PEST CONTROL IN FOOD PROCESSING PLANTS
AND OTHER FOOD HANDLING AREAS
Hazardous Materials Advisory Committee
Environmental Protection Agency
February 1972
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ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D. C. 20460
AUG 25 1971 of net or THE
ADMINISTRATOR
Subject: Request for Hazardous Materials Advisory
Committee to Review Pest Control in Food
Processing Plants and Other Food Handling
Areas
To: Hazardous Materials Advisory Committee
I am persuaded that a potentially serious situation has
developed as a result of a series of individual regulatory
actions, each one of whifh seems to have been well justified,
but which, in toto, have resulted in inadequate control
methods being available to protect foods from pest contamina-
tion in food handling and processing plants. Pest regulatory
actions, applied on a use-by-use basis, have resulted in
increasing the likelihood of food contamination by pests and
vermin. Will you review this entire situation and advise me
as soon as practical as to what guidelines and policies you
believe to be desirable to assure a proper balance between
the need for pest control and the potential hazards from the
chemicals involved?
In considering this matter, I would encourage you to consider
all routes of exposure to the pesticides in question, all
methods of pest control available including all recognized
pesticide application techniques, and any and all other factors
you consider relevant. Your suggestions may be as innovative
as you believe desirable. They may distinguish between dif-
ferent chemicals and different application techniques. Though
you may wish to suggest additional research, I hope you will
also recommend actions that can be taken based upon current
knowledge.
We will provide you with reasonable staff services and endeavor
to provide specialized consultant services as you deem desirable
Though I cannot set a firm goal for your report, I hope you
will bear in mind the urgency of the situation and expedite
your report accordingly. I have stated that we expect your
report within 6 months.
William D. Ruckelshaus
Administra tor
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HAZARDOUS MATERIALS ADVISORY ^COMMITTEE
Dr. Emil M. Mrak Chairman
Chancellor Emeritus
University of California at Davis
Dr. William J. Darby Cochairman
President, Nutrition Foundation
and Chairman, Department of
Biochemistry
Vanderbilt University
Mr. Errett Deck
Chairman, Legislative Committee
Association of American Pesticide
Control Officials
Washington State Department of
Agriculture
Dr. Norton Nelson
Director, Institute of
Environmental Medicine
New York University Medical
Center
Dr. Leon Golberg
Scientific Director, Research Professor
of Pathology
Institute of Experimental Pathology
and Toxicology
Albany Medical College
Dr. Ruth Patrick
Chairman, Department of
Limnology
Academy of Natural Sciences,
Philadelphia
Dr. Frank Go1ley
Executive Director and Professor of
Zoology, Institute of Ecology
University of Georgia at Athens
Dr. William R. Rothenberger
Agricultural Production
Specialist
Frankfort, Indiana
Dr. Gordon E. Guyer
Chairman, Department of Entomology
Michigan State University
Dr. Paul E. Johnson
Executive Secretary, Food and
Nutrition Board
National Academy of Sciences
Dr. Earl Swanson
Professor of Agricultural
Economics
University of Illinois
Dr. Wilson K. Talley
Assistant Vice President
University of California
Berkeley
Mr. William Murphy
President, Campbell Soup Company,
Camden
Dr. W. Leonard Weyl
Chief of Surgery
Northern Virginia Doctors
Hospital
McLean, Virginia
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Regular Consulcants
Dr. Dale R. Lindsay
Associate Director of Medical
Allied Health Education
Duke University
and
Dr. Caro Luhrs
Medical Advisor to the Secretary
U. S. Department of Agriculture
Mr. James G. Terrill, Jr.
Manager, Special Projects
Environmental Systems Department
Westinghouse Electric Company,
Pittsburgh
Staff
Dr. William S. Murray
Staff Director
Mr. W. Wade Talbot
Executive Officer
Mrs. Alva J. Ware
Clerk-Typist
Mrs. Dorothy I. Richards
Administrative Assistant
Miss Carolyn L. Osborne
Clerk-Stenographer
Miss Ruby D. Armstrong
Secretary
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CONSULTANTS
ON
PEST CONTROL IN FOOD PROCESSING PLANTS
AND OTHER FOOD HANDLING AREAS
List of Contributors
Conveners and Members of the Hazardous Materials
Advisory Committee
Dr. Emil M. Mrak
Chancellor Emeritus
University of California at Davis
Dr. Gordon E. Guyer
Professor and Chairman of the Department of Entomology
Michigan State University
Consultants to the Hazardous Materials
Advisory Committee
Mr. Robert M. Brown
President
National Sanitation Foundation
Dr. Arnold E. Denton
Vice President, Technical Administration
Campbell Soup Company
Dr. Stanley P. Mayers, Jr.
Professor of Health Care Planning
College of Human Development
Pennsylvania State University
Dr. Paul W. Purdom, Sr.
Professor of Environmental Engineering
Drexel Institute
Dr. Herbert F- Schoof
Chief, Technical Development Laboratories
Center for Disease Control
Dr. Philip J. Spear
Research Director
National Pest Control Association
Dr. Philip L. White
Director, Department of Foods and Nutrition
American Medical Association
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Resource Contacts
Mr. Samuel Billings
Pesticides Regulation Division
Environmental Protection Agency
Mr. William F. Bower
Food Service Sanitation Branch
Food and Drug Administration
Dr. Robert L. Caswell
Pesticides Regulation Division
Environmental Protection Agency
Dr. Murray Cooper
Insect Control and Research, Inc.
Dr. Thomas H. Harris
Pesticide Tolerances Division
Environmental Protection Agency
Mr. Lessel L. Ramsey
Office of Compliance
Food and Drug Administration
Other Representatives
Mr. Bart
CAP, Inc.
Mr. Garth Bischoff
Mark Chemical Company
Mr. Glenn V. Brauner
National Canners Association
Mr. Vernon Cordell
National Restaurant Association
Mr. Darrell F. Jones
General Mills, Inc.
Mr. Joseph Kahn
Ritt Consolidated Industries, Inc.
Mr. Richard A. McDonald
Paper Products, Inc.
Mr. Robert Russell
Orkin Exterminating Company, Inc.
Dr. Michael P. Shinkle
Orkin Exterminating Company, Inc.
Dr. M. J. Sloan
Shell Chemical Company
Mr. Vern E. Walter
Bruce Terminix
Mr. Seth Wissman
Athena Corporation
Mr. Robert Zeender
Blair Mansion Inn
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POLICY AND GUIDELINES FOR
PEST CONTROL IN FOOD PROCESSING PLANTS
AND OTHER FOOD HANDLING AREAS
SUMMARY
A basic need for pest control in food handling
areas, and the attendant role of pesticides, is
acknowledged. However, minimization of pesticide
use and human exposure is to be encouraged through
local inspection and education in sanitation and
other non-pesticide approaches. Since neither
assurance of absolute safety nor of harm from
incidental exposure is normally available, a risk
must be judged acceptable through an assessment of
the risk-benefit equation. Labeling should,
therefore, reflect risks and benefits associated
with product use. Availability of a range of
pesticide products should be encouraged. Residual-
type pesticides are particularly important; selected
use of aerosols and vapor dispensing devices are
appropriate under selected situations.
Procedures for the maintenance of records of pesticide
use in food handling establishments should be
developed. Dietary intake residue data are needed
to meet legal requirements and to insure that dietary
intake does not exceed that stipulated by existing
food additive tolerances.
The Administrator requested the assistance of the Hazardous Materials
Advisory Committee in the review of the subject problem for advice on
policies and guidelines to assure a balance between the need for pest
control and potential hazards of attendant chemicals. The following
policy and guidelines were recommended by consultants and are hereby
endorsed by the Hazardous Materials Advisory Committee to the
Administrator.
Food processing plants and other food handling areas are exemplified
by facilities in which food, or food ingredients, are commercially
prepared for further processing or for packaging for wholesale or
retail markets. Also included are grocery stores, institutional
kitchens and service areas, restaurants and snack facilities, trans-
port vehicles and warehouses.
Suggested Policy
As used here, policy is considered a course of action or objective. "The
following are related suggestions that should be considered in any
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re-evaluation or restructuring of policy relative to pest control
in food handling establishments.
(a) Pesticides must not be recognized as substitutes for
sanitation. The need for pesticides should be
minimized by pest prevention through effective
sanitation, exclusion, and non-insecticidal controls.
(b) There are problems of pest control that can be dealt with
only through properly selected and applied pesticides.
(c) The amount of pesticides applied should be appropriate to
minimizing human exposure via inhalation and ingestion
as well as maximizing control of pests.
(d) The selected applications of residual type pesticides are
necessary for the protection of food establishments
from noxious pest infestations. Alternate application
techniques in most instances may be less desirable and
might not provide adequate protection and in some cases
could provide undesirable residues.
(e) The selected use of continuous aerosols and vapor dispensers
such as plastic strips for slow release are appropriate
under selected situations to prevent the annoyance by
pests and possible food contamination by them.
(f) Additional food additive regulations may not be required,
since the proposed use must be so controlled as to
permit no greater final dietary intake than that already
stipulated by existing tolerances.
Suggested Guidelines
Guidelines, as herein referred to, are specific approaches or steps in
the implementation of policy.
(a) It is suggested that increased emphasis be directed to
education and the effective inspection and regulation
of sanitation in food handling establishments. Local
agencies should be encouraged, appropriately. This
should include preventive sanitation in construction,
physical maintenance and cleaning of facilities and
equipment used in the transportation, processing, storage,
preparation and service of food.
(b) Use of pesticides in food establishments should be directed
to minimizing both the amount of pests and pesticides
reaching food. The choice of pesticides and their
regulation should, therefore, be based on evaluation of
benefit to hazard—not on the basis of toxicity of
compounds alone I There should be encouragement of the
registration of the widest range of control products %>r
pest control in food handling areas.
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(c) Pesticides should be used in dosages no greater than that
•sufficient to eliminate the pest hazard. Through the
mechanism of labeling requirements, there should be
insurance that each product describes its benefits and
risks and that—in food handling areas—details of
application be included (example: cubic and square
foot limitations and time of day to be used in
restaurants).
(d)
While recognizing the importance of labeling, it should not
be a substitute for assurance of compliance.
(e) Representative residue data should be obtained for food
exposed in areas treated with insecticides, either in
response to food additive petitions or upon the
initiative of the Pesticides Regulation Division. Food
additive regulations (Food, Drug and Cosmetic Act,
Section 409) are needed in order to prescribe the safe
conditions of use of pesticides in food handling
establishments. Such residue data are needed to meet
. legal requirements and to ensure that dietary intake
does not exceed that stipulated by existing food
additive tolerances.
(f) Examples of applicable uses of continuous aerosols and vapor
dispensers include their use in switch boxes, utility
and rest rooms, non-food areas and in food areas where
they will be programmed for periods of disuse.
(g) Procedures should be developed for the maintenance of records
regarding all uses of pesticides in food handling
establishments, and such information should include the
name of materials and amount used as well as where and
when used, and the purpose for which it was applied.
(h) It is believed that the "rule of reason" concept should be
included as a component part of these guidelines:
Since it is difficult to unequivocally prove a negative (example: that
a low-level exposure does not adversely affect humans), there must be
a reasoned basis for evaluating risk versus benefit. There comes a
time, the Supreme Court has said, when the government administrator of
a law must apply the "rule of reason." The basis for this approach is
provided as background in the following: Prudence counsels that we
should regard all substances foreign to man's diet, including pesticide
chemicals, as potentially poisonous and deleterious. It is generally
recognized by scientists that a showing of safety cannot be absolute,
that the absolute safety of a pesticide chemical cannot be demonstrated.
Philosphically, the scientist is confronted with the ancient enigma of
proving the negative, an acknowledged impossibility. Toxicological methods,
like the analytical methods of chemists, are designed to detect a
response; for the toxicologist, a discernible deleterious effect on the
animal and for the chemist, usually an instrumental reading. Thus, a
toxicological method is inherently limited by the sensitivity of the
observation just as the analytical method is inherently limited by the
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sensitivity of the particular technic, including that of the instrument.
It is likely that millions of molecules of a substance are ordinarily
required for a detectable response in either case.
In no event can a toxicological method unequivocally demonstrate that
the effect of a pesticide chemical is zero or the analytical method
unequivocally shows that the level of such chemical is zero. The zero
for the analytical chemist and the no-effect level (zero) for the
toxicologist may be approached ever so closely but never reached, or,
if reached, never proved in the absolute sense.
Moreover, the toxicologist recognizes that no species of animal responds,
qualitatively and quantitatively, exactly like man; and he also recognizes
that data from industrial exposure, accidents, or even short-term
controlled experiments on man are not absolutely predictive of the
long-term effects on man. Thus, there is a risk, be it however so slight
in some cases, in translating animal data to man or even in relying on
human data and using the common safety factors. Obviously, prudence and
common sense dictate that human exposure to pesticide chemicals should
be minimized in order to minimize the risk and that none should be
allowed unless there is a recognizable benefit to society.
In short, the responsibile scientist cannot ignore even small amounts of
a pesticide chemical or hold that these amounts are absolutely safe;
but, on the basis of adequate data, he can make an informed judgment as
to the degree of risk and where the data warrant, he can advise that the
degree of risk is acceptable, that the pesticide usage and tolerance are
legally safe (within the meaning of the law), not absolutely safe.
Title 21 CFR*, Section 121.l(i) in the regulations sets out our legal
definition of safe. Originally, it read: "Safe means that there is
convincing evidence which establishes with reasonable certainty that no
harm will result from the intended use of the food additive." In the
Federal Register of June 25, 1971, this definition was revised as follows:
"Safe means that after reviewing all of the available evidence.. .the Food
and Drug Administration can conclude that no significant risk of harm
will result when the substance is used as intended."
Those in agencies traditionally concerned, such as the Food and Drug
Administration, are cognizant of the fact that insects and other pests
must be controlled in food processing and food service areas, not only
because of aesthetics but because of the potential for spreading disease.
* Code of Federal Regulations
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INFORMATION REVIEWED BY CONSULTANTS
ON PEST CONTROL IN FOOD
PROCESSING PLANTS AND
OTHER FOOD HANDLING AREAS
Alford, H. G. August 19, 1968. Notice to manufacturers, formulators,
distributors, and registrants of economic poisons on status of residual
type insecticide products bearing directions for use in food processing
plants. U. S. Department of Agriculture. Washington, D. C.
Alford, H. G. (undated draft). Notice to manufacturers, formulators,
distributors, and registrants of economic poisons on status of residual
type insecticide products bearing directions for use in food processing
plants, restaurants or other areas where food is commerically prepared,
processed or served. Personal communication. Environmental Protection
Agency. Washington, D. C.
American Can Company. (undated). The safer aerosol container...(rim vent
release). Advertisement. Greenwich, Conn.
American Medical Association, Food Science Committee AMA-Council on Foods
and Nutrition and AMA-Food Industry Liaison Committee. February 17, 1971,
Resource conference on microbiologic safety in catered, franchised and
vending machine foods (proceedings). Washington, D. C. 71 p.
Appleby, W. G. June 1, 1970. Food additive petition no. OH2477 amendment.
Personal communication. Washington, D. C.
Appleby, W. G. June 5, 1970. Food additive petition no. OH2477.
Personal communication. Washington, D. C.
Athena Corporation. (undated). Pest-Guard, Pretty Please, bug proof shelf
paper. Advertisement. Dallas.
Barlow, D. B. October 19, 1971. Information on measured-release aerosols.
Personal communication. Chevron Chemical Company. San Francisco.
Bischoff, G. L. December 31, 1970. Petition no. 1H2634 for synergized
pyrethrins in food from the use of automatic dispensers in areas where
food is processed or served. CAP, Inc. (Committee to Clarify Status of
Automatic Pyrethrin Dispensers). Orange, Calif.
Bischoff, G. L. November 4, 1971. Expansion of views on automatic pyrethrin
dispensers. Personal communication. CAP, Inc. (Committee to Clarify
Status of Automatic Pyrethrin Dispensers). Orange, Calif.
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Bjornson, B. F., H. D. Pratt and K. S. Littig. 1956. Control of Domestic
Rats and Mice. U. S. Department of Health, Education, and Welfare.
U. S. Government Printing Office. Washington, D. C. Reprinted 1970
by the Environmental Protection Agency, Office of SoLid Waste Management
Programs. 47 p.
Bower, W. F. February 1, 1968. Automatic or continuous dispensing of
insecticides in food establishments, milk houses, etc. Personal
communication. Food and Drug Administration. Cincinnati.
Bower, W. F. April 28, 1970. February 1, 1968 memorandum relating to
automatic or continuous dispensing of insecticides in food establish-
ments, milk houses, etc. Personal communication. Food and Drug
Administration. Washington, D. C.
Brauner, G. V. October 15, 1971. Statement presented before Hazardous
Materials Committee of EPA. National Canners Assn. Washington, D. C.
CAP, Inc. (Committee to Clarify Status of Automatic Pyrethrin Dispensers).
June 15, 1970. Brief on intermittent pyrethrin dispensers. Unpublished.
CAP, Inc. (Committee to Clarify Status of Automatic Pyrethrin Dispensers).
December 28, 1970. Compilation of reports on intermittent pyrethrin
dispensers. Orange, Calif.
CAP, Inc. (Committee to Clarify Status of Automatic Pyrethrin Dispensers).
(undated). Protocol, rat inhalation study. Orange, Calif.
Cline-Buckner, Incorporated. April 1, 1971. Distributor /equipment and/
prices. Information pamphlet. Cerritos, Calif.
Cline-Buckner, Incorporated. (undated). Easily programmed by you...not
by program systems analysts. Advertisement. Cerritos, Calif.
Cline-Buckner, Incorporated. (undated). Purge II concentrated aerosol
insect killer. Label. Cerritos, Calif.
Cline-Buckner, Incorporated. (undated). The new Automizer automatic
flying insect killer. Advertisement. Compton, Calif.
Code of Federal Regulations. 2,2-Dichlorovinyl dimethyl phosphate; tolerances
for residues. U. S. Government Printing Office. Washington, D. C.
Title 21 CFR Sec. 120.235.
Cooper, M. I. October 15, 1971. Summary of presentation. Personal
communication. Insect Control and Research, Incorporated.
Glenside, Pa.
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U. S. Department of Agriculture. September 1970. Cockroaches, how to
control them. U. S. Government Printing Office. Washington, D. C.
Leaflet No. 430. Revised. 8 p.
U. S. Department of Health, Education, and Welfare, Center for Disease Control.
March 1971. Public health pesticides. Pest Control. The Harvest
Publishing Company.
U. S. Department of Health, Education, and Welfare, Food and Drug Administration.
November 3, 1971. Use of automatic pyrethrin dispensers in food
handling areas. Field Management Directive. Washington, D. C.
U. S. House of Representatives. 1969. Fountain Committee hearings. p. 88-91.
U. S. Government Printing Office. Washington, D. C.
U. S. House of Representatives, Committee on Government Operations. May 7
and June 24, 1971. Deficiencies in administration of Federal Insecticide,
Fungicide, and Rodenticide Act. Hearings. U. S. Government Printing
Office. Washington, D. C. p. 88-91, 124-127, 138-140.
Walter, V. E. (undated). Pest control in food processing and food handling
areas. Bruce Terminix. Harlingen, Texas. 5 p.
Wessel, R. D. October 6, 1971. Aerosol insecticide use in food processing
plants. Personal communication. Chevron Chemical Company. Richmond,
Calif.
Wiseman, S. December 2, 1969. Petition no. 2489 for tolerance in connection
with our bug-proof shelf paper. Personal communication. Dallas.
White, R. 0. April 13, 1966. Notice to manufacturers, formulators,
distributors, and registrants of economic poisons on registering
pesticides on a zero tolerance or no residue basis. Personal communication.
U. S. Department of Agriculture. Washington, D. C.
Zapp, J. A., Jr. December 13, 1971. Comment on protocol. Personal
communication. Wilmington, Del.
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Cordell, V. E. and R. R. Zeender. October 15, 1971. Presentation made
to consultants on pest control in food processing plants and other
food handling areas. National Restaurant Association. Chicago.
Unpublished. 6 p.
Diechmann, W. B. December 13, 1971. Comments on protocol. Personal
communication. Coral Gables, Fla.
Dierks, J. C. November 3, 1971. Misuse, abuse of the use, and toxicity of
pesticides relative to food processing. Personal communication.
Omaha-Douglas County Health Department. Omaha.
Espoy, H. M. March 17, 1970. Study to determine the effects on various
food products placed in cabinets which were sprayed with common
commercial household insecticide sprays packaged in aerosol cans.
Unpublished. Daylin Laboratories, Incorporated. Los Angeles.
Espoy, H. M. April 27, 1971. Study to determine the effects on various
food products placed in cabinets which were sprayed with commercial
household insecticide sprays packaged in aerosol cans. Unpublished.
Daylin Laboratories, Incorporated. Los Angeles.
Espoy, H. M. September 13, 1971. Study of lindane release into air
from lindane-impregnated paper. Unpublished. Daylin Laboratories,
Incorporated. Los Angeles.
Federal Food, Drug, and Cosmetic Act, as amended. April 1970. Title 21
U. S. Code. U. S. Government Printing Office. Washington, D. C.
Reprint. 83 p.
Federal Register.' February 28, 1968. Milk, eggs, meat, and/or poultry,
pesticide tolerances; policy statement. Washington, D. C. 33:3438.
Federal Register. January 13, 1970. Shell Chemical Company, notice of
filing of petition for food additives. Washington, D. C. 35:440.
Federal Register. January 21, 1970. Athena Corporation, notice of
filing of petition for food additives. Washington, D. C. 35:820.
Federal Register. June 16, 1970. Hazelton Laboratories, Incorporated,
notice of filing of petition for food additives. Washington, D. C.
35:9869.
Federal Register. August 8, 1970. Shell Chemical Company, denial and
withdrawal of petition for food additive 2,2-dichlorovinyl dimethyl
phosphate. Washington, D. C. 35:12680.
Federal Register. October 8, 1970. Hazelton Laboratories, Incorporated,
notice of withdrawal of petition for food additives. Washington, D. C.
35:15859.
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Federal Register. December 9, 1970. Committee to Clarify Status of Automatic
Pyrethrin Dispensers, denial of petition for food additive pyrethrins in
conjunction with N-octyl bicycloheptene dicarboximide and piperonyl
butoxide. Washington, D. C. 35:18687.
Federal Register. April 6, 1971. Committee to Clarify Status of Automatic
Pyrethrin Dispensers, notice of filing of petition for food additives.
Washington, D. C. 36:6540.
Federal Register. April 16, 1971. Athena Corporation, denial of petition
for food additive, chlordane. Washington, D. C. 36:7283-7284.
Federal Register. August 13, 1971. Rules and Regulations, Table G-I
continued. Washington, D. C. 36:15103-15104.
Fine, S. D. November 19, 1971. Pyrethrins and automatic dispensing devices.
Personal communication. Food and Drug Administration. Washington, D. C.
Fine, S. D. November 19, 1971. Use of automatic pesticide dispensers
containing pyrethrins and piperonyl butoxide. Personal communication.
Food and Drug Administration. Washington, D. C.
Fisher, F. E. January 4, 1972. Automatic pyrethrin dispensers. Personal
communication. Indiana State Board of Health. Indianapolis.
Fitzsimmons, K. R. March 19, 1970. Safety of No-Pest (Vapona) insecticide
strips with regard to inhalation. Shell Chemical Company. Unpublished.
New York.
Food Chemical News. September 27, 1971. Hearing examiner rules for
registration of lindane vaporizers. Louis Rothschild, Jr.
Ed. & Pub. Washington, D. C.
Food Chemical News. November 8, 1971. Judicial officer allows commercial
use of lindane vaporizers, p. 34-35. Louis Rothschild, Jr.
Ed. & Pub. Washington, D. C.
Harris, K. L., J. F. Nicholson, L. K. Randolph and J. L. Trawick.
January 4, 1952. Report on -the wheat and wheat flour investigational
program. J. Assn. Off. Agr. Chemists. Feb 1952. Condensed
by R. K. Durham, Millers' National Federation. Chicago. 7 p.
Harris, T. H. May 11, 1971. Pesticide food additive petition no. 1H2634,
background information, and recommendation of action. Personal
communication. Environmental Protection Agency. Washington, D. C.
Harris, T. H. May 26, 1.971. Memorandum of conference between CAP, Inc. and
EPA on automatic pyrethrin dispensers--food additive petition no. OH2515.
Personal communication. Environmental Protection Agency. Washington, D. C.
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Hayes, W. J., Jr. October 20, 1971. Study on pyrethrin formulations.
Personal communication. Nashville.
Hayes, W. J., Jr. December 2, 1971. Comments on protocol. Personal
communication. Nashville.
Holsing, G. C. May 6, 1970. Petition no. OH2545 for lindane as a contact
insecticide in shelf and drawer paper. Hazelton Laboratories Incorporated.
Vienna, Va.
Holsing, G. C. September 3, 1970. Withdrawal of food additive petition
no. OH2545 without prejudice to a future filing. Personal communication.
Hazelton Laboratories Incorporated. Vienna, Va.
Jones D. F. October 19, 1971. Points on control of food contaminating
pests. Personal communication. Operative Millers Sanitation Committee.
Minneapolis.
Jones, D. F. November 2, 1970. Boxcar study--1970. Personal communication.
Association of Operative Millers Sanitation Committee. Minneapolis. 5. p
Kimbrough, R. D., T. B. Gaines and W. J. Hayes, Jr. March 1968. Combined
effect of DDT, pyrethrum, and piperonyl butoxide on rat liver. Arch.
Environ. Health 16:333-341.
Kitzke, E. D. October 15, 1971. Pyrethrin aerosol formulations around
food processing plants and restaurants. Personal communication.
S. C. Johnson and Son, Incorporated. Racine, Wise.
Mark Chemical Company. (undated). Chemmark Midas Auto Con automatic
control of small flying insects. Label. Orange, Calif.
McClure, D. A. September 16, 1971. Aerosol propellants--how safe?
Tenth Annual Industry Conference, California Cosmetic Association,
Incorporated. Los Angeles.
McDonald, R. A. October 15, 1971. Remarks of Mr. Richard McDonald, President,
Paper Products Incorporated, October 15, 1971 to...Hazardous Materials
Advisory Committee of the EPA. Unpublished. Long Beach, Calif.
McDonald, R. A. November 29, 1971. Further comments on pest control in food
handling areas. Personal communication. Paper Products Incorporated.
Long Beach, Calif.
McFarland, F. J. June 1, 1970. Memorandum of conference between Shell
Chemical Company and FDA on amendment to food additive petition no.
OH2477, DDVP resin strips. Personal communication. Washington, D. C.
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Milby, T. H., A. J. Samuels and F. Ottoboni. October 1968. Human exposure
to lindane; blood lindane levels as a function of exposure. J.
Occup. Med. 10:584-587.
Milby, T. H. February 25, 1969. Effects of lindane on human health.
Personal communication. Berkeley, Calif.
Milby, T. H. December 6, 1971. Comments on protocol. Personal communication.
Berkeley, Calif.
National Pest Control Association. May 11, 1966. Cockroaches and their
control. Technical Release. Elizabeth, N. J. 26 p.
National Pest Control Association. July 20, 1970. Food plant pest control.
Technical Release. Elizabeth, N. J. 7 p.
National Pest Control Association (NPCA). September 15, 1971. Schedule A,
NPCA insured termite warranty program and the following good practice
statement drafts on: The use of thallium sulfate by the PCO, The
use of traps for commensal rodent control by the PCO, The use of
calcium cyanide as a burrow fumigant, Misting of insecticides
indoors, The use of dusts indoors for insect control, The use of
insecticidal baits for insect control, The use of insecticidal
aerosols indoors, The use of Avitrol 200 for bird management, The
use of Rid-A-Bird perches containing endrin on fenthion for management
of pest birds, Practices to be followed in all types of bird manage-
ment, Technical release 14-71--Fleas. Service Letter. Elizabeth, N. J. 40
National Pest Control Association. October 29, 1971. Pest Control in
food handling establishments. Association Affairs. Elizabeth, N. J.
National Pest Control Association. (undated). Good practice statements.
Technical Release. Elizabeth, N. J. 74 p.
National Restaurant Association and National Pest Control Association,
Incorporated. (undated). Pest prevention. Technical bulletin.
National Restaurant Association. Chicago. 16 p.
O'Brien, J. E. October 29, 1971. Aerosols in food plants. Personal
communication. San Francisco.
Paper Products Incorporated. (undated). No Bugs M'Lady, odorless shelf
and drawer paper. Label. Long Beach, Calif.
Pest Control Magazine. May, June, July, 1970. Roach control in a restaurant.
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