vxEPA
                              fiowimisor 1B33
Analysis of
the Risks and Benefits
of Seven Chemicals
Used for Subterranean
Termite Control

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    ANALYSIS OF THE RISKS AND BENEFITS
            OP SEVEN CHEMICALS
          USED FOR SUBTERRANEAN
             TERMITE CONTROL
              NOVEMBER, 1983

OFFICE OF PESTICIDES AND TOXIC SUBSTANCES

       OFFICE OP PESTICIDE  PROGRAMS

     ENVIRONMENTAL  PROTECTION AGENCY
            401 M Street, S.W.
          Washington, D.C.  20460

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                      TABLE OF CONTENTS

                                                           PAGE

INTRODUCTION                                          '     1-1

IDENTIFICATION AND REGULATORY
    HISTORY OF CHEMICALS IN THE
    TERMITICIDE CLUSTER                                    II-l

THE COSTS AND BENEFITS OF
    SUBTERRANEAN TERMITE CONTROL                           III-l

RISK ANALYSIS                                              IV-1

RISK/BENEFIT ANALYSIS             '                         V-l

CONCLUSIONS                                                VI-1

BIBLIOGRAPHY                                               VII-1

APPENDIX 1
    Physical and Chemical Properties
    of Termiticides

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                          CHAPTER 1

                         INTRODUCTION


This paper responds to the concerns expressed in the General
Accounting Office (GAO) report "Need for a Formal Risk/Benefit
Review of the Pesticide Chlordane."

In August, 1980 the GAO summarized its investigation of the
adequacy of the Environmental Protection* Agency*1 s (EPA)
regulation of pesticides used in and around the home.  During
this review, the GAO concluded that underground application of
pesticides to control termites, may pose unreasonable risks to
man and the environment.  The GAO report specifically cited
problems the United states Air Force has had with contamination
in military housing where Chlordane had been applied for termite
prevention or control.     "

The GAO report concluded that the EPA should conduct a
Rebuttable Presumption Against Registration (RPAR) review of
Chlordane to determine whether the potential risk of the termite
•use outweighs the benefits of this use.  In support of this
conclusion, the report cites the National Canter Institute's
finding that Chlordane causes cancer in laboratory mice, and
the Air Force incidents showing airborne concentrations of
Chlordane in the living quarters of homes built on slab with
heating/cooling ducts in or under the slab previously  treated
with Chlordane.

The Agency responded to the GAO report in September, 1980.  In
the response, entitled "Response to GAO Report Need  for a Formal
Risk/Benefit Review of the Pesticide Chlordane", EPA agreed with
GAO's finding that there is cause for concern about  the use of
chlordane for termite control in some treated structures.
Exposure from the termite-control use of chlordane was not
anticipated at the time of the 1974 decision to cancel all
other uses of chlordane.

However, the Agency stated that an RPAR review  of chlordane
would not be the best approach to  the problem.  Although chlordane
is the most widely used termiticide, several other compounds
are also registered for this use, and some are  similar in
structure and effects to chlordane.  Therefore,  the  same problem
now associated with chlordane could occur with  some  or all  of
the other compounds.
                              1-1

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 The  Agency  proposed  a  comparative  risk/benefit analysis of the
^terraiticides  as  a  cluster.   This approach  results  in a more
 efficient use of Agency  resources  than  cheraical-by-cheraical
 RPAR proceedings and it  identifies  those termiticide chemicals
 requiring further  regulatory action.  Moreover,  this -approach
 would ensure  that  the  Agency would  not  take  regulatory action
 against  a pesticide  only to  have the market  replace it with a
 more hazardous pesticide.

 The  major objective  of the terraiticide  p-roject'"is  to identify
 and  assess  the health  risks  to  man  associated with the use of
 the  termiticides as  well as  the benefits derived from their use.
 The  chemicals included in the cluster aVe  those  currently
 registered  for subterranean  termite control:  chlordane, heptachlor,
 aldrin,  dieldrin,  lindane, pentachlorophenol, and chlorpyrifos.
 Once the potential risks and benefits are  discussed, and compared,
 further  actions, regulatory-and non-regulatory,  are identified
 to ensure that the concerns  raised  by the  GAO investigation
 are  adequately addressed.

 This report is composed  of five chapters in  addition to this
 introduction,  Chapter  I.  In Chapter II the  termiticide chemicals
 are  identified and a synopsis of the EPA's refulatory actions
 on each  chemical is  presented.  Chapter III  is a discussion
 of the subterranean  termite  and the costs  and benefits associated
 with its control.  This  information on  current control practices,
 benefits of control, and economic scenarios  of possible regulatory
 options  was compiled by  the  Agency's Benefits and Field Studies
 Division, Office of  Pesticide Programs.

 Chapter  IV summarizes  the data  on the health effects and human
 exposure associated  with the termiticides.   Data on the possible
 health effects of the  cyclodienes - chlordane, heptachlor, aldrin,
 dieldrin - are presented together because  of the similarity
 of these chemicals.  The data for the remaining  termiticides
 are  presented  for each chemical individually.  The summaries
 of the health  effects  data are  based upon  a  report entitled
 "An  Assessment of the  Health Risks  of Seven  Pesticides Used for
 Termite  Control" developed by the National Academy of Sciences,
 August,  1982  as  well as  other published reviews.  Exposure data
 were  taken from  the  open literature and unpublished data were
 obtained from  the Departments of the Air Force,  Navy and Army.

 Chapter V presents a summary of the health risks and benefits
 associated with  the  use  of the  termiticides  and  the final
 chapter, Chapter VI, presents the Agency's conclusions and
 recommendations.
                             1-2

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                           CHAPTER  II

            IDENTIFICATION  AND  REGULATORY HISTORY OF
              CHEMICALS  IN  THE  TERMITICIDE CLUSTER
 Identification

 The  chemicals  included  in  the  termiticide cluster are those
 currently  registered  with  the  Agency  for subterranean termite
 control.   A  list  of  the  common names  along with  the chemical
 names of these pesticides  is presented below:
Common Name

Chlordane



Heptachlor



Aldrin



Dieldrin




Lindane

Pentachlorophenol

Chlorpyrifos
Chemical Name

1,2,4,5,6,7,8,8-Octachloro-
4,7-methano-3a,4,7,7a-tetra-
hydroindane

1,4,5,6,7,8 ,8a-Heptachloro-
3a ,4,7 ,7a-tetrahydro-4,7-
methanoindane
            *      «
1,2 ,3 ,4 ,10 ,10-Hexachlcro-
1,4 ,4a,5,8,8a-hexahydro-
1,4 ,5 ,8-dimethanonaphthalene

1,2 ,3 ,4,10 ,10-Hexachloro-
6,7-epoxy-l,4,4a,5,6,7,8,8a-
octahydro-1,4,5,8-dimethano-
naphthalene

Hexachlcrocyclohexane

same as common name

o,o-Diethyl o-  (3,5,6-trichloro-
T-pyridyl) pEbsphorothioate
The chemical structure of each termiticide is displayed in
Table II-l.  Chlordane, heptachlor, aldrin, and dieldrin are all
chlorinated cyclodiene pesticides.  Because of the structural
similarity of the cyclodiene pesticides, the behavior of these
chemicals in the environment and associated health effects
are similar.  Lindane and pentachlcrophenol are also chlorinated
hydrocarbons.  Chlorpyrifos is an organophosphate pesticide and
thereby, is structurally different from the other terraiticides.

A complete listing of the physical and chemical properties of
the termiticides is presented in the Appendix to this document.
                             II-l

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                               TABLE II-l




                   CHEMICAL STHUCTUHE OF TERMITICIDES
 CIILOHDANE
                                  ci  a H
IIEPTACHLOR
                                                                   ALDRIN
       CI
DIELDItlN
                                   M CI    •*
                                 LINDANE
                                                              PEWTACIIIX)ROPIIENOf.
                                        o r,n6

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Regulatory History

Chlordane/Heptachlor

    1947 - Chlordane first produced commercially in the
    United States.

    1953 - Commercial production of heptachlor reported in the
    United States.
                                             4
    March 18 , 1971 - EPA Administrator*announced that an active
    internalreview was being initiated  on a number of pesticide
    products including those containing  chlordane and heptachlor.

    November 26 , 1974 - A Notice of Intent to cancel all registered
    uses of heptacnlor and chlordane, except for subsurface
    ground insertion for termite control and dipping of roots
    and tops of nonfood plants, appeared in the Federal Register.

    July 25, 1975 - EPA Administrator issued a Notice of Intent
    to suspend the registrations of certain pesticide products
    containing heptachlor and chlordane.

    November, 1977 - Cancellation proceeding's continued until
    11/77 at which time EPA and Velsicol Chemical Corporation
    (registrant) entered into settlement negotiations.

    March 6, 1978 - Final cancellation order putting into effect
  ,  terms of settlement was issued.

Aldrin/Dieldrin

    1948 - Aldrin and dieldrin synthesized in laboratory.

    1951 - Commercial production registered in United States.

    March 18, 1971 - EPA Administrator announced issuance of
    appropriate notices of cancellation of aldrin and dieldrin.

    August 2, 1974 - A Notice of Intent to suspend the registration
    of'certain pesticide products containing aldrin and
    dieldrin was issued.  The use to control termites was
    continued.

    October 18, 1974 - EPA Administrator announced ail pesticide
    products containing aldrin or dieldrin were suspended and
    the production for use of all such pesticide products is
    prohibited.  Subsurface ground insertion for termite control,
    dipping of non-food roots and tops,  moth-proofing by
    manufacturing processes in a closed system uses were
    allowed to continue.


                             II-3

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Lindane

    Early 1950's - Pesticide products containing lindane are
    federally registered.

    February 17, 1977 - Position Document 1; Notice of
    Rebuttable  Presumption Against Registration (RPAR) was
    issued.  Terraiticide use was not considered in this review.

    June, 1980  - Position Document 2/3 in RPAR process was
    issued-fermiticide use was not considered in this review.

Pentachlorophenol

    1930's - Use as wood preservative began.

    1950 - Commercial production in United States reported.

    October 18 , 1978 - Position Document 1; Notice of Rebuttable
    Presumption Against Registration (RPAR) was issued.
    Termiticide use was not considered in this review.

    January, 1981 - Position Document 2/3 in RPAR process was
    issuedtOnly wood preservative use of pentachlorophenol
    were considered in the wood preservatives RPAR PD 2/3;
    no discussion of penta as a soil termiticide was included
    in the PD 2/3.

Chlorpyrifos

    1979 - Dow Chemical Co. obtained state/local need registration
    (24-C)  from EPA for use of chlorpyrifos in subsurface
    termite control.

    August, 1980 -  Conditional registration granted for general
    use as a termiticide.
                             II-4

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                         CHAPTER III

    THE COSTS AND BENEFITS OF SUBTERRANEAN TERMITE CONTROL


Subterranean Teraites;  The Nature of the Bea3t

Subterranean termites belong to a number of .species in three
genera in the United States.  Generally, the genera Reticuliterates
and Coptotermes are considered the subterranean tenaites of
economic importance, but the dampwood termites of the genus
Zootermopsis may also be included.  The most common pests
are species from the genera Reticulite'rmes.  The genus Cop tote rmes
are subterranean termites but are able to sustain colonies
without soil contact, if there is moisture in the wood.

Termites are social insects like ants, and some bees and
wasps.  A colony is made up of several castes, each with
specific functions within the colony..  A complete colony
consists of a pair of primary reproductives or supplementary
(secondary) reproductives and two non-reproductive castes,
known as workers, and soldiers.  The primary reproductives
are darkly pigmented, ant-like winged termites andj are most
commonly observed.  In North America, they are usually seen
in the spring when swarming to establish new colonies.

After the swarming flight, males and females pair off and
seek suitable nesting sites.  After mating, the queen begins
egg-laying.  Only a few eggs are laid the first year, and about
six weeks pass before the eggs hatch.  The primary pair cares
for the eggs and the early growth stages of the nymphs, and
also maintains the colony.  Gradually, as the nymphs increase
in size and number, castes are formed.             -  .

The workers maintain and feed the colony.  Workers are the
damage-producing caste, destroying wood while tunneling for
food.  The soldiers have larger head capsules and powerful
mandibles that enable them to protect the colony.  If
supplementary reproductives develop, the growth of the colony
accelerates.  A colony started by a single pair of primary
reproductives, develops three to four years before the first
winged reproductives are seen.

Caste regulation is accomplished by an  intricate  system of
hormones or pheromones.  Termites engage in a large  amount of
fraternal feeding, or trophallaxis, and almost incessant grooming.
In doing so,, they transfer the hormonal chemicals that maintain
the colony's social cohesiveness.  Pheroraones are believed to
inhibit or allow development of members of one sex or  the
other, and to regulate the numbers of each caste.
                             III-l

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 Generally,  subterranean termites  must maintain  contact with
 the  soil.   They  are  susceptible to dessication  and need the
 protection  of  the soil  for  moisture.  As  noted  earlier,
 exceptions  occur rarely in  Reticulitermes  but more often in
 Coptotermes and  Zootermopsis  species, which  can maintain
 colonies  in constantly  dampened wood.   Subterranean  termites
 can  become  a problem any time they encounter moist,  warm soil
 containing  sufficient food, either wood or other material
 containing  cellulose.   Termites range between the 40°F annual
 mean isotherm  north  and south of  the equator.   In most
 centrally-heated buildings, termites can 'feed all year.  In
 unheated  buildings located  in the cooler extremes of the
 termites' range, feeding is reduced or  may cease entirely
 during  the  winter.   In  such instances the  termites may remain
 in the  nest deep in  the soil.  However, termites may be spread
 inside  previously infested  lumber and building  materials
 above this  isotherm.  Colonies can then maintain themselves
 in soils  under modern,  centrally  heated structures.

 The  Consequences of  Termites

     The Damage

 Termites  feed  on the cellulose in plants and p^Lant materials.
 In natural  habitats  this  is beneficial, in that the  termites
 degrade dead plant materials  to their original  elemental
 state.  On  the other hand,  when termites feed on man-made
 structures,  they can be extremely destructive and must be
 controlled.  Like most  wood-destroying  insects, subterranean
 termites primarily attack processed wood in  use.35 The U.S.
 Department  of  Agriculture has  estimated that throughout the
 U.S., 46 million dwelling units are subject  to  termite attacks
 annually.35 xne  damage  caused  by  wood-destroying insects is
 responsible for  major economic losses throughout the United
 States.   Damage  caused  by subterranean  termites accounts for
 an estimated 95% of  all the termite damage in the U.S.35

    The Costs

 No national data base has been compiled and  published on the
 costs of subterranean termites.   Several estimates of the
 annual  national  cost, ostensibly  including both the  loss due
to termite damage and the cost of control, appear in the
 literature.  These estimates  range from S100 million to $3.5
 billion.  Ebeling's  estimate  of 5500 million is the most
 frequently quoted figure.35
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 One  measure  of  the cost of  subterranean  termite damage is the
 cost of  termite control and damage prevention.  The amount
 people are willing to spend to prevent possible termite damage
 is a lower-bound estimate of their expectation of termite losses.
 In a 1979 USDA  report,  Richard Smythe and Lonnie Williams
 used the state  records  of a few  states to estimate numbers of
 wood-destroying insect  treatments during 1970 and their cost
 in 1976  dollars.,  These estimates were for single family
 dwellings in 11 southern states  with high rates of termite
 infestation.35     '                      .      *

 The  estimates derived by Symthe  and Williams indicate that
 nearly 440,000  treatments for subterranean termites were
 performed in 1970.  Of  the  total, 323,000 were remedial
 treatments and  115,000  were preventive or pretreatment.  In 1970,
 an estimated $130.2 million (1976 dollars) was spent by owners
 of single dwelling homes to "prevent and  control subterranean
 termite  infestation.  The costs  incorporated into this estimate
 include:  $79.4 million for remedial treatments, $13.8 million
 for  pretreatments  and $37.0 million for  contract renewal .or
 damage insurance.   The  cost estimate could be further increased
 by an estimated $33.6 million for expenses of damage repair
 done by  persons other than  those in the pest sontroi industry.35

 Symthe and Williams have estimated a lower bound for the
 value of termite losses in  11 southern high termite infestation
 states.  In  order  to construct national estimates one would have to
 have similar data  on treatment incidence and costs for the
 remaining states.   Unfortunately, very few states maintain
 extensive records  of this type.  Given this problem, the cost
 of potential nationwide termite  damage had to be estimated by
 extrapolating the  Smythe and Williams estimates using national
 survey data  on  pesticide usage.  These data came from the EPA
 National Household Pesticide Usage Study 1976-77 which
 indicated frequency of  termite treatments by EPA region
 throughout the  U.S.4  The extrapolation resulted in an estimated
 1.2  million  treatments  of single family dwellings for
 subterranean termites being performed in 1970, at a cost of
 $260.3 million  (1976  dollars).   Including an estimated $102.9
 million  for  contract  renewal or  damage insurance raises the
 total national  potential loss estimate in 1970 to $363.2
 million.  This  estimate can be further increased by adding
 the  estimated $107.6  million for damage  repair by someone
 other than the  pest control industry, bringing the total
potential loss  to  $470.8 million.

 This  loss estimate is in 1976 dollars; it can be inflated to
 1980 dollars using the  Bureau of the Census New One-Family
 Houses Construction Cost Index.35 inflating by this index
produces a national  potential loss estimate in 1980 dollars


                             III-3

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,o*f  S753.4  million  annually.   The  potential loss estimate
 presented  here  would  be  increased significantly by adding
 losses  in  aultifaraily dwellings,  commercial establishments,
 public  buildings and  the major  growth  in housing stock between
 1970  and  1980.  Although these  national loss estimates for
 single  family dwellings  probably  have  an upward bias .since
 they  were  developed by extrapolating  information for 11
 southern  high infestation states, this bias is no doubt more
 than  totally offset by the downward bias resulting from the
 exclusion  of potential losses in  multi-family dwellings,
 commercial establishments and public  buildings.,  Velsicol
 Chemical  Corporation  estimates  that these excluded losses
 appear  to  be on the order of  $250 million annually.  However,
 it  should  be noted, that this is  an extrapolation of an
 extrapolation,  based  on  uneven  data from 11 high infestation
 level states.   Given  the available data, 0.75-1.00 billion
 dollars per annum  appears to  be the best available estimate
 of  the  magnitude of the  subterranean  termite problem in the
 U.S.  This figure  is  an  estimate  based on treatment costs,
 cost  of renewal and/or damage insurance and the cost of damage
 repair.  The potential loss estimate  represents a lower-bound
 estimate of expected  termite  losses.35

 Control Methods

    Introduction

 There are  three basic methods for preventing or controlling
 termite infestation.   The first method is mechanical alteration.
 The second method  is  chemical control. The third method  is
 integrated pest management which  encompasses mechanical
 alteration and  chemical  control along  with several other
 methods and non-chemical methods. In  addition to these
 three control methods, there  is also  the use of nonwood
 construction materials or wood  resistant to termite attack.

    Mechanical  Alteration

 Mechanical alteration prevents  termite infestation in  two
 basic ways:  reduction or denial  of potential  food sources,
 and dessication of the microhabitat.

 Mechanical alteration entails such things as sanitation of
 wood  scraps during construction,  manipulation  of microhabitats
 by  increasing crawl space ventilation  to reduce moisture  levels
 or  grading so that water drains properly, and  use of construction
 techniques that do not allow  wood-soil contact.

 Termite shields were  used more  in the  past than  in recent years.
 These shields were thought to aid in  protecting against termites
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but instead just allow for better inspection for termites.

    Chemical Control

Chemical control occurs on two occasions.  The first is
preconstruction treatment or pre-treatment.  The second is
post-construction or remedial treatment, and is usually in
response to an identified infestation problem.  In either
case, the methods of chemical application are similar.
Notable differences between the two types of application are:
cost (pre-treatment is more economical); e^se of treating a
site rather than drilling and rodding chemicals into the soil
under a structure; and pre-treatment is more thorough and,
thereby, effective.                *

        Professional Application Practices

This section paraphrases the 1980 Approved Reference Procedures
for Subterranean Termite Control published by the National
Pest Control Association (NPCA) headquartered in Dunn Loring,
Virginia.18 Tne current labeling of termiticide compounds
contains application instructions which are similar, but not
always as extensive as those provided by the NPCA.
                                         «      *
Subterranean termites can be controlled or deterred by
impregnating the soil adjacent to a structure with a termite
toxicant.  Chemicals to control or prevent termite infestation
are used in three basic ways:  soil treatment, foundation
treatment, and wood treatment.  Only soil and foundation
treatments will be considered here.  Basically, in soil and-
foundation treatment, chemicals are applied along the  inside
and outside of foundations; around the bases of supporting
piers, chimney bases, plumbing and conduits; under filled
porches, entrances and terraces; under floor structures
resting on soil or gravel fill; and exposed soil areas under
structures.

One commonly used method of treating inside or outside a
foundation is called trenching.  Usually the  trench need not
be more than 8 to 12 inches wide, should penetrate the soil
to the top of the footing, and be dug to slope towards the
foundation wall and the top of the footing.  Where the tops
of footings are too deep to be easily reached via trenching,
a combination of trenching and grouting  or  rodding is  used to
apply the chemical to the tops of  footings.  The chemical
is poured along the bottom of  the  trench.  A  layer of  fill is
replaced, then more chemical is applied, another layer of
fill is replaced, then there is another  application, until
the trench is filled.  The last layer of treated soil  is
covered by a layer of untreated soil or  another  suitable
barrier such as polyethylene sheeting.   In  special cases,
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 such as near a well or cistern, the backfill may be treated
 elsewhere and returned to the trench.   In lighter soils or
 along rock ledges, the trench may first be lined with a heavy
 polyethylene film to prevent the leaching of the pesticide
 away frora the trench and foundation.

 Treatment along the inside of foundation walls is basically
 similar to the trenching done for treatment outside the walls,
 although the trenches need not be as deep or vd.de.   In cases
 where the soil is covered with concrete', roddiVig or grouting
 may be necessary.  Trenching is being  used less now than in
 the past and rodding has increased in  -use.  Currently,
 trenching is typically used in combination with rodding to
 prevent runoff.   Trenching is also done in low crawl spaces.

 Grouting rods are pushed or. driven into the ground  along a
 foundation.   Rods are placed about a foot frora the  wall and
 driven in at an  angle to the top of the footing at  one foot
 intervals.   Pesticide is then pvimped through the rods to the
 footing.   Often  the pumping is concurrent with driving the
 rod,  to aid  in penetration.  Less commonly, solid rods are
 driven down  to about the footing,  removed, and the^pesticide
 is  poured down the holes.   The interior of foundation walls
 are sometimes treated by rodding,  especially if concrete
 floors cover the soil.   Holes are drilled through the concrete
 floor at  18  inch intervals 8 to 12 inches from the  wall.  The
 grouting  rod is  then driven into the soil below the concrete
 floor.

 Treatment of fill under filled porches,  terraces and slab
 entry platforms  can be  done by tunneling or by drilling, then
 injecting or spraying the  pesticide.   To inspect or treat
 such  areas,  an opening  is  made in the  side of  a porch or
 terrace,  then soil is excavated from against the outside wall
 of  the  foundation.   This practice  breaks any soil-wood contact,
 allows  inspection for termite activity and also provides
 space  for a  trench treatment,  if one is  necessary.   Alternatively,
 the slab  may  be  drilled  vertically or  the sides may be drilled
 horizontally  and  the  pesticide pumped  into the fill under
 the slab  or  inside the  porch.

Masonry walls  of  block,  brick,  stone,  tile or  other materials
have  voids which  provide termites  with ready,  hidden access
 to wooden building  members.   The principle reason for treating
foundation voids  is  to place the chemical so it can seep
through cracks or voids  to  the top of  the footing.   This
prevents  the  termites from  entering via  the faults  or voids.
This  treatment is  administered by  drilling holes into each
void of blocks or  about every  18  inches  of bricks or into the
top of a  crack in  masonry  wall,  and  then pumping pesticide
into  the  drill hole  so  that  it can  seep  downward.   Generally,
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 the  holes are drilled just above  grade.  After  application,
 the  drill holes  and cracks are  sealed with mortar.

 Another application which appears to be  confined  to California'
 involves surface (spray)  treatment  of the soil  beneath existing
 structures.   In  the past, chlordane, heptachlor,  and lindane
 were applied  as  a broadcast spray often  under high pressure.
 More recently,  the California Department of  Food  and Agriculture
 (CDFA)  has made  regulations concerning spray application of
 chlorinated hydrocarbons  for subterranean termites more
 restrictive.   Surface application mus't be made  under low
 pressure as a perimeter band not  exceeding 18 inches and only
 when conditions  (access)  will not permit trenching or rodding.
 However,  the  soil surface treatment issue has not been resolved
 in California since there is still  considerable discussion on
 how  restrictions on surface treatment should be enforced.
 The  term "California Wash_®  is now used to refer to any process
 where surfaces under a structure  are sprayed in treating for
 termites.  It connotes an over-treatment or  drenching of the
 soil surface  with little  concern  for contact with the foundation
 walls or sub-flooring.

         Comparative Efficiency    • •             A
         	c.  , ..  .                        ^     <»

 The  efficacy  of  termiticides is measured by  the time over
 which the  toxic  barrier remains effective in resisting
 penetration by the termites.  The efficacy of a specific
 termiticide may  vary depending  on soil type, temperature,
 alkalinity, and  weather conditions.

 There is  very little primary literature  on the  efficacy of
 termiticides.  However, nearly  all  of the truly historic and
 current  studies  have been or are  being conducted  at the USDA
 Southern  Forest  Experiment  Station  at Gulfport, Mississippi.
 The  station has  unpublished data  indicating  100%  effectiveness
 for  34 years  with chlordane and slightly less with the other
 cycledienes.  Many compounds have been screened for activity
 in controlling termites,   Williams  indicated data exist
 demonstrating about 15  years of 100% effective  control with
 chlorpyrifos.35  These  tests are still in progress.
 Dr.  Raymond Beal also  of  the Southern Forest Experiment
 Station,  informed the  Agency that lindane applied at 0.4%
 was  effective for 11 years.^5 By  doubling the rate to
 0.3%, effectiveness was only increased by two additional
 years.   Dr. Seal also  indicated that endosulfan,  which is not
 registered for termite  control, was tested at 0.5% and provided
 about 10 years control.   Increasing the  rate of endosulfan to
 2.0% made  it  "hold up  for a few years longer".

Numerous  insecticides  have  been under study  for many years in
 soils in southern Mississippi for protection against subterranean
 termite attack.35  of these,  aldrin, chlordane,  dieldrin, and
heptachlcr applied at  various concentrations and  rates are still
effective after  17 to  21  years.

                             III-7

-------
•These tests are still underway and indicate that chlordane
remains an effective barrier for at least 34 years, whereas
heptachlor, aldrin, and dieldrin continue to be effective
after 29 years.. 35 soil residue studies were also conducted
which indicated that the insecticides inoved only a few inches
during 17 to 21 years of exposure to the elements.  In practice,
as  they are placed  in and under buildings, the cyclodiene
termiticides movement, without climatic weathering, appears
to  be neg-ligible.
                                              *
In  1972, Seal and Smith published the results of a long term
study which evaluated new compounds in terms of termite
control.35 They studied Baygon®, Dimetllan®, Sevin®, Dursban®,
Strobane®, Diazinon®, Zyton*, and the numbered compounds
GS-12968 and GS-13005.  As a result, they said:  "Dursban® is
the only insecticide that is still 100% effective after 4
years at both 1 and 2% concentrations in both tests...".
They also concluded:  "We know that some of these chemicals
will give at least  4 years of protection against termites...
This is a much shorter time than the 33 years that chlordane
has continued to control termites".

Dr. Raymond Seal reported on test data obtained afCer about
11 years of testing.35 peal said:  "We chose insecticides
for field testing after screening chemicals in laboratory
tests.  Only those  chemicals with .a low mammalian toxicity,
low toxicity to other soil insects, relatively low water
solubility, and a manufacturer willing to market the material
[were chosen] ..."  Nine compounds were selected that met
those criteria.  These were:  GS-12968, methidathion, diazinon,
and dimetilan (Ciba-Geigy Corp.); chlorpyrifos and Zytron®
(Dow Chemical Corp.); and carbaryl (Union Carbide Corp.).
As a result of this study,'Seal concluded "dimetilan, diazinon,
GS-12968, methidathion and Zytron* were ineffective as soil
insecticides.  Under a concrete slab, camphechlor, propoxur,
and chlorpyrifos remained 100% effective, for 11 years at the
2.0% rate of application.  Of these, chlorpyrifos remains the
most promising new  compound to date".

In conclusion, chlordane, heptachlor, aldrin, and dieldrin are
the most effective  termiticidal compounds and are comparable
in efficacy.

    Integrated Pest Management and Non-chemical Control

An  integrated pest management (IPH) approach for termite
protection begins with the design of structures, and continues
through site preparation and construction to maintenance,
                            III-8

-------
moisture control, environmental modification, inspection, and
judicious chemical treatment.  In essence, these measures are
a combination of the mechanical and chemical control methods
already described.

The most promising IPM innovation in termite cont-rol appears
to be the bait-block method of insecticide delivery, which
can be used with conventional toxicants, insect growth
regulators, antibiotics, and other control agents.  Among the
more innovative approaches to chemical control using bait-
blocks is the use of the juvenile hormone analog methoprene.
Methoprene is an analog of a naturally occurring insect growth
regulator and, when applied as an insecticide, it disrupts
the development of the insect which* eventually results in
mortality.  Methoprene is currently registered for use against
mosquitoes, certain flies, and fleas.^5

A non-chemical alternative to termite control has been recently
announced by The Nematode Farms, Inc. in Pest Control Magazine,
October, 1983.  The product  is called SPEAR".  The active
ingredient of SPEAR" is a Steinernematid nematode which  is  a
microscopic organism with an appetite .for termites.  The
nematodes can search for termites by sensing their body  heat,
carbon dioxide, and waste trails.  After 
-------
 hich has been treated  is found to be infested within one year
 >£ /treatment, retreattnent is performed at no cost to the
 jwner.  Such guarantees are renewable yearly for an annual
 fee.  These  renewal agreements usually provide for an annual
 inspection and retreatment, if necessary.

 In some cases, additional guarantees are offered.  Depending
 on the type  of structure and the type of treatment performed,
 the pest control firm may offer a guarantee against structural
 damage for a'one-year period.  These damage guarantees are
 available only if a retreatraent 'guarantee* is in effect.
 These guarantees apply  only to termite damage and commit the  .
 pest control firm- to repair all termite-producing structural damage,
 This sort of guarantee  is also renewable on an annual basis.

        The  Cost and Pricing Structure of the Termite Control
         Industry .

 Table III-l  presents a  breakdown of variable costs for the
 termite control industry.  This breakdown of costs is based
 on data provided by three leading pest control companies.

 The fee charged for treatment is based primarily on t^he amount
 of time (labor) required to do the treatment, *The amount of
 *ime required to-perform a termite treatment is a function
 f both the'mode of application and the area Clinear feet) to
 e treated.  The mode of application, in turn, is determined
 by the type  of structure (e.g., slab, crawl space, etc.).  To
 simplify computation of the treatment charge, most termite
 control companies use a pricing schedule.
                  1                       i>
Wages, equipment, vehicles, chemicals, other direct costs,
 in addition  to overhead and profit margins are factored into
 the dollar charge per linear foot presented in the schedule.
 Some companies convert  linear feet into a time factor before
 referring to the pricing schedule, while the others have
 already accounted for this conversion in their schedule.

    Comparative Cost-Effectiveness of the Registered
  * Termiticides

        Background and Market Preference

 For more than 25 years, foundations and soil beneath ho'uses
 have been treated with cyclodiene insecticides (chlordane,
 aldrin, dieldrin, and heptachlor) to control termite colonies
 and to prevent future infestations.  Currently, chlordane is
 the most widely used insecticide for subterranean termite
 control, followed by heptachlor.  Before 1974, chlordane
competed closely with aldrin for the major share of the
market.25 Generally, 55% of the market went to chlordane,
while aldrin accounted for about 40%.  The remaining portion
was primarily taken up by heptachlor.  Following EPA's
                            111-10

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                               TABLE III-l

 Variable or "Direct" Costs of Termite Control Industry Expressed as a
                Percentage of Total Termite Control Revenue
         I tan

     Labor  (wages)

     Chenical

     Equipment (punping units,
                 hoses)

     Vehicles (includes maintenance)

     Damage Claims

     Other  (miscellaneous expenses,
             uniforms, insurance,
             taxes)
of Total Revenue a/b/
     6-7

     2-5


     7-13

     1-3

    10-20
Based on chemical prices prior to the 60 percent increase in the price of
chlordane in the fall of 1982.
Infonnaticn source:  Orkin Pest Control, Termini* International, Inc.,
                     Western Termite and Pest Control
                                III-ll

-------
cancellation of most of aldrin and dieldrin uses,  Shell
Chemical Company discontinued the manufacture and  sale of
both compounds in the United States.  One of Shell's major
customers, Termini*, a aajor structural pest control applicator,
purchased the remaining supply of technical aldrin and continued
to formulate aldrin products for about a year.  From 1975 to
1976, Amvac Chemical Corporation synthesized aldrin for
Tenninix from available intermediates, but these materials
eventually ran out.  Currently, Terrainix relies <^n Shell
International (U.K.) for its supply of technical aldrin.

Terrainix imported aldrin in 1977 and 1978>, but aldrin lost
its price competitiveness and was not imported in 1979 and
1980.  Between 1980 and 1981 chlordane costs increased
significantly, which improved aldrin1s competitiveness.

There is little evidence of usage of the other chemicals '
registered to control subterranean termites, with the exception
of heptachlor.  Heptachlor is typically used in combination with
chlordane and has limited use as a single active ingredient
tenniticide.  Dieldrin was never used to any significant
extent in the past, primarily because of its high cost.  The
major uses of lindane are as a seed treatment £nd for1 control
of various species of wood inhabiting beetles, but a limited
quantity is applied for termite control by a few pest control
operators (PCO1s)(primarily in California).  Although registered
to be used in the soil for controlling subterranean termites,
pentachlorophenol (penta) is rarely applied in this manner.
Penta is used as a tenniticide only for special applications,
such as wood icipregation when termites are associated with
decay.  A concentrated formulation of chlorpyrifos for
subterranean termite control has been developed by Dow Chemical
Company.  Although registered with EPA in late 1980, the
product has only recently been introduced for the 1981 market
season.  There was some use of chlorpyrifos (Dursban®) for
subterranean termites in California under 24-C registration
(late 1979) from about June 1980 to December 1980.  Currently,
the chlcrpyrifos termiticide is more expensive than the
chlorinated hydrocarbons, and provides an option to PCO's
and their customers.  Table 111-2 presents production and
usage information on the termiticides.

        Costs of Termiticides

Table III-3 presents the comparative costs of the termiticides
in current use.  These are bulk user prices.  From the table,
it can be seen that chlordane, heptachlor, and aldrin are
virtually identical in cost and significantly cheaper than
either chlorpyrifos or lindane.  Dieldrin is not included  in
the cost table because it is currently not available or
                            111-12

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                                                      Table II1-2
                                     Production and Usage of Tenniticide Chemicals
Chemical
                 Producer
Amount of Chemical
    Used in
 Termite Control (1980)
  Most Comon
Formulated Products
     Used in
 Termite Control
                                                                                               Camtents
Chlordana
                 Velsicol
                 Chemical
                 Corporation
   (Ibs./ai)

 Approx. all of 10
 million pounds used
 for termite control
C-100 (Bibs/gal)1
C-50 (4 Ibs/gal)1
8EC (8 Ibs/gal)»
Termide* (4.2 Ibs.
 chlordane/yal;
 2.1 Ibs. heptachlor/
 gal.)2
Most widely used insecticide
 for subterranean termite
 control in 19BO.

Largest quantity of chlordane
 initially distributed to
 Region IV.
Hepatchlor
                 Velsicol
                 Chemical
                 Corporation
 Approx. 90%
 (1-2 million Ibs)
H-60 (2 l/21bs/gal)3
Termide** (2.1 IbsV
 heptachlor/ga1;
 4.2 Ibs. chlordane/
 gal.)
Used in smaller quantities
 and on fewer sites than
 chlordane.
                 linported fron
                 Shell International
                 Chemical Company
Aldrin           Unported fron                                Aldrin 4-E               A^ldrin was not imported in
                                                              (4 lb/gal)4               1979-or 19BO.
                                                                                       Aldrin was imported again  in
                                                                                        1981.
                                                                                       Use as a termiticide aeons to
                                                                                        be increasing in response to
                                                                                        chlordane price increases.

1/Chlordane concentrations are typically diluted with water to obtain a 1.0%/gal.  emulsion before use."~~
2/Chlordano-heptachlor mix is diluted with water to obtain a 0.5% chlordane/0.25&  heptachlor emulsion.  '
3/Heptachlor concentrate is typically diluted and applied as a 0.5% emulsion.
4/Bitulsifiable concentrate is mixed 1 gal. (EC) to 95 gallons of water to form a 0.5% use strength emulsion.
                                                         Ht-13

-------
                                                      Table II1-2
                                     Production and Usage of Term!ticIda Chemicals
Chemical
Producer
Amount of Chemical
    Used in
 Termite Control (1980)
  Most Cannon
Formulated Products
     Used in
 Termite Control
Comments
Dieldrin
Shell International
Chemical Company
    (Ihs.a.i.)

 No production in U.S.
  since 1974.
                          Hot available in the U.S,
                          and no known consunption
                           in U.S.
Lindane
Zoecon Corporation   11,000-12,000
                                                  No domestic production of
                                                   lindane since 1976;
                                                  Usage level haa remained
                                                   constant for the  last 5
                                                   yearsj
                                                  Few POO's identify lindarta
                                                   as preferred termite control
                                                   ageqtj
                                                  Use apparently limited to few
                                                   pest control firms in So.
                                                   California}
                                                  Most lindans used  in termite
                                                   control is applied to soil  as
                                                   surface epray.
Pentachloro-
 phenol
                     Very low percentage of
                     the 40-50 million Ibs.
                     produced is used in
                     termite control
                                                  Ko application to soil  reported
                                                   by PCO'sj
                                                  Use limited  to specific termite
                                                   control problems (e.g., where
                                                   termites have been  associated
                                                   with decay  or direct application
                                                   to infested wood structures).
                                                         111-14

-------
                                                      Table
                                     Production and Usage of
                                              rmiticide Chemicals
Chemical
Producer
Amount of Chemical
    Used in
 Termite Control (1980)
  Most Common
Formulated Products
     Used in
 Termi te Control
Ccmnents
Chlorpyrifos     Dow Chemical
                  Company *
                      (Ibs.  a.!.)

                     Few thousand Iba.
                     sold by end of 1980.
                     (California onlyj
                         Dow Termiticide^
                          concentrate 44.4% BC
                         Dursban^TC 42.09% EC5
                         In 1979 Dow obtained a state
                          local need registration (24-C)
                          for chlorpyrifos to be used for
                          subsurface termite control
                          in California.
                         Conditional registration as
                          termiticide granted in 1981.
5/Two gallons of concentrate are mixed with 100 gallons of water to yield a 1.0% use strength emulsion.
                                                         111-15

-------
                                                       TABI£ III-)
                                       Gon|>arat|ve Coala o( Iterwlticlrie
(.1u»ic*l tormildtloii l/ost » Caot/qal. Dilute /Ippro*. Chuaical
|$/9*l.l Dilute Solution Beady-to-Use Solution Coat for Protection
Bpilvalent of
1 gal. cyclmllenesty
($>
(lili r.lim: (1 IX' 10. 00 1.0 O.JO 0.10
/M.lrln 4 rt- 25.00 0.5 0.25 0.25
Hil«i.tiii<>/ 4.2 Uilor. 2U.OO 0.5 0.27 0.27
l^l'l.ujilor 2.1 ll>vta. 0.25
V
(ltlo«vyri(os 4 P.C 6S.OO 1.0 I.JO 2.60
l.iiiliiV! 1 UL 12.00 0.8 0.77 ^ 1.54
^Pf^rott. Ibtal
o( Projection
Bjuiviilent to
1/qal. cyclollenea^^y
($>
5.OO
5.00
5. IK)


12. no
10.94
V
 Ki'iur'^ Uvso<1 on tulk unor |>rlonn palil l>y Orkln, Heatern. nnd Itomlnlx In 1981.


•y
 A.s:«m:n d>loq»yr ilofl nnl llrvlaiw |x;ralttt 1/2 «a loot] as cyclodleneo.-


£/
         cyclulf<»M>  dnikioil  oost to 6t of total ajipl'cation onta.
'J/
 CiMita |ir'.-H«-«a<-l  .u >r  I'JHl  oat lm.il 
-------
consumed in the United States and, therefore, current price
estimates are not available.  In the past, the cost of dieldrin
was typically higher than the cost of the other cyclodienes,
which contributed to lower dieldrin usage relative to the
other cyclodienes.  When the reduced persistance of lindane
and chlorpyrifos is taken in account, cost differences between
these chemicals and the cyclodienes widen still further.  If
one assumes that chlorpyrifos and lindane persist half as
long as the cyclodiene termiticides, the chemical cost of the
protection equivalent to that provided by one^ gallon of
cyclodiene tenniticides increases from'$1.30 to $2.60 with
chlorpyrifos and frora $0.77 to $1.54 with lindane.

The application costs of the retreatments required with the
chlorpyrifos and lindane will further expand the cost
differential, from $5.00 with the cyclodienes to approximately
$12.00 with chlorpyrifos and to $10.94 with lindane.

Another factor that would increase the differential on costs
for the application of chlorpyrifos compared to the cyclodienes
is the cost for monitoring the blood cholinesterase level of
applicators before the use of the chemical and on a regular
basis.

As can be seen from this and the previous section, chlordane,
heptachlor, and aldrin are the most cost-effective
chemicals for termite control.  Lindane or chlorpyrifos are
alternatives which can be used where use of the other
termiticides is restricted either by the structure's owner
or government regulation.

There appears to be some disagreement within the PCO  industry
as to which of the cyclodienes is best in terms of ease of
handling and applicator health effects.  On balance,  the
choice between the cyclodienes seems to be one of personal
preference rather than documented advantages or disadvantages.

The efficacy of a number of chemicals, not currently  used  as
termiticides, was previously discussed.  While some were
effective, their persistence compares unfavorably with  those
chemicals currently in use.  Mobay Chemical Company has  a
compound, Oftanol*, that was registered as a restricted  use
pesticide for control of subterranean termites July 19,  1982.
However, insufficient testing has been done  to date to  allow
evaluation of its viability as an alternative  to  the  cyclodienes,

It is reasonable to expect  that as  long as the cyclodienes
remain on the market and/or are relatively inexpensive,  the
                             111-17

-------
 outlook  for new  chemical  controls  will  be  bleak  because of the
 difficulties  in  finding cost  competitive alternatives to the
 existing chemicals.  There  is currently little incentive to
 develop  new control methods as  long as  inexpensive, effective
 products are  available.
Subterranean  termites are colonial  insects which damage wooden
structures  by eating the cellulose  in  the wood.  The estimated
annual  cost of this damage  to  the nation is at  least three
quarters of a billion dollars.  This estimate is based on
treatment costs, cost renewal  and/or damage insurance and the
cost of damage repair.  Subterranean termites can be prevented
partially by  proper construction methods and design, and by
prophylaxis with terraiticides.  When termites do become
established in a structure, they can generally  be controlled
with pesticides.  The preferred pesticides r considering
price, efficacy, and extended  period of protection, are the
cyclodiene  pesticides, particularly chlordane or aldrin.  While the
extended period of protection  is a, major advantage of the
cyclodiene  pesticides, current practices in* the field indicate
that treatment with the cyclodienes occurs more frequently
than the 30 plus years of termite control shown by these chemicals.
If, in practice, the consumer  is not able to take advantage of
the extended  period of protection, then the benefits of the
cyclodienes would diminish.  Pest control operators as well as
the financial  and real estate .institutions must be aware that
frequent retreatments with cyclodienes are not  necessary unless
a reinfestation is found in a structure.
                            111-18

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                          CHAPTER  IV

                        RISK ANALYSIS
An analysis  of  the  risks  associated wi.th  the^use of the
chemicals  in the  termiticide cluster considers  information on
health effects  in combination with an assessment of the
exposure likely to  occur  from this registered use.  The first
part of this chapter consists of a discussion of the available
information  on  the  health effects for each of the chemicals.
Chlordane, heptachlor, aldrin, and dieldrin, referred to as
the cyclodienes,  will be  considered together because of
similarity in chemical structure and associated health effects,
Lindane, pentachlorophenol, and chlorpyrifos will be discussed
individually.  The  summaries on toxic effects are taken from
extensive published reviews and assessments of  the data on
the termiticides, particularly the recently completed National
Academy of Sciences report, "An Assessment £>f theiHealth Risks
of Seven Pesticides Used  for Termite Control" (referred to as
NAS report).  In  cases where a specific study is discussed,
the author of the study is given so that  the study may be
identified.   However, in most cases the original study was
not reviewed by the Agency, but rather the information was
taken from a secondary source.  The secondary source is then
referenced and listed in  the bibliography.

The second part of  this chapter discusses the information
available on the  extent of human exposure to the termiticides,

HEALTH EFFECTS DATA

Cyclodienes  - Chlcrdane, Heptachlor, Aldrin, Dieldrin

Acute toxicity information for the cyclodienes  is presented
in Table IV-1.  Toxicity  for the cyclodienes is characterized
by effects on the central nervous system.^5,39,40
                          Table IV-1

             Acute Oral Toxicity Data By Chemical

     C_hemi_ca_l                 Oral LDgj) Value  (rats, mq/kg)

     Chlordane                         335-430

     Heptachlor                        100-160

     Aldrin                             46-63T

     Dieldrin                           38-52

                             IV-1

-------
Data show that exposure to the cyclodiene terraiticides can
affect the central nervous system in humans and animals.
Symptoms of acute poisoning in man include: dizziness, nervousness.,
convulsions, and loss of coordination.40

Oncogenicity

Carcinogenicity data on the cyclodiene' termiticides have'been
reviewed extensively.  Studies have been conducted in several
species of laboratory animals to evaluate the carcinogenic
potential of each of the chemicals.  The analyses and
interpretations of the results of these studies regarding
carcinogenic potential vary for each compound and species/strain/sex
of the test animal.  Tests conducted in rats were all negative
for chlordane, heptachlorT aldrin and dieldrin.  Chlordane,
heptachlor, aldrin, and dieldrin are carcinogenic in mice,
producing liver neoplasms after oral administration of the
chemicals.  Data concerning the Carcinogenicity of these.
chemicals in rats are inconclusive.41 The one consistent
result observed is that all four of ,the cyclodienes produce' a
significant increase in the incidence of he'batocellular   :
carcinomas in the B6C3F1 strain of mice.15,39,40

The limited human studies with long-term exposure to any of
the cyclodienes have not revealed any consistent or significant
detrimental health effects.

Teratogenicity and Reproductive Effects

The available teratogenicity and reproductive effects data
for the cyclodienes are not as extensive as  the Carcinogenicity
data ^and are inconclusive.

In a study (Ingle, 1952) in which rats were  fed chlordane  in
the diet at 5,10,30, 150, or 300 ppm, one female rat  from
each test group was mated at the 24th and 48th week.  No
effects on litter size or number were reported by the authors.
Heptachlor, fed to rats in the—diet at 6 mg/kg body weight,
caused a decrease in litter size in a multigeneration study
(Mestitzova, 1967).15

Several studies investigating the teratogenic potential of
aldrin and dieldrin were cited in the NAS report.15 Pregnant
hamsters were given single oral doses of aldrin at 50 mg/kg
and dieldrin at 30 mg/kg on day 7,8, or 9 of gestation
(Ottolenghi e_t a^. , 1974).  The authors of the study  reported
an increase in fetal deaths, compared with controls,  and  an
increase in anomalies such as open eye, cleft palate, and
webbed feet.  Mice, given aldrin at 25 mg/kg or dieldrin  at
15 mg/kg on day 9 of gestation, showed no effect on fetal
survival or weight but some anomalies were noted.


                             IV-2

-------
In other studies on mice and rats administered dieldrin at
1.5, 3, and 6 mg/kg/day on days 7-16 of gestation, no teratogenic
effects were observed (Chernoff et al., 1975).  However, at
6 rag/kg a 41% increase in mortalTty was noticed in rats and
increased liver-to-body weight ratios and decreased weight
gain in mice was observed.1*
                                              4
In a six-generation mouse reproduction study, aldrin and
dieldrin were administered at 25 rag/kg per day in the diet.
The authors noted marked effects in fertility, gestation^
viability, and lactation at 25 mg/kg  (Deichmann, 1972).^

Mutagenieity
                           *«
Data from the tests including the Salmonella microsome assay
and the dominant-lethal test (mouse!indicate that pure
chlordane is negative in all of these test systems but
technical chlordane was mutagenic in Salmonella without
mammalian activating enzymes (Simmon e_t £l. , 1977).15,39
When chlordane was administered in a single <^ose ofi 50 or
100 mg/kg/body weight to Charles River CD-I male mice that
were then mated to untreated females, no dominant lethal
effects were noted in the offspring (Arnold e_t aj^., 1977). 15

In a recent study, chlordane and heptachlor were  investigated
for genotoxicity in cells derived from the organ  in which
they produce tumors (liver cells).  The authors concluded that both
chlordane and heptachlor were negative in  the ARL-HGPRT
mutagenesis, which is a sensitive system for detecting mutagenic
potential of various compounds  (Telang e_t Q. , 1982).*4

Additionally, heptachlor was found not to  be mutagenic when
tested in several strains of Salmonella typhimurium with  and
without a rat-liver microsomal  activation  system  (Marshall et al.,
1976).  In a dominant-lethal test rats were  fed a diet  of
heptachlor at 1 or 5 mg/kg.  Significant number of  resorbed
fetuses and increases in the numbe'r of abnormal mitoses were
absorbed in the second and third generations  (Arnold  et al.,
1977). 15,39                      *                    	

The results of several studies  indicate that  dieidrin was  not
mutagenic in several strains of Salmonella typhiniurium  with
or without liver activation systems.  One  study reported  that
dieldrin was mutagenic in  two or three strains of Salmonella
typhimurium without activation  (Majumber et  al.,  1977).15
                             IV-3

-------
 Lindane

 The acute oral LDsg value for rats is between 125-230  mg/kg/body
 weight.  Earliest signs of lindane toxicity include:   headache,
 dizziness, and vomiting.   Other symptoms are:  diarrhea,
 hypothermia, hyperirritability, incoordination, and
 convulsions.15f 36

        Oncogenicity

 Several carcinogenicity studies have been conducted on lindane.
 In a study similar to those conducted on the  cyclodienes,
 groups of 50 B6C3P1 mice  of each sex were fed 80 or 160 ppm
 lindane in the diet for SO^weeks (NCI, 1977)  .   The results
 indicated a significant increase in the incidence of hepatocellular
 carcinoma in the  males of the low-dose group  compared  to the
 controls.  However, no significant difference in the incidence
 of hepatocellular carcinoma was found in the  high-dose group
 when compared to  the controls.   The authors of  the study
 concluded that lindane was not  carcinogenic ^Ln  mic%.15

 In another study,  400 ppm lindane in the diet was fed  to CF1
 mice (Thorpe and  Walker,  1973).  Increases in liver tumors
 were observed in  both male and  female mice.15

 Groups  of 50 Osborne-Mendel rats of each sex  were fed  lindane
 in the  diet for 80  weeks;  236- or 472 ppm for  males and 135 or
 270  ppm for females (NCI,1977).   No significant increase in
 the  incidence of  tumors was observed in any of  the test
 groups.. I5

        Teratogenicity and  Reproductive Effects

 Several  studies have  been  conducted on the teratogenic and
 reproductive effects  potential  of lindane.  Lindane does not
 appear  to cause teratogenic or  reproductive effects.   Fetal
 effects  at or above the dosage  that causes general maternal
 toxicity  have  been  observed.

 In a  three-generation rat  study,  lindane was  fed in the diet
 at 25, 50,  or 100 ppm (Palmer e_t aJL ,  1978).  No reproductive
 effects were  observed and  no increase in malformations were
 observed.15  When lindane was given  orally at  5,  10, or 15
mg/kg/body  weight to  rabbits  on days 6-18 of  gestation and
 to rats on  days 6-16  of gestation,  no teratogenic effects
were  observed.4&

 In another  study, lindane  was given orally to female rats at
 0.5 mg/kg  (Naishtein  and Leibovich,  1971).  Disturbances in
 the estrus  cycle and  diminished  reproductive  capacity  were
observed.40

                              IV-4

-------
        Mutagenicity

Mutagenicity  was  not  a  concern  at  the time Position Document 2/3 .
was developed by  the  Agency.  The  mutagenicity data base for lindane
is not  complete,  but  available  studies suggest little mutagenic
activity,  if  any.36

Pentachlorophenol

The oral LD$Q of  pentachlorophenol  for rats is 146-175 mg/kg.
Symptoms of intoxication  include accelerated respiration,
vomiting,  increased body  temperature, tachycardia, neurorauscular
weakness,  and cardiac failure.  Similar symptoms of loss of
appetite,  respiratory difficulties, hyperpyrexia, sweating,
dyspea, and coma  have been reported in humans.40

In the  Notice of  Rebuttable Presumption Against Registration
(October 18,  1978), the Agency  cited-three studies concerning
the possible  oncogenicity of pentachlorophenpl.  rhnes et al.
(1969)  administered by  gavage 46.4 mg/kg pentachlorophenol to
mice on days  7 through  28 of age,  followed by 130 ppm
(17 mg/kg/day) in the diet for  2 years did not increase tumor
incidence  over control  animals.  Boutwell and Bosch (1959)
applied 0.3%  dimethylbenzanthracene in benzene as an initiator
to the  shaved backs of  mice.  As a promoter, a solution of
20% penta  in  benzene  was  applied similarly twice weekly for
15 weeks.34

These papers  were reviewed by the Agency's Carcinogen Assessment
Group and  were found  to be negative with respect to oncogenic
effects of penta.  However, since  that time several other
studies pertinent to  the  oncogenic potential of commercial
pentachlorophenol and its contaminants became available.  The
National Cancer Institute reports  two bioassay studies dealing
with the possible carcinogenicity.  of two isomers of
hexachlorodibenzo-p-dioxin (HxCDD), a contaminant of
pentachlorophenol.  The results of one study, on the dermal
application of HxCDD  to mice were  negative.  In the second
study, rats and mice  were given oral doses of HxCDD ranging
from 1.25  mg/kg/week  to 10 mg/kg/week.  Under the conditions
of this study, HxCDD  increased  the  incidence of benign and
neoplastic liver tumors in mice of both sexes and in female
rats.34

     Teratoqenicity and Reproductive Effects

Embryotoxic and fetotoxic effects  were observed in Sprague-
Dawley rats given pure  or commercial grade pentachlorophenol
at dosage  levels of 15  mg/kg/body  weight or greater (Schwetz et
al. ,  1974).   In another study by the same author, no effects


                             IV-5

-------
on neonatal survival and development were observed in rats  fed
3 mg/kg of pure pentachlorophenol prior to Bating, during
mating, during gestation and lactation.  At 30 rag/kg , a
reduction in body weight was observed among adult rats as
veil as & decrease in neonatal survive! and growth. 15

     Mutagenicity

Pentachlorophenol did not induce sex-linked recessive lethals
in Drosophila melanogaster. ^°
Chlorpyrifos
The oral LDso of Chlorpyrifos for rats is between 82-245
ag/kg.  Acute data in rats suggest that Chlorpyrifos is
absorbed through the skin in acutely toxic amounts.  A study
in humans indicates that absorption through the skin is limited
to only a small fraction of the applied dose. ^ Symptoms
of Chlorpyrifos poisoning include:  nervousness, giddiness,
headache, blurred vision, weakness, nausea, cramps, diarrhea,
and discomfort in the chest.10,15

       Oncoqenicity

Two long-term feeding studies have been conducted to
investigate the effects of Chlorpyrifos.  In a 2-year study,
groups of rats and dogs received dose levels of up to
3 mg/kg body weight/day Chlorpyrifos.  Dosages of 0.1 mg/kg/day
or less had no effect on plasma and red-cell cholinesterase
activity in rats and no effect was observed in dogs at
0.03 mg/kg body weight/day.  Higher dietary concentrations of
Chlorpyrifos caused significant decreases in cholinesterase
activity (McCollister et aU , 1974). 1S

In another study, CD— 1 mice were^given Chlorpyrifos in the
diet at 0.85, 6.72, and 15.8 ppm for 105 weeks (approximately
0.05, 0.5, and 1.5 rag/kg body weight/day) (Warner et al. ,
1980).  No significant effects were observed in the treated
group.  Tumors and other lesions were observed in treated
and control groups but no tumors appeared to be related to
the treatment of Chlorpyrifos.15
                             IV-6

-------
     Teratogenicity and Reproductive Effects

No teratogenic effects were observed in pregnant CF-1 mice
administered chlorpyrifos by gavage at 1, 10, or 25 mg/kg on
days 6-15 of gestation (Deacon e_t a 1. , 1980)'.  At 25 ag/kg
severe maternal toxicity and fetotoxicity was observed
and a decrease in plasma and red-cell cholinesterase was
reported at all dosages.  In a repeated experiment, a decrease
in cholinesterase activity was noted at 1 and 10 mg/kg.^

     Mutagenicity

Mutagenicity tests in several strains of Salmonella typhimurium
and Escherichia coli were negative.15


EXPOSURE DATA

Available evidence of potential human exposures to the
termiticides is presented in the discussion ythat fallows.
Distinct groups of people that could be exposed to termiticides
have been identified:  workers engaged in the manufacture of
termiticides; persons who apply termiticides, including
professional applicators and the general public who use
household products which contain these chemicals; and persons
residing in structures which have been treated with termiticides,
Although some exposure data are available for each of the
groups identified above, the information is primarily on
exposure to chlordane.

Human exposure to termiticides has been previously considered
and various exposure levels have been established.  The
American Conference of Governmental Industrial Hygienists 1982
(ACGIH) has adopted a Threshold Limit Value-Time 'Weighted
Average (TLV-TWA) of 500 ug/M^ for chlordane  in workroom  air.
This value can be interpreted as, the maximum  level  to which
workers may be continuously exposed to chlordane in  the
workplace (8 hours/day, 5 days/week) without  adverse effect.
The Occupational Safety and Health Administration's  (OSHA)
permissable workplace exposure limit  is  500  ug/M^.
                              IV-7

-------
 Similarly,  exposure levels  have -been established for-the other
 tenniticides  and are listed below:

                             ACGIH  Level     •   OSHA  Level
      Chemical                (uq/M3)            (ug/M^)
      "                       	 	.      «

      Heptachlor               500                500
      Aldrin/Dieldrin          250    *           250
      Lindane                   500                500
      Pentachlorphenol         500                500
      Chlorpyrifos              200                 -
 The  exposure  analysis  that  follows considers inhalation and
 dermal exposure to  these chemicals from their termite control
 use.  Exposure to these chemicals as a result of other uses
 is not considered for  the purposes of this discussion.
 Although  the  most widely used  termiticides, the cyclodienes,
 have not  been registered for uses other than termite control
 (and certain  phase-out uses of chlordane and heptachlor)
 since the mid-1970's,  these chemicals are very persistent in
 the environment.  Therefore, other sources of exposure, as a
 result of former registered uses is very probable.  The
 other termiticides, lindane, pentachlorophenol, and Chlorpyrifos
 are not widely used for termite control but have numerous
 other registered uses.  Also,  since all of these chemicals.
 are available for homeowner use, the additional potential
 sources of exposure are difficult to estimate.  Therefore,
 the exposure  estimates do not  represent total possible exposure
 to any of the chemicals but rather attempt to estimate the
 amount of exposure from just the termite control use.

 Workers Involved in Manufacture of Tenniticides

 The few studies that have been 'conducted to investigate the
 occupational exposure to the tenniticides have focused on
 exposure  to chlordane.  The most recent investigation studied
 a cohort  of 1,403 workers employed for longer than three
months in the manufacture of chlordane and heptachlor at two
plant locations between 1946 and 1976 (Wang and McMahon, 1979).
 Data obtained from Social Security records, death records,
 and employment records, indicated no overall excess of deaths
 from cancer.  There was a statistically significant excess of
deaths from cerebrovascular disease but the authors concluded
 that these deaths occurred after termination of employment
and were  not related to duration of exposure.15
                             IV-8

-------
 Shindell  and  Associates  (1980)  continued  to study  former and
 current employees  at  the  two  plants of the Velsicol Chemical
 Corporation.   This cohort consisted of 1,115 people who worked
 at  the Memphis plant  between  January, 1952 and December, 1979
 and 783 people who worked at  the Marshall, Illinois plant
 from January,  1946 through December, 1979 „  T^e authors
 concluded that the mortality  among workers at the  Marshall,
 Illinois  plant was significantly lower than expected while at
 the Memphis plant  the mortality was lover than expected, but
 not significantly  so.

 There was a statistically significant positive trend in the
 standard  mortality ratio  far  cancer deaths in workers with
 increasing duration of employment.  However, the increase in
 standard  mortality ratios from  one to 20 years of  exposure
 was not large.  The findings  among workers who had a minimum
 of  20 years of  employment were  seven deaths from cancer with
 6.6  deaths expected;  for  workers with 10 or more years of
 employment there were 14  deaths with 13.6 deaths expected;
 and  for workers with  a minimum  of five years employment there
 were  16 deaths  with 16.5  deaths expected.  None of the
 individual values  has statistical significance.  The authors
 of  the study concluded that there was no evidence  to indicate
 that  current or past  workers  at Velsicol plants are at an
 increased risk  for health-related problems.  The HAS report
 indicates that  the results of this epidemiology study suggest
 a trend in cancer  deaths  with duration of employment but
 advise that more complete data  are needed before firm conclusions
 can  be reached  with regard to the carcinogenicity  of
 chlordane in humans.15,23

 Additionally,  a retrospective cohort mortality study to
 examine mortality  among workers employed  in the manufacture
 of  the chlorinated hydrocarbon  pesticides was initiated by
 the  National Institute of Occupational Safety and  Health
 (NIOSH).6 The  intent  of the study was to examine the mortality
 of workers employed in plants where the following  pesticides
 are manufactured:   chlordane, heptachlor, DDT, aldrin/dieldrin,
 and  endrin.  Pour  U.S. manufacturing plants were selected for
 the study and  each cohort  included all workers employed for
 at  least  six months prior to  December 1, 1964.  The study
group consisted of 2100 individuals.

The vital status for  each  of  the individuals in the cohorts
was followed up to December 31, 1976.  The Standard Mortality
Ratio (SMR) for all causes  of death in each cohort was below
 the expected level.   In one of  the plant cohorts (aldrin/dieldrin/
endrin)  deaths  due to  nonmalignant respiratory system disease
were significantly  above  that expected.
                             IV-9

-------
The authors stated that the deaths observed due to "all
malignant neoplasms" in each plant were less that the number
expected.  Although there were no statistically significant
excesses or deficits in mortality for any specific cancer
site, for the following several sites the observed number of
deaths slightly exceeded the expected number for individual
plants:  stomach, esophagus, rectum, liver, iV^phatic
and hematopoietic system.  There was a deficit for respiratory
cancer in one plant.                 ^

The overall conclusions of the study investigators were that
due to the small number of workers included in the study, the
statistical power does not support a conclusion that no
association exists between*cause-specific mortality and
employment at the study plants.  The authors stated that the
primary reason for the small cohort numbers is due to the
rapid turnover at the plants and, therefore, most workers who
were hired left before completing six months of employment.

Professional Applicator Exposure    '       t    •-*•'•

The National Pest Control Association (NPCA) has provided
estimates of the number of personnel engaged in structural
pest control work.  These estimates are presented in
Table IV-2.

                          Table rv-2

          Number of Personnel Engaged in Structural        . • "•
                      Pest Control Work
                       Total
                Number of Personnel       Personnel Specializing
                Engaged in General          in Control of Wood
Year               pest Control	        Destroying Organisms

1974                  31,000                      8,600
1979         .         42,000                     11,524
1980                  36,500                     13,500

Information on potential exposure levels for applicators of
termiticide chemicals is limited to a study conducted jointly
by Velsicol Chemical Corporation and the California Department of
Pood and Agriculture.  This study determined potential chlordane
exposure to applicators and inhabitants in six houses of two
types:  crawl space and slab construction.  The treatments
were conducted by commercial pest control operators.  Exposure
was measured by monitoring the concentration of chlordane in


                             IV-10

-------
the applicator's breathing zone and by attaching cloth patches
to the applicator's coveralls.  Air samples were taken as
follows:  air inside and outside applicator's respirator,
air during and after application, air samples taken 24 and
48 hours after application, and 7 and 30 days after application.
The levels of chlordane detected from the cloth patches and
gauze material worn on the applicator's overalls were similar
for the slab and crawl space treatments.  The levels of
chlordane from the slab treatment ranged from 0.005-1.70 ug/M^
and for the crawl space 0.019-2.90 ug/M2.3,12

Nonprofessional (Homeowner) Applicator Exposure
                           «
There are no known data on the number of people who use
commonly available products containing the termiticides.
However, EPA estimates that approximately 1.5 million pounds
of these chemicals are sold annually to the general public for
the period 1979-1981.  In 1982, 1.4 million pounds of chlordane
were sold.  Velsicol forecasts that 600,000 pounds -of chlordane
will be sold for home owner use in 1983.

The National Household Pesticide Usage Study, 1976-1977
provides some information on homeowner usage of chlordane-
containing products.  In this study, 8254 households were
interviewed and asked to provide information regarding all
pesticides that they had used or stored during  the past year.
The data from this survey pertaining to chlordane are presented
below and provides an indication of homeowner usage.  However,
the time period considered in this study preceded the
restriction of chlordane usage to subterranean  termite control.

Chlordane ranked fourth among 12 known pesticides observed
most frequently in the study.  From the survey, 639 households
reported having used or stored 694 chlordane products within
the previous year.  Based on these- data, it was estimated
that 7.7% of the households in the U.S. used or stored
chlordane-containing packages or containers and that over
6.2 million chlordane products were used by 5.7 million  U.S.
households.  Sixty-five percent of the household use was
application to the lawn, yard or flower gardens; 17.2% application
inside houses; and 14.1% application to vegetable gardens.
                             IV-11

-------
 Residents of Buildings Treated  with  Teraiticides

 Several reports and studies  are.available  on  possible exposure
 to residents of tenaiticida-treated  dwellings.

      U.S. Department of Defense Monitoring program

        Department of the Air Force

 Airborne chlordane contamination of  military  housing units
 following treatment for tennites was Reported by  the Department
 of the Air Force in the early 1970's.  The first  incident
 occurred at Wabb Air Force Base, Texas in  the spring of 1970.
 Twenty-eight air samples from two houses with cardboard duct
 work in a concrete slab were analyzed for  chlordane.  The
 concentrations  of chlordane  ranged from 800 to 1600 ug/H3
 initially and from 34  to 180 ug/M3 eighteen days  after attempts
 to clean the chlordane from  the duct work.

 A  second incident occurred at Wright-Patterson Air Force Base,
 Ohio during 1974-19.75.  Air  samples  were obtained 2rom 537
 newly constructed houses that had been pretreated with
 chlordane.   Measurable levels of chlordane were detected in
 412 of 537  houses sampled*   Concentrations ranged from a
 trace (>0.4 ug/M3)  to  34 ug/M3.

 In October  of 1978,  two houses  at Scott Air Force Base,
 Illinois, were  monitored as  a result of occupant  complaints
 of odors following  subslab injection of chlordane.  The chlordane
 concentration in these units were 263 and  26  ug/M3.  These results
 prompted a  survey of 11 other units  treated in a  similar manner
 in 1978.  Chlordane  concentrations ranged  from 0.4 ug/M3 to 22 ug/M3
 in these units.   In  1980, the study  was expanded  to include ail
 498  housing units,  63  of which  had no record  of termiticide treatment.
 Measurable  levels of chlordane  ranging from a trace O0.2
 ug/M3)  to 38  ug/M3  were found in 335 out of 435 treated
 units  (77%).  The study investigations concluded  that there
was  a  statistical difference  in chlordane  levels  in units
 treated  in  1978  as  compared  to  units treated  in other years.

These  several occurrences of  chlordane contamination of houses
prompted the  Air Force to conduct extensive tests in houses
throughout  the Air Force with a history of chlordaae treatment
and  with ducts  in or beneath  the concrete  slab.   Two studies
were conducted,  the  first in  1975 following discovery of the
contamination at  Wright-Patterson Air Force Base  and the
second following  discovery of contaminated houses at Scott
Air  Force Base.   The 1975 study  included only houses with
preconstruction  treatment and involved sampling 165 houses at


                             IV-12

-------
 five Air Force bases.  Sample results ranged from none  detected
 (<0.2 ug/M3) to 4.1 ug/M^.  A more extensive program was  begun
 in 1980 which included all houses with a history of  chlordane
 treatment regardless of the method of application.   Approximately
 6400 Air Force houses were included in the study.  A three-year
 program was established with those houses treated by subslab
 injection receiving the highest priority .for evaluation.
 Second priority for evaluation were those houses that received
 preconstruction treatment.  Finally, those houses evaluated
 in the 1975 study were to be reevaluatetf.

 The data from the air samples collected since 1973 in the Air
 Force owned houses are summarized in Table IV-3 by house
 construction type and type of chlordane treatment.   The levels
 of chlordane presented in the table represent only the  initial
 samples collected in houses with potential chlordane
 contamination.  Specifically, these houses were those chlordane-
 treated houses constructed over an enclosed crawl space with
 ventilation ducts traversing the crawl space.  Based on these
 monitoring results, the air in 55% of the unitp of siab or
 crawl space construction were found to have n£ detectable
 amounts of chlordane, 40% had detectable levels of < 5  ug/M3
 chlordane, and 5% had levels of >5 ug/M^ chlordane.T

 In a report "Chlordane in Air Force Family Housing:   A  Study
 of Slab-On-Grade Houses, April 1983", the Air Force  noted the
 difference between measurable air levels in slab houses
 treated prior to construction versus houses treated  after
 construction.  An explanation offered for this difference was
 that preconstruction ground treatment provided a considerably
 more uniform ground application than that of post-construction.
 Furthermore, it was stated that high pressure injection
 techniques used in post-construction treatment may have
 resulted in an uneven distribution or concentration  of  chlordane
 under the slab.   Additionally, the possibility exists that the
 pesticide could be forced into cracks in the duct or slab
 during high pressure injection.

 Based on the monitoring data collected, the Air Force noted
•that chlordane intrusion into slab houses peaked during cold
 weather months when heating systems were utilized.   The warm
 air passing through the ducts heated adjacent to chlordane
 treated surfaces increased the vaporization of chlordane.  In
 houses with poorly sealed ductwork, chlordane vapors entered
 the ducts with subsequent distribution throughout the
 ventilation system.

 Air Force investigators have noted that modifications to the
 ventilation system in slab houses decreased airborne chlordane
 concentrations 93-97%.  (Livingston, J.M. et al., 1981)  30.
 The modifications consisted of sealing all~subslab ducting
 and relocating ventilation ductwork inside the house.

                             IV-13

-------
                         TABLE IV-3
            ,'
Summary of Chlordane Air Monitoring Program of Housing  Units
           Located at U.S. Air Force Installations
Type
Construction
Slab
Crawl-Space
Total
Type Total
Chlordane Units
Treatment Sampled
Subs lab
Injection - Post 987
Construction
Subslab Ground
Application - 2818
Precons truct ton
Trench Ing- Post 12
Construction
No treatment
records , some
treatment 210
suspected
Crawl-space soil
application- post
construction
(surface or
trenching) 749
4776

Non-
detectable
255
2145
10
177
37
2624
(54.9%)
IV-U
Number of Chlordane Air Samples
<2uq/M3 <5ug/M3 <10ug/M3 >10ug/M3
493 190 37 12
481 152 31 9
11 00
*
^ 24 8 1- 0
360 206 98 48
1359 557 167 69
(28.5%) (11.7%) (3.5%) . (1.4%)

-------
For example, at Scott Air Force Base slab ducts were sealed
and relocated overhead in 39 houses where chlordane levels
were found to be >_ 4 ug/M3.  The interiors of the houses
were repainted.  A resampling of air levels showed a decrease
in airborne chlordane levels of 93-95% in the reducted units.

As a result of the monitoring data collected and published in the
previously cited April, 1983 report, the' Air Force concluded
the following:  airborne chlordane concentrations are not
likely to exceed 5 ug/M3 in sub- or intxraslab ducted houses
that have only been treated prior to construction: airborne
levels of chlordane in the living area of sub- or intraslab
ducted houses is likely to occur following pesticide treatment
of these dwellings using high pressure injection techniques;
sub- or intraslab ventilation ductwork is the source of
chlordane intrusion into the living area of slab houses; and
sealing sub- or intraslab ducts and relocating the ventilation
ducting overhead will reduce chlordane levels in family
housing living areas by 93-97%.

The Air Force recommended for their installations that "family
housing units with sub- or intraslab ventilation ducting
should not be treated for termites using injection  techniques
unless absolutely necessary to save the structure"; and "if
sub- or intraslab ducted houses have been treated for
subterranean termite control, airborne chlordane concentrations
in the house should be measured to determine if relocating
the ventilation system ductwork inside the structure is necessary".

       U.S. Department of the Navy

The Naval Facilities Engineering Command, Department of Navy
conducted a monitoring program for airborne levels of
terraiticides in Navy and Marine Corps family housing units.
This program was conducted during the 1981-1982 heating season
in nearly 4,000 family housing units which were identified as
units whose construction included sub- and intra-slab heating
or cooling ducts, including single and multi-family units.
As of October 18, 1982, 3957 buildings located at thirty-two
installations across the United States had been sampled and
the samples had been analyzed for levels of chlordane,
heptachlor, aldrin, and dieldrin.

The results from the initial sampling are presented on  the next
page.  In most units where detectable levels of a  termiticide
were found, the termiticide was chlordane since it was  the
probably the termiticide used the most.  Some  samples  from
units also contained heptachlor, aldrin and dieldrin.   However,
the data are only available in aggregate form  and  are  not
                             IV-15

-------
 broken down for each chemical.   The  guideline  levels 'used
 were the National Academy of  Sciences  guidelines of 5 ug/M3
 chlordane,  2 ug/M3 heptachlor,  and 1 ug/M3  aldrin/dieldrin.

 Number of Housing Dnits                Levels of Termiticides
                                        «      v—

      3160 (79.9%)                     Below detection limit

       740 (18.7%)                     Detectable, below NAS
                                        guidelines levels

        57 (1.4%)                       Greater  than HAS
                                        guideline levels


 As a  result of  this  monitoring  effort,  the  occupants of the
 fifty-seven housing  units  having termiticide levels exceeding
 the action  levels were relocated.H


        Department of the Army

 The Department  of the Army is conducting a  monitoring program
 for airborne  levels  in the 19,741 Army housing units that have
 sub- and  intra-slab  heating and  cooling ducts.  Of the 3,061
 housing units sampled as of June, 1983, 27  units had levels
 of chlordane  exceeding the 5 ug/M3 HAS  interim guideline.
 Twenty-three  of these twenty-seven units were  located at one
 installation, and the four remaining units  were located on 2
 different installations (Smith,  Department  of  the Army, personal
 communication).

 Non-Military Termiticide Monitoring Studies

 Five additional monitoring studies are  available.  A brief
 description of each  study  and the results are presented in
Table IV-4.  Four of the five studies monitored for indoor
airborne concentrations of chlordane,  heptachlor, aldrin, or
dieldrin and one  study monitored for chlorpyrifos.  Houses
of the following  types were monitored  in these various studies:
plenum, crawl space, slab  and combination of crawl space/slab
basement.
                             IV-16

-------
                                                            TABLE IV-4

                                      Summary of Non-Military Termiticide Monitoring Studies
Title of Study
and Author
Types of
Samples Collected
Chemical
Analyzed For
Description of
Owe11i ng Men1tored
Study Results/Conclusions
Pesticide Air, Soil, Blood
Residues in
Mouses Utilizing
Forced Air Plenum
Distribution
Systems, I975i
Colorado
Epidemiology
(Pesticides Studies
Center



Chlordane Houses- treated with
Heptachlor cyclodienes
Dieldrin
6 plenum, 1-3 yrs.old
6 plenum, 9-12 yrs.old

Uouses-Not Treated

3 plenum, 1-3 yrs.old
2 crawl space, 1-3 yrs.old
3 plenum, 9-12 yrs.old
1 crawl si>ace,9-12 yrs.old
6 conventional, crawl space
Dieldrin
(ng/M7!

n.d.-12t)
25-467

g

.7-2
1.0
2-99
2
2-46
Chlordane
(ng/M^

7-3654
12-41



7-16
9,53
12-53
c 39
4
27-1513
Heptachlor
(ng/M^T

3-269
.7-27



.6-6
1,3
2-5
5
7-622
                                                        1-3  yrs.old

                                                      5 conventional,crawl  space
                                                        9-12 yrs.old
                                                                  1-108
                                                           -180
                                                        3-25
                                                          Conclusions

                                                          Mean levels of  cyclodienes  in air higher in samples
                                                          fn*n treated plenum houses  than air  samples collected
                                                          fr
-------
                                                            TABLE IV-4

                                      Summary of Non-Military Termiticide Monitoring Studies
Title of Study
and Author
Types of
Samples Collected
Chemical
Analyzed For
Description of
Dwelling Monitored
   Study Results/Conclusions
Airborne
Concentrations of
Chlorpyrlfos
Monitored in
Buildings During
and After Appli-
cation of Formu-
lation M-4328 for
Control.of Suh-
terranoan Termites.
Dew Chemical Company,
1979,
   Air
Chlorpyrifoa
5 Crawl Space Houses
   (Georgia)
                                         4 Basement Houses
                                            (California)
   Crawl Space Houses - Highest
   concentrations found during and
   after application in living areasi
   .003 mrj/M3 and .002 mg/M*
   respectively.
   Basement Houses - Highest
   concentrations found during and
   after application (24 hrs.)
   in living areast  .037 mg/M-* and
   .013 ng/M3, respectively.

Conclusipns - Authors of study
   concluded "that airborne
   concentrations found in
   structures during and after
   treatment are believed to be
   well below*levels expected
   to cause a health concern to
   occupants of treated structures.
                                               • I  il .11.. j
                                                               IV-18

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                                                            TABLE IV-4

                                      Summary of Non-Military Termiticide Monitoring Studies
Title of Study
and Author
Types of
Samples Collected
Chemical
Analyzed For
Description of
Dwelling Monitored
Study Results/Conclusions
Assessment of
Exposure Pollowing
the Use of Aldrin
as a Termiticide
in Homes, Shell
Research Limited,
Sittingbourne
Research Centre,
December, 1982.
  Air
Aldrin,Dieldrin
3 Concrete Slab Houses
   (California)
                                                              3 Crawl Space Houses
24 Hours After Application

<.04-.27ug/M3 (aldrin)
<.04-.06ug/M3 (dieldrtn)

7-56 Days After Application

<.04-.15ug/M3 (aldrin)
<.04ug/M3 (dieldrin)

24 Hours After Application

.09-7.0ug/M3 (aldrin)
<.04ug/M3 (dieldrin)

7-<66 Days After Application
~*~     •

.05-.55UJ/M3 (aldrin)
<.04-.17ug/M3 (dieldrin)
                                                           IV-19

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                                                      Table IV-4

                                      Sumwry of Non-Military Termitlclde Monitoring Studies
Title of Study
and Author
Types of
Samples Collected
Chemical
Analyzed For
Description of
Dwelling Monitored
   Study Results/Conclusions
A Study In So.
California in July
1979 of the Potential
Dermal and Inhalation
Exposure of Applicators
and Other Persons Vt\o
Might Later Enter or
Occupy Areas Treated
with Chlordane Used
Against Subterranean
Termites Under Housest
1979.  Maddy et a\,
California Department
of Food and Agriculture
  Air
Chlordane
3 Crawl Space Houses
3 Slab Houses
 During Application (Lavela in
                       Living Areas)
   Crawli   N.D.-.001 mg/fi*
   Slab:   N.D.

rAfter Application (Levels  in
                      Living Areas)

   Immediately After Application

   Crawli   N.D.
   Slabs   N.D.
             *
   24-48 Hours After Application

   Crawlt   N.D.
   Slab:   N.Q,

   7 Days  After  Application

   Crawlt   .OOl-.OOTrog/M3
   Slab:  ,004-.013mg/M3

   30 Days

   Crawlt   N.D.
   Slab:   N.D.
                                                          IV-20

-------
                                                       Table IV-4

                                      Summary of Non-Military Termltlclde Monitoring Studies
Title of Study
and Author
Types of
Samples Collected
Chemical
Analyzed For
Description of
Dwelling Monitored
Study Results/Conclusions
Applicator and Inhabitant
Exposure to Chlordane
During and After Termiticide
Applications in California
Cahill.W.P. and M.K.Stumphy,
1979. (Velsicol Results o£
Study Cited on p. 1V-19.)
                                                                  Immediately After Application

                                                                   Crawl:   N.n.-.104mg/M3
                                                                   Slab:    N.D.-.0023nq/M3

                                                                  24-48 Hours After Application

                                                                   Crawls   N.D.-.OB4mg/M3
                                                                   Slab:    N.D.-.0017nq/M3

                                                                  22 Pays  After Application

                                                                   Crawlt   .0010-.064mg/M3
                                                                   Slab:    No samples
                                                           IV-21

-------
                                                           TABLE IV-4
                                      Sunmary of Non-Military Termitlcide Monitoring Studies
Title of Study
and Author
Types of
Samples Collected
Chemical
Analyzed For
Description of
Dwelling Monitored
 Study BeauIta/Concluaions
Termite Control
Produces Low Levels
Chlordane and
Heptachlor in Treated
(louses.  Wright, C.G.
and R.B. I,eidy.
Peat Control
Technology, July, 1982
pp.44-45,55.
  Air
Chlordane,
Heptachlor
6 Houses Infested with.
Subterranean Termites
Having Crawl Spaces
or Crawl Space/
Slab Basement
Ranges of Mean Values of 1%
 Chlordane Product Used -
  Inroad lately After Application
  through 1 Year Aftert

    2.75-5.01 ug/M3

Ranges of Mean Values
After Termidea(.5% Chlordane
and .25ft Heptachlor)
Product Used-Immediately After
Application through 1 Year After?
                                                                                          crflordanet   2.34-5.81 ug/M3

                                                                                          Heptachlort  1.00-1.80 ug/M3
                                                           IV-22

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                          CHAPTER V

                    RISK/BENEFIT ANALYSIS


The purpose of this chapter is to summarize th^ risks and
benefits associated with the chemicals used in subterranean
termite control and to then compare these risks, and benefits
for this use.

Summary of Risks

Health Effects

Data indicate that all of the cyclodiene termiticides cause
central nervous system.effects in humans and animals after acute
exposure.  Symptoms include:  dizziness, nervousness, convulsions,
and loss of coordination.  Lindane has also been shown to
be toxic to the central nervous system to animals aqd humans
after both short and long term exposure.     *

The symptoms identified from exposure to pentachlorophenol
include loss of appetite and respiratory difficulties.  Other
effects include pathologic changes in the liver and kidneys.
Embryotoxicity and fetotoxicity was observed in the offspring
of rats.

The primary effect noted as a result of an acute exposure of
humans to chlorpyrifos is a reduction in plasma and red-cell
cholinesterase activity.  Symptoms include:  nervousness,
giddiness, headache, blurred vision, weakness, nausea, cramps,
diarrhea, and discomfort in the chest.  All of the cyclodienes
have induced hepatocellular carcinomas in the B6C3F1 strain
of mice.  However, this response was not observed in rats.
The results of the carcinogenicity tests in rodents administered
lindane have not been  consistenty~with both positive and
negative results reported.  The data available for pure
pentachlorophenol and  chlorpyrifos do not indicate a carcinogenic
effect.  However, technical pentachlorophenol is contaminated
with the carcinogenic  dioxin, hexachlorodibenzo-p-dioxin
(HxCDD).

In the recent investigation of the risks of the termiticides
by the National Academy of Sciences (NAS), it was concluded
that available data are insufficient to determine whether
carcinogenesis is the  critical biological end-point  (health
effect) of concern when humans are exposed to the cyclodienes
and lindane.  However, the NAS report did state that available
animal data allow a comparison to be made of carcinogenic
potential for 5 out of 7 pesticides that were tested under
similar experimental protocols and had similar results -
hepatocellular carcinomas in B6C3F1 strain of male mice.


                             V-l

-------
 On the basis of the ED^o»  the dosage producing  an  incidence  in
 liver tumors 10% above background level,  the  ranking  from
 greatest to least carcinogenic risk  potential would b®  aldrin,
 dieldrin;  heptachlor;  chlordane;  lindane. *5.

 In the HAS report,  it  was  noted that a^ diraci; comparison of
 the carcinogenic potential of chlorpyrifos  with the cyclodienes
 is not possible.  The  reason is that the  available studies on
 the compounds used a different test  protocol  and a different
 strain of  mice (cyclodienes used  B6C3F strain and  chlorpyrifos
 used CD-I  strain).   The authors of the NAS  report  continued
 to point out that if the highest  dose in  the  chlorpyrifos study,
 15.8 ppm,  and the same experimental  conditions  were used,
 estimates  of the proportion of animals that would  be  expected
 to have tumors after exposure to  other pesticides  could be made.
 On this basis, chlordane and lindane would  be expected  to yield
 negative results if tested under  the same conditions  as
 chlorpyrifos and the carcinogenicity potential  of  chlorpyrifos
 cannot be  predicted.   While it is true that the carcinogenicity
 of chlorpyrifos cannot be  predicted,  the  erfects of higher
 doses  of chlorpyrifos  will be depression  of acetylcholinesterase.
 Therefore,  for chlorpyrifos this  dosage can be  considered
 maximum since higher doses would  result in  survival problems
 due to the  acute toxieity  and cholinesterase  depression
 effects associated  with chlorpyrifos.

 Exposure

 A  discussion of possible health effects provides only half of
 the  risk assessment  of a chemical.   The issue of whether or-.
 not  humans  are exposed to  termiticides as a result of their"
 proper,  registered  use "must be  settled in order to assess Lf
 the  use  of  these chemicals poses  an  unreasonable risk to man.

 A  level of  exposure  to any of the termiticides  below  which  .
 there  would  be  no biologic effects has not  been determined.'
 In  its August,  1982  report the  NAS Committee  on Toxicology
 suggested  interim airborne concentration  level  guidelines for
 five termiticides as follows:   chlordane  (5ug/M3), heptachlor
 (2 ug/M3),  aldrin/dieldrin (1 ug/M3),  and chlorpyrifos
 (10  ug/M3).  A guideline was  not  suggested  for  lindane  because
available data  are  not adequate to provide  a  basis for  an
airborne exposure limit and  because  lindane is  not currently
used to control  termites in military  housing.   Similarly, a
guideline was  not set  for  pentachlorophenol because of  the lack
of definitive  data and it  also  is not  now used  to  control termites
 in military housing.
                             V-2

-------
 In  the  NAS  report,  these exposure  guidelines  for each of  the
 termiticides  were  presented  for the  purpose of providing  guidance
 in  estimating the  health risks  of  these  chemicals  in military
 housing.  These  exposure limits were based on.health considerations
 as  well as  the judgement of  scientists participating in the
 NAS study.   It should  be noted  that  the  MAS interim guidelines
 apply  to long-tern  continuous exposure and the NAS Committee
 did not consider short-term  exposure guidelines.  Therefore,
 the guidelines would be applicable to tenaiticide concentra-
 tions measured over an extended period such as a year but
 not to  concentrations  measured  over  shorter periods.

 The Agency  views the interim levels  as useful for guiding
 efforts to  determine on a ca"se-by-case basis whether particular
 individuals  in fact face a health  risk in a particular
 environment.   Such  a determination would often involve testing
 and health  monitoring  beyond the sampling of air concentrations.
 The guidelines will be reassessed  once the further toxicology
 and air monitoring  data are  generated and then reviewed by
 the Agency.                                   *

 The information  on  exposure  to  applicators is limited to  one
 study in  which -air  monitoring was  only done for chlordane.
 The results  indicate levels  ranging  from non-detectable to
 .073 ug/M-3  of  chlordane inside  slab  and  crawl space houses
 up  to 30  days  after application.

 The  data  pertaining to exposure to residents of treated
 dwellings also is primarily  for chlordane and the majority of
 the  data  were  collected in military  housing units in dwellings
 wth  heating/cooling ducts in or below the slab and houses
 with crawl  spaces.  In the aggregate/ military data on the
 sub- and  intra-slab duct houses and  some crawl space houses
 indicate  that  out of 11,794  housing  units tested, 320 (2.7%)
 had  detectable levels  of chlordane,  heptachlor, aldrin or
 dieldrin.

 In  the  most recent  study conducted on civilian houses with
 crawl space or combination crawl space/slab basement—treated
 with chlordane and  chlordane/heptachlor, mean levels of
 chlordane immediately  and up to 1  year after application
 ranged  from 2.34-5.81  ug/M3.  The  respective levels for
 heptachlor were  1.00-1.89 ug/M3.42

Thus, given the  information  available to the Agency at this
 time, residents  of  dwellings of certain  construction types ma
 be  exposed  to  the chemicals  used to  treat the dwellings for
 termite control.
                             V-3

-------
Summary of Benefits

Chlordane  is the most widely used insecticide for subterranean
termite control.  Heptachlor and aldrin are used in much
smaller quantities than chlordane for termite control.
Aldrin, imported in 1981, could capture as much as
25% of the termiticide market in response to chlordane price
increases.   To date, there are no known sales or use of
dialdrin in the United States.  The use of lindane as a
termiticide seems to be limited to peat control firms in
California.  Pentachlorophenol is used only for specific
termite control problems where termites have been associated
vith decay or' direct application to infested wood structures.
It is not used for subsurface applications.  A few thousand
pounds of chlorpyrifos were sold in 1980, primarily in
California.

Available data indicate that chlordane is presently the most
effective termiticide.  Heptachlor, aldrin, and dieldrin are
comparable in effectiveness.  Dieldrin was rarely used as a
termiticide because of its high price..  Chldtpyrif*os seems
to be the most promising new compound.  However, to obtain
equivalent, pest control cost is at least twice that of
chlordane/heptachlor/aldrin.

Within the pest control industry, the choice between cyclodienes
appears to be one of personal preference rather than documented
advantages and disadvantages of the individual chemicals.

No national data have been compiled and published on the costs
society has incurred as a result of the subterranean termite.
A number of estimates of the annual national cost, including
both the loss due to termite damage and the cost of control
have been noted in the literature.  The most frequently cited
figure is S500 million.  The Agency has estimated the potential
cost of termite infestation by extrapolating from data on
control and damage repair costs in eleven states.  This
nationwide estimate, inflated to 1980 dollars, is $753.4
million.  If multi-family, commercial, and public dwellings
are considered, the estimate is-expanded to $1.022 billion.

In summary, the benefits for the termiti.cides, particularly
the cyclodienes, are very high.

Risk/Benefit

After consideration of the available  information on the risks
and benefits for the termiticides the Agency concludes that
the benefits from their use to control subterranean termites
are extremely high.
                             V-4

-------
The risk assessment for these chemicals is incomplete because
of the lack of definitive data on the extent of human exposure,
the amount of exposure, and, aost importantly, data on the
critical biological end point (health effect) in humans
exposed to these pesticides.  At this time in assessing the
risks and benefits associated with the total national use of
the termiticides based on available data, and considering the
lack of data outlined above, the Agency finds that the benefits
from the use of the currently registered tenaiticide products
outweigh the potential risks.  The Agency, recognizes that in
individual cases where tenaiticides were Improperly applied
or misused in treating a residential dwelling, the risks
from exposure to the chemicals nay exceed the benefits.
                             V-5

-------
                         CHAPTER VI

                        CONCLUSIONS
As a result of the analysis of the information on the risk
and benefits associated with the use of the termiticides,
the Agency has concluded that the benefits, particularly
for the cyclodienes, are very high and the cyclodienes are
the most effective chemicals currently registered for
termite control.  The Agency cannot complete a risk assessment
of the termiticides due to a lack of Definitive health and
exposure data.

The information on possible health effects associated with
the use of the termiticides is summarized in Chapter IV of
this document.  One major-inadequacy of the existing tenniticide
data base is that it consists only of dietary exposure
studies.  In the case of tenniticide use, inhalation is
clearly the route of exposure to be considered in assessing
the risk.  Moreover, in the recent tenniticide risk review
conducted by the National Academy of Sciences, it was
concluded that the data were not sufficients© determine
whether carcinogenicity is the critical biological end-point
(health effect) in humans exposed to the termiticides.
The Agency accepts this conclusion and has determined that
additional toxicology data are needed to assess the risks
to humans exposed to termiticides.

Additionally, the Agency has concluded that exposure is
the principal issue in assessing the health risks posed by
the use of the termiticides.  The Agency has recently
reviewed monitoring data that showed contamination of living
quarters following termite treatment.  The data consist
mostly of contamination incidents in military housing
units constructed with sub- and intra-slab ducts.  To a
limited extent, some contamination incidents were also
reported in military housing units with crawl spaces.
Information is not available on the tenniticide treatment
use history for the monitored mi-litary housing units or
for other types of housing structures.  Therefore, it
cannot be determined if the tenniticide contamination
problem is confined to houses with sub- and intra-slab
ducts and, possibly, crawl spaces and, if applied properly,
if contamination in these structures will always occur.
However, from the available monitoring data and individual
incidents reported, exposure to the termiticides may occur
in a low percentage of houses of specific construction types.

The risk assessment for these chemicals is incomplete because
of the lack of definitive data on the extent of human
exposure, the amount of exposure, and, most importantly
data on the critical biological end point (health effect)
in humans exposed to these pesticides.  At this time in
                            VI-1

-------
 assessing the risks and benefits,associated with  the  total
 national use of the termiticides  based  on  available data,
 and considering the lack of  data  outlined  above,  the  Agency
 finds  that the benefits from the  use of the currently
 registered termiticide products outweigh the potential risks.

 The Agency recognizes that in individual cases where
 tsrmiticides were improperly applied or misused in treating
 a  residential dwelling, the  risks  from  exposure to the
 chemicals may exceed the benefits*           ,
                                      *      ^
 The Agency has developed an  action plan to obtain the
 necessary toxicology and exposure  datea  to  fully assess the
 health risks and determine further regulatory action.
 Given  the uncertainties with respect to human health  effects
 and exposure, the immediate  short  term  actions that have been
 taken  focus on reducing possible human  exposure to the
 termiticides and obtaining additional information on  health
 affects  and exposure.

 Label  Improvement Program

 The Label Improvement  Program (LIP) that is being carried
 out by the  Registration Division, Office of Pesticide
 Programs  has resulted  in the addition of several statements
 to  labels of products  registered for the control of termites.
 These  statements are designed to prevent potential hazards
 by  reducing the  possibility  of misuse and, consequently,
 exposure.   A number of statements specifically caution the
 application of termiticides  near heating ducts, near  domestic
 water  supplies (cisterns,  private wells, etc.), and around
 structures  containing  sub-floor crawl spaces.

 The majority of  registrants  have compiled  with the LIP.
 The Agency  is currently notifying the remaining registrants
 regarding compliance with  the  LIP for termiticides.

 Restricted  Use Classification

 Currently,  federally registered products containing chlor—
dane,  heptachlor, aldrin,  dieldrin, lindane, pentachloro—
 phenol, and  chlorpyrifos  are  noJ: classified as restricted
use pesticides.   That  is,  products containing the above
 listed chemicals  are available to homeowners for purchase
and use, and are  not required  to be applied by certified
applicators.
                            VI-2

-------
 Six states have already taken regulatory  action  to  restrict
 the use of chlordane  to application  only  by  certified
 applicators or individuals  under their direct  supervision.
 These  states are:   Connecticut,  Hawaii, Massachusetts,
 New Mexico (products  with concentrations  >5%), New Jersey
 (effective 12/83),  and  Vermont.

 The Agency has identified restricting  the use  of  the
 termiticides as a measure to  alleviate possible misuse of
 these  chemicals and,  thereby,  reduce human exposure.  The
 Agency is  contacting  state  regulatory  agencies to obtain
 information on incidents of misuse that would  support the
 classification of restricted  use.    *

 Prohibit Use jpf Cyclodienes on Specific Structures

 Measures concerning the use of the cyclodiene  termiticides
 on  certain types of structures have  already  been  taken by
 registrants and the National  Pest Control Association
 (NPCA).  The manufacturer of  chlordane has voluntarily added
 to  the label the statement  not to use  chlordane on plenum
 housing.   NFCA also instructs  its membership not  to treat
 plenum houses with  the  cyclodienes.  Additionally^ NPCA
 cautions its members  to locate ductwork prior  to  treatment
 of  houses  with sub- and intra-slab ducts.

 The Agency is currently evaluating the measures outlined
 above  in light of available monitoring data  and monitoring
 data that  is being  requested  by  the  Agency.

 Concurrent with pursuing the above short-term measures,
 the Agency has identified data that  are needed to complete
 a qualitative and quantitative risk  assessment on each of
 the._termiticides and  determine if additional regulatory
 action  is  necessary.

 Toxicology Data

As  stated  previously, the toxicology data available on the
 termiticides  consists of animal  studies where the route of
 exposure is  dietary.  Inhalation is  the route of exposure
of concern  in  dealing with  the problems of termiticide
 use.  Additionally, the critical biological  end point as a
 result of  exposure  to these chemicals  cannot be determined
 from existing  data.  Therefore,  the Agency is  requiring
registrants of  termiticides in the cluster considered in this
 report to  submit the  following data  under the  authority of
Section 3(c)(2)(B)  of the Federal Insecticide, Fungicide, and
Rodenticide Act:  mutagenicity tests and  a subchronic
 inhalation study.
                            VI-3

-------
The battery of mutagenicity tests would consist of the
following (in vivo activation): host.mediated assay with
bacterial indicator or sex-linked recessive lethal assay
in Drosophila; chromosomal aberrations assay in bone marrow
cells, or a micronucleus test, or a sister-chromatid exchange
teat;'unscheduled DNA synthesis in hepatocytes from treated
rodents; and cell transformation in primary cultures from
treated hamsters.  These specific studies -will allow for
an evaluation of mutagenic risk and for assessment of oncogenic
risk for the cyclodienes.

A subchronic inhalation study will provide data on the critical
biological end point after exposure to these chemicals.
The Agency reserves the right to request chronic inhalation
studies pending the results and analysis of the subchronic studies.

Monitoring Data

The Agency is requiring, under the authority of Section
3(c)(2)(B) of the Federal Insecticide,.Fungicide, and
Rodenticide Act, registrants of termiticides to submit
indoor air monitoring data of dwellings treated with a
tenniticide.  The dwellings included in th{0 monitoring
study should be of different construction types:  sub-
and intra-slab duct, crawl space, full basement.  A treatment
history sh.ould also be available for each of the houses in-
cluded in the study.  These data will then be used to determine
if exposure to the dwelling occupant occurs when termiticides
are applied according to current label directions and
application rates.

Concurrent with the requirement for registrants to submit
monitoring data, the Agency is contacting several private
researchers and state regulatory agencies for any monitoring
data that they may have collected as a result of complaints
and/or enforcement efforts.
                            Vl-4

-------
                         BIBLIOGRAPHY


1.    Birch, Shelton R.  Memo to Lois Rossi regarding
           data from Air Force monitoring study of airborne
           concentration of termiticides in Air Force housing units.
           October 29, 1982.

2.    British Crop Protection Council.  British Crop Protection
           Council 1974 Pesticide Manual:  Basic Information
           on the Chemicals Used as Active Components of Pesticides.
           Edited by H. Martin and C.B^ Worthing.   4th Edition.
           London, England.

3.    Cahill, W.P. and M.K. Stumphy.  Applicator and Inhabitant
           Exposure to Chlordane During and After Termiticide
           Applications in-California.  Velsicol Chemical
           Corporation.  1979.  Confidential.

4.    Colorado State University.  National Household Pesticide
           Usage Study, 1976-1977.  Addendum I:  Household
           Usage and Storage of Chlordane-Containing  Products.
           Epidemiologic Pesticide Sjtudies Center,
-------
 12.   Maddy, K. et  al.  A  Study  in Southern California'in
           July, 1979 of the Potential Dermal and ZnhalaticTn
           Exposure of Applicators and Other Persons Who
           Might Later Enter or occupy Areas Treated with
           Chlordane Used Against Subterranean Termites
           Under Bouses, California Department of Pood and
           Agriculture, Sacramento, California.  1979.

 13.   Merck Index.  Ninth Revision.        •.

 14.   Messerschmidt, M. Olav.  Letter-to Loil Rossi regarding
           EPA Risk/Benefit Analysis of Termiticides.
           June 9,  1983.

 15.   National Academy of Sciences.  Committee on Toxicology.
           An Assessment of the Health Risks of Seven Pesticides
           Used for Termite Control.  Washington, D.C. 1982..
                         T»
 16.   National Academy of Sciences.  Committee on Toxiciology.
           Chlorpyrifos Risk Assessment and Inhalation
           Exposure Limits.  Washington, D.C.  1978.

 17.   National Academy of Sciences.  Subcommittee on Chlordane
           in Military Housing of the Committee on Toxicology.
           Chlordane in Military Housing prepared for the
           United States Air Force/  Washington, D.C. 1979.

 18.   National Pest Control Association.  The Structural Pest,
           Control  Industry, Description and Impact on the
           Nation.  NCPA, 1981.

 19.   Nolan, R.J.; Rick, D.L.; Preshour, N.L. and J.H. Saunders.
           Chlorpyrifos:  Pharmacokinetics in Human Volunteers.
           (In Press)

 20.   Office of the Surgeon, Headquarters Air Porce Logistics
           Command, Wright-Patterson Air Porce Base, Ohio.
           Summary and Comparison of Two-hour Baseline Chlordane
           Air Sampling Results prom Air Porce Military Family
           Housing.  1975.

 21.   Regional Environmental Health Laboratory, Kelly Air Force Base,
           Technical Report: -Chlordane Contamination of
           Government Quarters and Personal Property, Webb
           Air Force Base, Texas.  1970.

22.   Shell Research Limited, London.  Assessment of Exposure
           Following the Use of Aldrin as a Termiticide in Homes.
           December, 1982.  Confidential.

23.   Shindell,  Sidney.  Letter to Will Brocker, Velsicol Chemical
           Corporation regarding EPA Risk/Benefit Analysis of
           Termiticides.   June 3, 1983.


                            VI1-2

-------
 24.    Telang,  S.;  Tong,  C.r  and G.M. Williams.  Epigenetic membrane
            effects of  a  possible  tumor promoting type on
            cultured liver cells by  the non-genotoxic organochlorine
            pesticide chlordane and  heptachlor.  Carcinogenesis.
            Vol.  3, No. 10, pp. 1175-1178, 1982.

 25.    Tenniticides in  Building Protection.  Proceedings of a
            Workshop, September 22-23, 1982, Washington, D.C.,
            1983.   Edited by  A. Khasawinah, Velsicol Chemical
            Corporation,  Chicago,  Illinois.    *

 26.    United States Department of the Air Force.  Chlordane
            Contamination in  Wherry  Housing, Scott Ai'r Force
            Base,  Illinois. 1979.

 27.    United States Department of the Air Force.  Office of
            the Surgeon,  Headquarters Air Force Logistics
            Command,  Wright-Patterson Air Force Base, Ohio.
            Summary and Comparison of Two-Hour Baseline Chlordane
            Air Sampling  Results From Air Force Military Family
            Housing.  May 13, 1975.

 28.    United States  Air  Force Occupational and Environmental
            Health  Laboratory, Aerospace Medical Division,
            Brooks  Air Force  Base, Texas.  Chlordane in Air
            Force Family  Housing - A Study of Houses Treated Prior To
            Construction.  June 1982.

 29.    United States  Department of the Air Force.  USAF
            Environmental Health Laboratory, Kelly Air Force
            Base, Texas.   Chlordane Contamination of Government
            Quarters  and  Personal Property, Webb Air Force Base,
            Texas.   March 12, 1970.

 30.    United States  Department of the Air Force.  USAF
            Occupational  and  Environmental Health Laboratory,
            Aerospace Medical Division, Brooks Air Force Base,
            Texas.  Chlordane in Air Force Family Housing:
            A Study of Slab-On-Grade Houses, April 1983.

31.    United States  Environmental Protection Agency.  Ambient
            Water Quality  Criteria for Aldrin/Dieldrin.
            Office of water Regulations and Standards, Washington,
            D.C. 1980.

32.   United States  Environmental Protection Agency.  Ambient
           Water Quality Criteria for Chlordane.  Office of
           Water Regulations and Standards, Washington, D.C.
            1980.

33.   United States  Environmental Protection Agency.  Ambient
           Water Quality Criteria for Heptachlor.  Office of
           Water Regulations and Standards, Washington, D.C.
           1980.
                            VI I-3

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34.   United States Environmental Protection Agency.   Creosote,
           Inorganic Aresenicals, Pentachlorophenol Position
           Document 2/3.  Office of Pesticides and Toxic
           Substances, Washington, D.C.  1981.

35.   United States Environmental Protection Agency.
           Comparative Benefit Analysis  of  the Seven  Chemicals
           Registered for Use Against Subterranean Termites.
           Benefits and Field Studies Division, Office
           of Pesticide programs, Washington? O.C. 1981.

35o   United States Environmental Protection Agency.
           Lindane Position Document No. 2/3.   Office of
           Pesticides and Toxic Substances, Washington, O.C.
           1980.

37.   United States General Accounting Office.  Need  for  a
           Formal Risk/Benefit Review of the Pesticide Chlordane.
           Report No. B-199618.  1980.

38.   Velsicol Chemical Corporation.  Report of Epidemiologic
           Study of the Employees of Velsicol Chemical Corporation
           Plant, -Memphis, Tennessee.  January, r§52  - December,
           1979.  1980.

39.   World Health Organization, International Agency for
           Research on Cancer.  IARC Monographs on the Evaluation
           of the Carcinogenic Risk of Chemicals to Humans.
           Some organochlorine pesticides.   Volume 5, 1974.
           pp. 25-38; pp. 125-156.

40.   World Health Organization, International Agency for
           Research on Cancer.  IARC Monographs on the Evaluation
           of the Carcinogenic Risk of Chemicals to  Humans.
           Some Halogenated Hydrocarbons.  Volume 20, October 1979,
           pp. 45-65, pp. 129-154, pp. 195-239, pp.  303-325.
                                                           •I2-
41.   World Health Organization, International Agency for Research
           on Cancer.  IARC Monographs on the Evaluation  of.Jthe
           Carcinogenic Risk of Chemicals to Humans.   Chemicals,
           Industrial Processes and Industries Associated with
           Cancer in Humans.  IARC Monographs, Volumes 1  to 29.
           IARC Monographs Supplement 4.  October, 1982.

42.   Wright, C.G. and R.B. Leidy.  Termite Control  Produces
           Low Levels Chlordane and Heptachlor in Treated Houses.
           Pest Control Technology, July, 1982, p.44-45,55.
                                   VI I-4

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                    APPENDIX 1
PHYSICAL.AND CiEMICAL PROPERTIES OF TEFMITICIDES
CHUTRDANE

chemical name:


Cnera. Abstr.
 Services Reg. No.:

molecular weight:

color:

odor:

melting point:

boiling point:

solubility:



physical state:

density:

vapor pressure:

viscosity;

stability:
          1,2,4,5,6,7,8,8-Octachlcro-4,7-tnBthano-
          3a,4,7,7a-tetrahydroindane

          57-74-9
          409.8

          amber

          chlorine odor

          106-107QC (cis-isoner);
          104-105°C (trans-isoner);
          decomposes at 1 atm.

          Insoluble in vater; soluble in most
          organic solvents, including petroleum
          hydrocarbons

          liquid

          d2S 1.59-1.63

          0.00001 nm at 25<=C

          75-120 centistokes at SSPT

          loses chlorine in presence of alkaline
          reagents; should~not be femulated with
          solvents, carriers, diluents, emulsifiers,
          which have alkaline reactions;

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HEPTK3LDR
 chemical nsne:

 Chan.  Abstr.
 Services Reg.  No.
 molecular weight:
 molecular fonajla:
 color:
 odor:
 melting  point:
 boiling  point:
 solubility:

physical stater
density:
vapor pressure r
viscosity:
stability:
1,4,5,6,7,8,8a-Heptachlorc-3a,4,7,
7a-tetrahydrc~4,7-jnsthanoindane
76-44-8
373.5
white (pure); light tan (technical)
canphor-lifre odor
135-145QC at 1-1.5 asa
practically insoluble in water*
soluble in ethanol, xylener carbon
tetrachloride, acetone, and benzene
crystalline solid
1.57-1.59
0.0003 mm at 25°C
not applicable
stable in daylight, air, moisture,
and moderate heat; oxidized biologically
to heptachlor epoxide;

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 ALDRIN
 chemical name:

 Chem.  Abstr.
  Services Reg.  No.
 molecular weight:
 molecular formula:
 color:
 odor:
 melting  point:
 boiling  point:
 solubility:

 physical state:
density:
vapor pressure:
viscosity:
stability:
 1,2,3,4,10,10-Hexachlorc-l,4,4a,5
 8,8a-hexahydro-i,4,5,8-dimethanonapthalene
 309-00-2
 364.9
white  (pure); tan  to dark brown  (technical)
ehefaical°liXe odor
104-104. 5°C
deu.mgjuaes at 1 am.
very soluble in nest organic splventsl
practically insoluble in water;
crystalline solid
1.70 at 20QC
2.31 x 10-5 am Bg  at 2QQC
not applicable for solid
stable with alkali and alkaline-
oxidizing agents;  not stable with
concentrated mineral acids, acid catalysts,
acid-oxidizing agents, phenols, active metals

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DIcIDRIN
chemical nans:

Gieau Abstr.
 Services Reg. No.
iBolacular weights
nolecular fonsula:
color:
odor:
melting point:
boiling point:
solubility:


physical state:
density:
vapor pressurei
viscosity:
stability:
1,2,3,4,10,10-Hexachlorc—6,7-epoxy
1,4,4a,5,6,7,8,8a-octahydro-l ,4,5,8
dimethanonaphthalene
60-57-1
380.9
      (pure)r light tan (technical)
         ^>
odorless
176-1770C
           at 1 atsu
practically insoluble in water;
slightly soluble in 'petroleum oils;
Moderately soluble in acetone;
soluble in aronatic solvents;
crystalline solid
1.70 at 2QQC
1.78 x 10~7 nan Bg at 20«C
not applicable for solid
stable in alkalis and in acids except
strong mineral acids;

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CHLORPYRIFOS

chemical  name:


Chen.  Abstr.
 Services Reg. No.

molecular weight:

molecular formula:

color:

odor:

melting point:

boiling point:

solubility:

physical  state:

density:

vapor pressure:

viscosity:

stability:
0,O-Diethyl O-(3,5,6-trichloro-2-
pyridyl) phosphorothioate
2921-88-2

351
white

mild mercaptan odor

42.5-43°C




soluble in most organic solvents
                      t

crystalline solid




1.87 x 11T5 nn Hg at 25°C




stable under normal storage conditions

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