chain
and
bioconcentrate
in
microorganisms,
invertebrates,
fish,
birds,
and
mammals.
In
practical
terms,
this
means
that
when
women
are
exposed
to
lindane
through
food,
water,
or
the
atmosphere,
they
will
accumulate
lindane
residues
in
their
fatty
tissue,
including
breast
milk
and
breast
milk
fat,
and
that
these
lindane
residues
will
remain
there
for
an
undetermined
amount
of
time.
2
Thus,
to
the
extent
women
in
the
United
States
are
exposed
to
lindane,
EPA
believes
that
that
lindane
likely
will
accumulate
in
their
breast
milk
or
breast
milk
fat.

Moreover,
in
the
1970s
and
1980s,
lindane
was
detected
in
breast
milk
in
women
in
Binghamton,
New
York;
Saint
Louis,
Missouri;
several
places
in
Mississippi,
and
in
Philadelphia,
Pennsylvania.
Lindane
also
has
been
detected
in
breast
milk
of
women
in
Argentina,
Australia,
Austria,
Belgium,
Bulgaria,
Canada,
the
former
Czechoslovakia,
Denmark,
the
former
Federal
Republic
of
Germany
(
FRG),
Greece,
Finland,
France,
Hungary,
India,
Iran,
Iraq,
Ireland,
Israel,
Italy,
Japan,
Luxembourg,
Mexico,
Netherlands,
Nigeria,
Norway,
Poland,
Rwanda,
Spain,
Sweden,
Switzerland,
Taiwan,
Thailand,
Tunisia,
Turkey,
the
United
Kingdom,
Vietnam,
Yugoslavia,
and
Zaire
(
Jensen
1991).
Several
of
these
countries,
like
Canada,
have
had
production
and
use
patterns
similar
to
those
in
the
United
States.
Given
the
U.
S.
and
world­
wide
presence
of
lindane
in
breast
milk,
EPA
expects
that,
if
U.
S.
monitoring
programs
existed,
lindane
would
be
detected
in
breast
milk
in
other
U.
S.
locales
as
well.

B.
Lindane
from
Treated
Seed
Could
Contribute
to
Breast
Milk
Contamination
EPA
believes
that
lindane
from
the
treated
seed
use
could
contribute
to
levels
of
lindane
in
breast
milk.
As
discussed
earlier,
there
are
several
routes
by
which
women
in
the
United
States
could
be
exposed
to
lindane
from
treated
seed.
These
include:
(
1)
eating
food
grown
from
treated
seed;
(
2)
eating
the
meat
of
animals
fed
with
feed
grown
2
Several
studies
suggest,
however,
that
once
exposure
stops,
certain
species
may
be
able
to
eliminate
lindane
from
their
systems.
EPA,
however,
cannot
determine
how
quickly
or
slowly
lindane
may
be
eliminated
from
the
human
body.
In
comments,
NRDC
states
that
lindane
is
converted
in
to
beta­
HCH
in
the
body
(
EPA
NRDC
Comments
at
p.
1).
NRDC
provides
no
support
for
this
statement
and
EPA
has
found
nothing
independently
to
confirm
or
refute
this
statement.
Beta­
HCH
accumulates
to
a
greater
extent
than
lindane
and
cannot
be
as
efficiently
eliminated
(
EPA
2006
Assessment
at
p.
19).
13
from
treated
seed;
(
3)
consuming
drinking
water
contaminated
with
lindane
from
the
seed
treatment
use;
and
(
4)
being
exposed
to
lindane
that
volatilizes
from
the
seed
treatment
use.
EPA
believes
that
all
of
these
are
potential
routes
of
exposure.

C.
Infant
Exposure
to
Lindane
from
Breast
Milk
and
Resulting
Risk
Infants
will
be
exposed
to
lindane
if
they
are
fed
contaminated
breast
milk.
Indeed,
for
women,
lactation
is
the
most
important
route
of
elimination
for
persistent
contaminants
such
as
lindane
(
Jensen
1991
at
p.
10).
EPA
is
not
able
to
conduct
a
scientifically
quantitative
assessment
of
the
risks
associated
with
exposure
to
lindane
in
breast
milk
due
to
the
uncertainties
regarding
current
monitoring
data
and
the
lack
of
a
validated
method
for
quantifying
the
infant
exposure.
In
general,
concentrations
of
manmade
chemicals
in
human
milk
often
are
more
than
ten
times
higher
than
in
cow's
milk
from
the
same
area.
Frequently,
limit
values
established
for
contaminants
in
cow's
milk
are
exceeded
in
human
milk.
Newborns
and
infants,
whose
main
foodstuff
is
breast
milk,
may
have
a
higher
relative
daily
intake
of
these
pollutants
than
adults
(
Jensen
1996).

As
far
as
EPA
is
aware,
there
have
been
no
overt
illnesses
in
infants
from
exposure
to
lindane
in
breast
milk.
In
addition,
breast
milk
is
the
natural
and
superior
foodstuff
for
newborns,
and
infants,
and
nursing
provides
important
immunological
and
psychological
benefits.
Moreover,
virtually
all
national
and
international
experts
agree
that
women
should
not
forgo
breast
feeding
even
though
breast
milk
may
be
contaminated
with
low
levels
of
lindane,
other
organochlorine
pesticides,
and
persistent
industrial
chemicals
like
PCBs
(
Jensen
1991
at
p.
288).

Nevertheless,
there
is
a
dearth
of
long­
term
studies
of
the
effects
of
infant
exposure
to
lindane
in
breast
milk.
Thus,
the
potential
long­
term
effects
of
newborn
and
infant
exposure
to
lindane
in
breast
milk
are
difficult
to
assess.
EPA
is
currently
unable
to
determine
whether
there
are
in
fact
adverse
effects
from
exposure
of
infants
to
lindane
in
breast
milk.
However,
EPA
believes
that,
because
of
lindane's
prior
detections
in
breast
milk,
its
physio­
chemical
properties,
and
its
continued
presence
in
the
diet,
the
potential
for
adverse
effects
to
infants
from
consumption
of
breast
milk
cannot
be
dismissed
due
to
a
lack
of
data.

VII.
Impact
on
Growers
Lindane
is
registered
in
the
U.
S.
as
a
seed
treatment
use
on
wheat,
barley,
oats,
rye,
corn,
and
sorghum.
An
application
to
register
lindane
for
use
as
a
seed
treatment
for
canola
is
pending
before
the
Agency.
In
support
of
the
2002
RED,
EPA
assessed
the
potential
impacts
on
growers
of
cancellation
of
the
lindane
seed
treatment
uses
(
U.
S.
EPA
2002
BEAD
Analysis).
At
the
time
of
the
2002
RED,
there
were
registered
alternatives
for
all
lindane
seed
treatment
uses
except
oats
and
rye.
Imidacloprid
and
thiamethoxam
were
identified
as
the
primary
seed
treatment
alternatives
to
lindane
(
U.
S.
EPA
2002
BEAD
Analysis
at
p.
1).
14
For
the
wheat,
barley,
corn,
and
sorghum
seed
treatment
uses,
grower­
level
effects
of
cancellation
of
lindane
were
expected
to
be
minor.
For
these
uses,
EPA
estimated
an
increased
treatment
cost
to
growers
using
lindane
ranging
from
0.3%
of
gross
revenue
to
4.4%
of
gross
revenue.
In
some
cases,
these
increased
treatment
costs
would
be
offset
by
the
effectiveness
of
alternatives
on
other
pests.
For
example,
for
sorghum,
EPA
estimated
increased
treatment
costs
to
growers
using
lindane
of
3.5­
4.4%
of
gross
revenue.
However,
the
Agency
found
that
this
increase
would
likely
be
offset
by
increased
yields
due
to
control
of
chinch
bugs
and
aphids
(
U.
S.
EPA
2002
BEAD
Analysis
at
p.
9).
Overall,
for
uses
for
which
alternatives
are
registered,
EPA
concluded
the
impact
of
cancellation
of
lindane
to
individual
growers
using
lindane
would
be
minor.
Further,
the
Agency
estimated
that
only
6%
to
7%
of
total
acres
of
wheat,
barley,
and
corn
planted
and
only
1%
of
total
acres
of
sorghum
planted
were
being
treated
with
lindane.

At
the
time
of
the
2002
RED,
no
alternatives
were
registered
for
oats
and
rye.
EPA
estimated
cancellation
of
the
lindane
seed
treatment
use
could
result
in
a
9%
yield
loss
to
growers
using
lindane;
however,
the
Agency
estimated
that
only
1%
of
total
acres
of
oats
and
rye
planted
were
being
treated
with
lindane.
For
the
growers
affected,
this
crop
loss
would
be
partially
offset
by
a
lower
treatment
cost,
but
the
Agency
concluded
that
cancellation
of
the
lindane
seed
treatment
for
oats
and
rye
would
have
a
major
effect
on
individual
growers
using
lindane
(
U.
S.
EPA
2002
BEAD
Analysis
at
pp.
3­
4).

Since
the
time
of
the
2002
RED,
additional
alternatives
to
the
lindane
seed
treatment
uses
have
been
registered.
Most
notably,
imidicloprid
is
now
registered
as
a
seed
treatment
use
for
oats
and
rye.
Thus,
there
are
now
alternatives
for
all
lindane
seed
treatment
uses.
The
registration
of
imidicloprid
for
oats
and
rye
significantly
alters
the
Agency's
2002
assessment
of
grower­
level
impacts.
A
9%
yield
loss
to
growers
using
lindane
would
no
longer
be
expected
if
lindane
were
cancelled,
though
growers
switching
to
imidicloprid
would
experience
increased
treatment
costs
of
0.52­
1.7%
of
net
revenues.
The
Agency
considers
this
to
be
a
minor
effect
(
U.
S.
EPA
2005
BEAD
Update).
For
all
uses,
the
Agency
expects
an
average
increase
in
treatment
cost
of
0.29%
of
net
revenues.

In
addition,
it
appears
that
use
of
lindane­
treated
seeds
is
declining.
In
2002,
EPA
estimated
that
approximately
4.8
million
acres
of
corn
crops
were
grown
from
lindanetreated
seed
(
7
percent
of
the
total
corn
acreage).
This
translated
to
approximately
52,000
pounds
of
lindane
used
for
corn
seed
treatment.
Updated
information
shows
a
substantial
reduction
in
these
figures.
For
2004­
2005,
EPA
estimates
that
less
than
three
million
acres
of
corn
crops
were
grown
from
lindane­
treated
seed
(
less
than
4
percent
of
the
total
corn
acreage).
This
amounts
to
less
than
30,000
pounds
of
lindane
used
for
corn
seed
treatment.
These
revised
figures
suggest
that
use
of
lindane
to
treat
corn
seeds
has
declined
by
greater
than
40
percent.

The
Agency
has
received
reports
that
some
farmers
using
treated
seeds
will
opt
for
lindane­
treated
seeds
because
lindane­
treated
seeds
appear
to
repel
sandhill
cranes
from
corn
crops.
Two
studies
have
estimated
that
sandhill
cranes
will
damage
20
percent
of
corn
crops
grown
near
wetlands.
It
appears
that
this
use
is
most
common
in
15
Wisconsin.
EPA
has
no
information
indicating
how
much
the
potential
20
percent
crop
damage
would
be
prevented
by
the
use
of
lindane­
treated
seeds.
As
a
result,
the
Agency
is
unable
to
quantify
any
resulting
benefit
from
using
lindane­
treated
seeds
in
this
manner.
Due
to
reduced
availability
of
lindane­
treated
seeds,
Wisconsin
has
submitted
a
FIFRA
§
18
emergency
exemption
request
to
use
anthraquinone
to
control
sandhill
crane
damage.
EPA
granted
Wisconsin's
FIFRA
§
18
emergency
exemption
request
and
believes
anthraquinone
is
an
alternative
for
protecting
crops
from
sandhill
cranes.

VIII.
Regulatory
Determination
Pursuant
to
FIFRA,
EPA
must
determine,
after
submission
of
relevant
data,
whether
pesticide
active
ingredients
are
eligible
for
reregistration.
(
FIFRA
§
4(
g)(
2)(
A).)
In
order
to
be
reregistered,
EPA
must
find
that
an
active
ingredient
meets
the
standard
in
section
3(
c)(
5)
of
FIFRA.
(
See
FIFRA
§
4(
a)(
2).)
This
requires
EPA
to
examine,
in
part,
whether
a
pesticide
causes
unreasonable
adverse
effects
on
the
environment.
Pursuant
to
section
2(
bb)
of
FIFRA,
"
unreasonable
adverse
effects
on
the
environment"
is
defined,
in
part,
as
"
any
unreasonable
risk
to
man
or
the
environment,
taking
into
account
the
economic,
social,
and
environmental
costs
and
benefits
of
the
use
of
any
pesticide."
In
other
words,
to
determine
whether
a
pesticide
causes
unreasonable
adverse
effects
on
the
environment,
EPA
must
examine
broadly
the
costs
and
benefits
of
the
pesticide's
use,
including
economic,
social
and
environmental
costs
and
benefits.

Based
on
new
information
the
Agency
received
since
the
2002
RED,
and
the
review
of
existing
information,
EPA
has
determined
that
the
seed
treatment
uses
of
lindane
are
ineligible
for
reregistration
under
FIFRA
because
the
current
risks
outweigh
the
benefits
of
the
use
of
the
pesticide.
As
of
July
27,
2006,
the
Agency
had
received
requests
from
all
lindane
technical
and
end­
use
product
registrants
to
voluntarily
cancel
all
lindane
product
registrations.
Once
the
cancellation
process
is
complete,
EPA
will
propose
to
revoke
the
existing
lindane
fat
tolerances
pursuant
to
section
408(
l)(
2)
of
FQPA.

EPA
believes
the
costs
and
benefits
associated
with
the
seed
treatment
use
have
changed
significantly
since
the
2002
RED.
At
the
time
of
the
2002
RED,
there
were
no
alternatives
to
the
seed
treatment
use
for
oats
and
rye
for
control
of
wireworm.
EPA
estimated
that
without
the
availability
of
lindane­
treated
seeds,
untreated
plots
might
suffer
as
much
as
a
9%
yield
loss.
The
Agency
considered
this
to
be
a
major
impact
on
growers
who
used
lindane
treatment
for
these
crops.
However,
this
was
the
only
major
impact
on
growers.
For
all
other
lindane
seed
treatment
uses,
alternatives
existed
and
grower
impacts
were
expected
to
be
minor.

In
March
2006,
EPA
registered
imidicloprid
as
a
seed
treatment
use
on
oats
and
rye
for
wireworm
control.
The
Agency
believes
imidicloprid
is
as
effective
as
lindane
for
control
of
wireworm.
With
the
availability
of
imidicloprid,
EPA
no
longer
expects
a
yield
loss
in
the
absence
of
lindane.
Growers
are
expected
to
see
increased
treatment
costs
of
0.52­
1.7%
of
net
revenues
with
use
of
imidicloprid.
The
Agency
considers
this
to
be
a
minor
impact.
In
addition,
at
least
with
respect
to
corn,
use
of
lindane­
treated
16
seeds
has
dropped
by
over
40
percent,
from
approximately
4.8
million
acres
to
less
than
3
million
acres
(
less
than
4
percent
of
total
corn
acreage).

Overall,
the
benefits
of
the
lindane
seed
treatment
uses
are
now
negligible.
For
all
uses,
if
lindane
were
cancelled,
the
Agency
would
expect
to
see
average
treatment
costs
increase
by
$
1.82
per
acre.
This
is
equal
to
0.29%
of
net
revenues.
For
some
crops,
the
increased
treatment
costs
may
be
partially
offset
by
better
control
of
certain
pests.
In
sum,
the
benefits
of
the
lindane
seed
treatment
use
to
growers
are
very
minor,
and
cancellation
of
the
lindane
seed
treatment
uses
is
not
expected
to
have
an
appreciable
impact
on
growers.

Under
FIFRA,
EPA
must
balance
the
benefits
of
the
lindane
seed
treatment
use
against
the
human
health,
environmental
and
social
costs
in
determining
whether
the
risk
posed
is
unreasonable.
EPA
has
identified
a
number
of
sources
of
exposure
to
lindane
beyond
the
seed
treatment.
Past
uses
of
lindane,
consumption
of
imported
meat,
and
pharmaceutical
uses
of
lindane
are
all
current
sources
of
exposure.
For
indigenous
populations
who
rely
on
subsistence
diets,
exposure
to
lindane
or
HCH
isomers
may
result
from
current
or
past
manufacture
or
use
due
to
the
long­
range
transport
of
lindane.
EPA
believes
these
sources
of
lindane
have
produced
a
reservoir
of
lindane
in
the
environment
that
may
remain
for
some
time
due
to
lindane's
persistence.

The
seed
treatment
use
adds
to
this
current
lindane
exposure.
There
are
multiple
routes
by
which
individuals
may
be
exposed
to
lindane
from
the
seed
treatment
use.
As
discussed
previously,
consumption
of
crops
grown
from
treated
seed,
consumption
of
livestock
fed
treated
seed
and
consumption
of
drinking
water
are
all
routes
of
exposure
to
lindane
from
the
seed
treatment
use.
There
may
be
additional
exposure
due
to
volatilization
of
lindane
from
treated
seeds.
The
lindane
seed
treatment
use
will
add
to
the
existing
reservoir
of
lindane
in
the
environment.

EPA
believes
this
potential
ongoing
exposure
may
be
of
particular
concern
to
nursing
infants.
Due
to
lindane's
tendency
to
accumulate
in
fatty
tissues,
it
has
been
detected
in
the
breast
milk
of
women
in
the
United
States
and
in
many
other
foreign
countries.
Although
there
is
no
current
monitoring
data
for
the
U.
S.,
EPA
believes
it
is
reasonable
to
conclude
that
lindane
is
present
in
the
breast
milk
of
U.
S.
women
given
ongoing
exposure
to
lindane
and
the
chemical's
fate
characteristics.
EPA
acknowledges
there
is
uncertainty
on
the
level
of
risk
posed
to
nursing
infants
and
that
no
adverse
effects
have
been
reported.
However,
the
potential
for
adverse
effects
from
consumption
of
lindane
in
breast
milk
cannot
be
dismissed.

EPA
finds
the
overall
costs
of
continued
registration
of
lindane
for
seed
treatment
are
high.
The
seed
treatment
use
will
only
add
to
the
existing
sources
of
lindane
exposure.
Ongoing
releases
of
lindane
into
the
environment
are
of
concern
due
to
the
environmental
fate
characteristics
of
the
chemical.
Lindane
is
persistent
and
mobile
and
will
accumulate
in
human
fat
tissue.
This
potential
for
ongoing
and
future
exposure
to
lindane
is
of
particular
concern
for
nursing
infants
because
of
the
potential
for
exposure
to
lindane
via
breast
milk.
17
In
sum,
EPA
finds
that
these
costs
of
continued
lindane
registration
far
outweigh
the
benefits
of
the
seed
treatment
use.
Therefore,
the
lindane
seed
treatment
uses
are
not
eligible
for
reregistration
under
FIFRA.

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