DDT
A REVIEW  OF SCIENTIFIC AND
 ECONOMIC ASPECTS OF THE
DECISION TO BAN ITS USE AS
          A PESTICIDE


              ^ PRO^°
   U.S. ENVIRONMENTAL PROTECTION AGENCY
         Washington, D.C. 20460
             JULY 1975
           EPA-540/1-75-022

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This report has been prepared by the U.S. Environmental Protection
Agency at the direction of a committee of Congress and has not been
reviewed by other Federal Agencies.  Mention of trade names does not
constitute endorsement.
For sale by National Technical Information Service, Springfield,
                            Virginia, 22151

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                              CONTENTS
I.    INTRODUCTION
      A.  Reason for Study	       1
      B.  How Undertaken	       1
      C.  What Report Does and Does Not Do	       2
      D.  DDT Regulatory History: A Brief Survey	       2
II.   SUMMARY
      A.  Fish and Wildlife Effects	       5
      B.  Human Effects	      10
      C.  DDT Residues in the Enviroment and Man	      13
      D.  Economic Aspects	      16
III.  DETAILED REVIEW OF SCIENTIFIC AND ECONOMIC ASPECTS
      A.  Fish and Wildlife Effects	      24
          1.  Introduction	      25
          2.  Bioaccumulation in aquatic organisms	      26
          3.  Effects on phytoplankton	      35
          4.  Lethal and sublethal effects on aquatic inverte-
                 brates 	      37 .
          5.  DDT toxicity in fish	      41
          6.  DDT effects on fish reproduction	      43
          7.  Sublethal effects on fish	      46
          8.  Bioaccumulation in terrestrial organisms	      49
          9.  Toxicity of DDT to birds	      56
         10.  Eggshell thinning and reproduction	      62
      B.  Human Effects	      82-
          1.  Carcinogenicity of DDT in mice	      83
          2.  Tumor production in mice as an index of potential
                 carcinogenicity in other species 	      87
          3.  Carcinogenicity of DDT in other mammalian species  .      88
          4.  Carcinogenicity of DDT in humans	      90-
          5.  Carcinogenicity of DDT metabolites	      92
          6.  Effects of DDT substitutes on humans	      951
      C.  Monitoring of DDT Residues in the Environment
              and Man	     105 ,
          1.  Persistence of DDT in soil.	     106
          2.  Transport of DDT from aerial application sites. .  .     109
              a.)  drift	     109
              b.)  vaporization	     109
              c.)  soil erosion	     Ill
          3.  Contamination of the aquatic environment	     113
          4.  Persistence in aquatic ecosystems 	     115
          5.  Human exposure to DDT residues	     117
          6.  Human storage and DDT residues	     133-
      D.  Review of Economic Aspects	     146
          1.  Introduction	     147
          2.  Cotton	     150
              a.)  overview of the cotton economy	     151
              b.)  trends in cotton acreage, yields, and produc-
                      tion in the US and in major producing
                      regions	     158
              c.)  availability of alternatives to DDT	     163

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        d.)  insecticide use patterns	       177
        e.)  insect control costs 	       184
        f.)  intraregional and interregional impact
                associated with cancellation of DDT . .  .       193
    3.  Economics of the minor uses of DDT	       198
        a.)  contested nonessential crop uses	       198
        b.)  sweet potatoes, sweet peppers, and onions.  .       215
        c.)  military use of DDT	       218
        d.)  public health	       218
        e.)  pea leaf weevil	       220
    4.  Forest uses of DDT	       225
        a.)  history of use on forest pests	       225
        b.)  benefits of control	       233
        c.)  federal policy on use of persistent
               pesticides	       237
APPENDICES
IA.     Opinion and Order of the Administrator	       242
IB.     DDT Regulatory History: A Brief Survey	       251
IIIB.l  Acute Human Hazard Information on Alternatives
           to DDT	       257
IIIB.2  EPA Report of National Pesticide Episodes for
           DDT Substitues, 1971-1974	       266
IIID.l  Efficacy and Cost Effectiveness of Alternatives
           to DDT for Cotton Insect Pests	       267
HID.2  The Value of DDT in Cotton Production	       290

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     I.



INTRODUCTION

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                              INTRODUCTION
REASON FOR STUDY

     At the request of the Appropriations Committee, U.S. House of
Representatives, the Environmental Protection Agency has undertaken
a review of the 1972 decision cancelling many of the registrations of
DDT.  The specific language of the request is contained in both the
1974 report of the Appropriations Committee and the November 6, 1973
Congressional Record (H 9619):

          "The Agency was also directed to initiate a complete
          and thorough review, based on scientific evidence of
          the decision banning the use of DDT.  This review of
          DDT must take into consideration all of the costs and
          benefits and the importance of protecting the Nation's
          supply of food and fiber."

     To this end, the Agency assembled a team of scientists and economists
to review the relevant scientific and economic data.
HOW UNDERTAKEN

     This review centered on the key findings of the Administrator in his
Decision released June 14, 1972 (Appendix IA).  The initial assemblage
and evaluation of the information was under the direction of the Criteria
and Evaluation Division, Office of Pesticide Programs.  Comments and
suggestions for the final report were given by scientists at offices
elsewhere in EPA.

     The review was divided into four major areas for purposes of conducting
the review by multidisciplinary teams and for presentation of findings:

     1.  Fish and wildlife effects

     2.  Human effects

     3.  Residues in the environment and man

     4.  Economic aspects

     The following methodology was used in reviewing various aspects of
the Administrator's Decision:

     1.  Ascertain the Administrator's findings in his 1972 Opinion
         (Factual Findings Section).
                                        -1-

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     2.  Review the information available to the Administrator in support
         of these findings at the time of his decision.

     3.  Conduct information searches using relevant data banks for more
         recently published articles and current research projects in
         EPA and elsewhere.

     4.  Evaluate available scientific studies and data on DDT in light of
         the key findings of the Administrator in his 1972 Opinion to
         determine which of the following best describes the current
         data situation:  a) no new data since the decision in 1972;
         b) new data confirm (or deny) 1972 findings.
WHAT THE REPORT DOES AND DOES NOT DO

     The aim of this report was to provide a detailed review of the litera-
ture and data relating to the findings which supported the 1972 decision,
and to impacts it had on social, economic, and environment variables since
it became effective January 1, 1973.  The review was of the data supporting
the various findings of the Administrator rather than of the overall decision
itself, which involved weighing of various social, economic and environmental
factors.
DDT REGULATORY HISTORY;  A BRIEF SURVEY

     A brief survey of the regulatory history involving DDT is presented
in Appendix IB.  The summary covers the period from early actions by USDA
to restrict DDT use in the late 1950's to EPA actions since 1972, such as
those involving temporary registration for use against the pea leaf weevil
(1973) and applications for emergency use of DDT against the tussock moth
in forests (1974) and against the tobacco budworm on cotton (1975).
                                       -2-

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               II.




            SUMMARY






A.  FISH AND WILDLIFE EFFECTS




B.  HUMAN EFFECTS




C.  DDT RESIDUES IN THE ENVIRONMENT AND MAN




D.  ECONOMIC ASPECTS

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                                  SUMMARY
     This summary consists of an introductory survey and a matrix summarizing
results in tabular form for each major review area: fish and wildlife effects,
human effects, residue monitoring, and economic (benefit) aspects.  The matrices
summarize results of the review, finding-by-finding in the 1972 order.  The
detailed analyses that led to the results summarized in Part II are presented
in Part III, arranged in the same order.
                                        -4-

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FISH AND WILDLIFE EFFECTS    .

     Voluminous literature published in this area since the DDT hearings has
allowed a more complete picture of DDT's effects in this area than was avail-
able at the time of cancellation.  Reproductive, behavioral, lethal, and sub-
lethal effects on fish and wildlife have been reviewed in detail based on the
additional literature and data.  Also, EPA personnel conducted intensive on-
site field interviews with persons involved in research on fish and wildlife
effects to obtain most recent data and results, as a supplement to the nearly
500 articles that have been published in this area and reviewed since the
cancellation.

     New data were available in the case of most findings on fish and wildlife
effects and none of the findings of the Administrator could be denied on the
basis of new data.  Certain behavioral effects on wildlife that were not known
in 1972 have been established since that time.
                                        -5-

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                                                          SUMMARY

                           REVIEW OF DATA ON FINDINGS SUPPORTING ADMINISTRATOR'S ORDER ON DDT


                                                      Fish and Wildlife Effects
Administrator's Findings:
Lines of Evidence or
Nature of Finding/
Subfinding
                        Current Data Situation
                                                    No
                                                    New
                                                    Data
                                                                New Data:
Confirms
  1972
Finding
Denies
 1972
Finding
                                                                                             Remarks
DDT can be Concentrated and Transferred in
freshwater and marine plankton, insects,
molluscs, other invertebrates, and fish,

     Experimental evidence has demonstrated
     the propensity of DDT to bioaccumulate
     in aquatic organisms and to be trans-
     ferred upward in the food web.

     Residue data collected in the environ-
     ment demonstrate that DDT is ubiqui-
     tous in aquatic organisms at levels
     exceeding those occurring in the
     physical environment.
DDT Affects Phytoplankton Species Composition
and the Natural Balance in Aquatic Ecosystems,

     DDT decreases photosynthesis by dif-
     ferent species of phytoplankton.
     DDT can adversely affect phytoplankton
     growth rate.

DDT Can Have Lethal and Sublethal Effects
on Useful Aquatic Freshwater Invertebrates,
Including Arthropods and Molluscs,

     Experimental laboratory data have
     shown that DDT is highly toxic to
     many aquatic invertebrates.

     Experimental data have demonstrated
     that very low levels can result in
     reproductive failure and other sub-
     lethal effects.
     DDT has resulted in acute kills of
     aquatic invertebrates in the environ-
     ment.
                                                     An absorption-diffusion uptake
                                                     mechanism has been proposed for the
                                                     midge; uptake by algae is also passive.
                                                     Residue determinations on organisms
                                                     from natural habitats provide most
                                                     credible evidence.  Since the DDT ban,
                                                     residues have generally declined.
                                                     Declines are especially evident in
                                                     salt water molluscs and Lake Michigan
                                                     fish.
                                                     Exposure to DDT has resulted in •
                                                     reduction of oxygen production of
                                                     near 90%^distorting of cell orpanelles
                                                     also resulted from DDT exposure.

                                                     Ability to tolerate Nad was reduced
                                                     after exposure to DDT.
                                                     DDT has been found to result in a
                                                     decrease in fructose diphosphatase
                                                     activity in quahog clams,  indicating
                                                     possible interference with gluconeo-
                                                     genesis.  It has also been shown to
                                                     result in reduction of sodium and
                                                     potassium concentrations in shrimp
                                                     hepatopancreas.

                                                     Few new data are available, with the
                                                     exception of preliminary data from
                                                     the Tussock Moth Spray Program in
                                                     the Pacific Northwest.  In one study
                                                     stream, the treatment resulted in
                                                     almost total elimination of the
                                                     aquatic insect fauna and no signif-
                                                     icant recovery was detectable a month
                                                     later.
     DDT has been shown to affect higher
     trophic levels as a result of starv-
     ation following kills of prey in-
     vertebrates.
                                                           -6-

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                                                         SUMMARY

                           REVIEW OF DATA ON FINDINGS SUPPORTING ADMINISTRATOR'S ORDER ON DDT

                                                     Fish and Wildlife Effects  (continued)
Administrator's Findings:
Lines of Evidence or
Nature of Finding/
Sub finding
                        Current Data Situation
                                                    No
                                                    New
                                                    Data
                                                                New Data:
Confirms
  1972
Finding
Denies
 1972
Finding
                                                                                            Remarks
DDT is Toxic to Fish.

     Experimental laboratory data have
     shown that DDT will kill most fish
     species at very low levels.
     DDT has been responsible for fish
     kills.
DDT Can Affect the Eeproductive Success
of Fish.

     DDT can be highly concentrated in
     fish and stored in liplds, particularly
     in the eggs.  This can result in in-
     creased fry mortality during the stage
     when the fry are utilizing tne yolk.
                                                    Recent acute toxicity data are sparse,
                                                    primarily because additional data
                                                    would be redundant.   A chronic study
                                                    on fathead minnows showed that they
                                                    are particularly susceptible during the
                                                    first 2-1/2 months of life and during
                                                    the spawning stage.

                                                    New reports of fish kills are lacking
                                                    except for Incomplete data obtained
                                                    from the Tussock Moth Spray Program
                                                    which showed 643 sculpins were killed
                                                    in one study creek following DDT
                                                    application.
                                                    In some  cases  recent  data are more com-
                                                    prehensive.  Egg residues have been
                                                    correlated with increased fry mortality,
                                                    both experimentally and in the environ-
                                                    ment.
     Experimental results have shown that
     DDT can result'In delayed maturation
     of lake trout.

DDT Has a Variety of Sublethal Physiological
and Behavioral Effects on Fish.

     DDT differentially affects the normal
     utilization of some amino acids.

     DDT inhibits thyroid activity in fish.

     DDT has been shown to alter the tem-
     perature regime selection of fish.
     DDT can affect the impulse trans-
     mission in the lateral line of
     fishes.
                                                    Also has been shown to affect the amount
                                                    of activity at the selected temperature.
                                                    Cold and warm water temperature shock
                                                    has resulted in death after altered
                                                    temperature selection resulting from
                                                    DDT exposure.
     DDT can affect learning processes
     of fishes.

     DDT has been shown to disrupt
     cellular energy.
                                                    Hypersensitlvity can result from DDT
                                                    exposure.

                                                    Exposure to DDT has resulted in decreased
                                                    enzyme (ATPases) activity in kidneys
                                                    and gills, sites intimately involved
                                                    in osmoregulation.   Exposure to DDT
                                                    has resulted in abnormalities in the
                                                    ionic makeup of blood.
                                                             -7-

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                                                         SUMMARY

                           REVIEW OF DATA ON FINDINGS SUPPORTING ADMINISTRATOR'S ORDER ON DDT

                                                    Fish and Wildlife Effects  (continued)
Administrator's Findings:
Lines of Evidence or
Nature of Finding/
Subfinding
                        Current Data Situation
                                                    No
                                                    New
                                                    Data
                                                                New Data:
Confirms
  1972
Finding
Denies
 1972
Finding
                                                                                             Remarks
     DDT alters other "natural"
     behavior.
     DDT can cause developmental effects.
Birds Can Mobilize Lethal Amounts of DDT
Residues.

     DDT residues present a hazard to
     birds during stress periods.
     Residues have been found in areas
     of little or no previous DDT use.
     Assessment of cause of death is sometimes
     difficult because of the many pesticides
     present in the enivornment.

DDT is Concentrated in and Transferred Through
Terrestrial Invertebrates, Mammals, Amphibians,
Reptiles and Birds.

      DDT is ubiquitous at all trophic levels
      in the terrestrial system.

      Some species near the top of the trophic
      levels are adversely affected by DDT.
      Residue body burdens in some speices
      are declining.
                                "X"*
                                                             "X"*
DDE Can Cause Thinning of Bird Eggshells
and Thus Impair Reproductive Success.

     Museum shells and collected shells
     showed marked thickness decline
     after introduction in 1940's.
     Correlations between degree of shell
     thinning and amount of residues in
     eggs and birds.
                                                     Exposure to DDT has resulted in
                                                     changes in exploratory behavior,
                                                     locomotive display patterns, and
                                                     schooling behavior.

                                                     Exposure to DDT resulted in increased
                                                     pectoral ray asymmetry.
                                                     During migration or food deprivation
                                                     when fat reserves are utilized,  DDT
                                                     residues are relocated through the
                                                     bloodstream and accumulated in the
                                                     brain causing death.

                                                     DDT residues up to 4.12 ppm have been
                                                     found in Australian birds in areas far
                                                     from any pesticide use.

                                                     DDE residues up to 78 ppm were found
                                                     in sick and dead eagles along with
                                                     dieldrin,  PCB's and mercury.
                                                     DDT has been found in virtually all
                                                     terrestrial organisms.

                                                     Osprey, eagle, sparrowhawk, peregrine
                                                     falcon and other piscivorous birds
                                                     are still affected by DDT in behavior
                                                     and reporductive success but some are
                                                     now showing some signs of recovery.

                                                     Migratory songbirds in Florida are
                                                     displaying a declining mean DDT
                                                     residues in ppm from 1964 to 1973.
                                                     Osprey have increased from 4 to 26
                                                     fledged young per year off Long Island,
                                                     New York, associated with declining
                                                     residues of DDE.
                                                     Shells now show pattern of returning
                                                     to nearer normal thickness since
                                                     suspension of use and reduction of
                                                     residues.

                                                     Numerous confirming  studies.
*Newly found effects.
                                                             -8-

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                                                          SUMMARY

                            REVIEW OF DATA ON FINDINGS SUPPORTING ADMINISTRATOR'S ORDER ON DDT

                                                  Fish and Wildlife Effects (continued)
Administrator's Findings:    Lines of Evidence or
                        :    Nature of Finding/
                        :    Subfinding
 .Current Data Situation
No
New
Data
            New Data:
Confirms  Denies
  1972     1972
Finding   Finding
                                        Remarks
     Laboratory studies showed the
     phenomenon to reproducible.
                             Confirming studies show that less than
                             1 ppm DDE diet causes thinning of shells.
     DDE affects calcium metabolism.
     Widespread reproductive failures in
     many avian species in U.S.
     No other chemical found to cause
     the degree of thinning caused by DDE.
                                                              "X"*
                             Biochemical mechanism found; DDE
                             inhibits calcium ATPase ("the calcium
                             pump") in the avian shell gland.

                             Breeding behavior and nest attentive-
                             ness adversely effected by DDE.

                             Fewer reproductive failures since
                             suspension.  Some avian populations
                             returning to near normal reproduction.
                             More chemicals tested.
                             thinning like DDE.
                                                                                                          None cause
     *Newly found effects.
                                                            -9-

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HUMAN EFFECTS

     Prior and current literature and data on carcinogenlcity of DDT are
reviewed.  The review indicates that DDT is a carcinogen in mice, and a
potential carcinogen in man.  Valid epidemiological studies of human effects
of DDT are still lacking.  Adequate laboratory studies in species other than
the mouse are still lacking.  NCI studies involving the carcinogenicity of
DDT and its metabolites in rats are scheduled to be completed during the
next year.  The extent of acute human health risk due to use of DDT substi-
tutes was reviewed, indicating no large increase in incidents due to the
cancellation.  However, data do not permit detailed evaluation of previous
DDT use patterns.  Acute and chronic health effects of DDT substitutes
are being evaluated under EPA's Substitute Chemical Program on a continuing
basis.  Efforts have been made to protect against acute health effects by
user awareness training and worker reentry standards.
                                       -10-

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                                                 SUtMARY

                       REVIEW OF DATA ON FINDINGS SUPPORTING ADMINISTRATOR'S ORDER ON DDT

                                               Hurnan Effects
Administrator's Findings:
Lines of Evidence or
Nature of Finding/
Subfinding
Current Data Situation
                                                   No
                                                   New
                                                   Data
                                                               New Data:
      Confirms
        1972
      Finding
Denies
  1972
Finding
                                                                                          Remarks
DDT is a Potential Human Carcinogen.
      Experiments demonstrate that DDT
      causes tumors in laboratory animals.
    - There is some indication of
      metastasis of tumors attributed
      to exposure of animals to DDT in
      the laboratory.

    - Responsible scientists believe
      tumor induction in mice is a
      valid warning of possible
      carcinogenic properties.
    - Not all chemicals show the same
      tumorigenic properties in
      laboratory tests in animals.
      There are no adequate negative
      experimental studies in other
      mammalian species.
                                                   The potential of DDT to produce
                                                   cancer in man has to date only
                                                   been evaluated on the results
                                                   obtained from mouse studies.
                                                   There are no adequate human
                                                   studies which document DDT as en
                                                   actual carcinogen in man.

                                                   The production of hepatic
                                                   tumors by DDT given by the
                                                   oral route has been demonstrated
                                                   and confirmed in several strains
                                                   of mice.

                                                   Liver cell tumors have been
                                                   produced in both sexes, and
                                                   in CF mice were found to have
                                                   metastasized to the lungs.

                                                   Specific chemicals have been
                                                   observed to produce tumors in
                                                   mice as well as in the rat,
                                                   dog and monkey.  In specific
                                                   cases a chemical was observed
                                                   to produce carcinomas in man
                                                   as well.

                                                   The mouse for specific chemicals
                                                   has been found to serve as a
                                                   reliable indicator of tne
                                                   carcinogenicity of a chemical
                                                   in other species and man,
                                                   although the target tissue may
                                                   be different.  Therefore,
                                                   carcinogenic effects in mice
                                                   can be valid when dealing with
                                                   these carcinogens; however,
                                                   carcinogenic effects can vary
                                                   greatly depending on the compound
                                                   tested.

                                                   Studies in rats have been incon-
                                                   sistent as to dose-response.
                                                   The groups were small in number
                                                   and the histopathology employed
                                                   was inadequate to draw definite
                                                   conclusions.  The one hamster
                                                   study cited in this review was
                                                   inconclusive, as a positive control
                                                   was not incorporated.  Further,
                                                   information as to carcinogeni-
                                                   city (e.g., spontaneous tumor
                                                   incidence; response to known
                                                   carcinogens) is not extensive
                                                   with this species.  Studies
                                                   performed with the dog and
                                                   monkey were of too short
                                                   duration and utilized too small
                                                   a sample size to yield any
                                                   reliable statistical information.

                                                   NCI studies now underway on
                                                   carcinogenicity of DDT and its
                                                   metabolites could be completed
                                                   during the next year (rats and
                                                   mice).
                                                    -11-

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                                                 SUMMARY
                      REVIEW OF DATA ON FINDINGS SUPPORTING ADMINISTRATOR'S ORDER ON DDT
                                                Human Effects (continued)
Administrator's Finding:
Lines of Evidence or
Nature of Finding/
Subfinding
                                                    Current Data Situation
                                                  No
                                                  New
                                                  Data
                                                              New Data:
Confirms
  1972
Finding
Denies
  1972
Finding
                                                                                            Remarks
      There is no adequate human
      epidemiological data on the
      carcinogenicity of DDT, nor
      is it likely that it can be
      obtained.
HUMAN EHH,TS OF DDT SUBSTITUTES
      Many poisonings have been attributed
      to the use of Methyl parathion.
    - Untrained users of Methyl parathion are
      frequently not sufficiently careful in
      its use despite lable directions.

    - Methyl parathion can be used safely.

    - Training programs are useful in averting
      the negligent use of Methyl parathion.
     • Methyl parathion is a substitute for
      most crop uses of DDT.

      Ultimately, parathion is dangerous
      to users and presents a risk to them.
      An opportunity to train users will
      minimize the risks.
                                                    No additional well-defined data
                                                    were obtained from the comnunity
                                                    studies program except residue
                                                    data.  The early studies cited
                                                    utilized small experimental
                                                    groups (35 or less)  over
                                                    relatively short periods of
                                                    time (1-11 years)  as compared
                                                    to that which is required (20-30
                                                    years)  or greater, to test a
                                                    potential carcinogen of the
                                                    potency of DDT in man.  Medical
                                                    follow-up in the case of Hayes1
                                                    controlled dose studies was
                                                    limited to 4 years with only 2
                                                    subjects in each dose group.
                                                    In addition, the majority of
                                                    studies utilizing occupational
                                                    high exposure groups were un-
                                                    controlled.  Small sample
                                                    size, lack of data on the
                                                    age of first exposure to DDT
                                                    (which could be critical in
                                                    development of a carcinoma)  along
                                                    with other limitations make
                                                    such studies inconclusive.   More-
                                                    over, since DD1' is ubiquitous,
                                                    there is no completely
                                                    unexposed human control group.

                                                    Definitive conclusions as to
                                                    the extent of acute human
                                                    health impacts of the use of
                                                    DDT substitutes cannot be
                                                    drawn on basis of available
                                                    data.  Data series do not
                                                    permit quantitative analysis
                                                    of human health effects in use
                                                    patterns impacted by the 1972
                                                    decision, e.g., cotton.  However,
                                                    there is indicated some acute
                                                    hazard to humans involving the
                                                    use of DDT substitutes, such
                                                    as the organophosphates.

                                                    EPA's pesticide episode review
                                                    system still lists methyl
                                                    parathion as one of the most
                                                    frequently reported pesticides
                                                    involving human poisonings.

                                                    As indicated by EPA's Project
                                                    Safeguard,  highly toxic organo-
                                                    phosphates could be used  safely
                                                    with training and  'following  laoel
                                                    directions.   Reentry standards
                                                    also offer some potential to
                                                    protect against premature
                                                    entrance into treated areas.
                                                    Such standards were promulgated
                                                    by EPA in 1974. Other substitutes
                                                    are used as well in most cases.
                                                   EPA pesticide applicator
                                                   certification and  training
                                                   programs will contribute to
                                                   reduced risk of toxic DDT
                                                   substitutes.
                                                        -12-

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DDT RESIDUES IN THE ENVIRONMENT AND MAN

     DDT is ubiquitous in the environment due to its past use and chemical
and physical characteristics.  Soil residues will continue to decline slowly.
Residues in food commodities and in man have declined in recent years.  Future
declines will be at a slower rate.
                                       -13-

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                                              SUMMARY

                    REVIEW OF DATA ON FINDINGS SUPPORTING ADMINISTRATOR'S ORDER ON DDT

                              DDT Residues  in the Environment and Man
Administrator's Findings:
Lines of Evidence or
Nature of Finding/
Subfinding
Current Data Situation
                                                   No
                                                   New
                                                   Data
                                                               New Data:
      Confirms
        1972
      Finding
Denies
 1972
Finding
                                                                                           Remarks
DDT Can Persist in Soil for Years and
Even Decades.

    Degradation of DDT in the soil
    environment is highly variable but
    typically is very slow.  "Half-life"
    values of 10 years or more are
    commonly found.

Because of Persistence, DDT is Subject to
Transport from Sites of Application.

    - DDT can be transported by drift during
      aerial application.
    - DDT can vaporize from crops and soils.
                                                    The use of DDT for agricultural and
                                                    forestry purposes has contaminated
                                                    a substantial portion of our nation's
                                                    productive land.  Total soil residues
                                                    of DDT and its metabolites will only
                                                    decline very slowly and substantial
                                                    portions will still be present after
                                                    extended periods of time.
                                                    Drift of DDT has ceased to be a
                                                    problem since cancellation of all
                                                    uses in 1972, except possibly in
                                                    the use of DDT against the tussock
                                                    moth.

                                                    The significance of vaporization
                                                    of DDT resides from soil, especially
                                                    the more volatile DDE component, is
                                                    still poorly defined.  Of special
                                                    importance is the relative role
                                                    that volatilization may play in
                                                    causing low level residues in domestic
                                                    animal feeds grown on DDT contaminated
                                                    farmland.
    - DDT can be attached to eroding soil
      particles.
DDT is a Contaminant of Fresh Waters, Estuaries
and the Open Ocean, and it is Difficult or
Impossible to Prevent DDT from Reaching"
Aquatic Areas and TopographyflAdjacent and
Remote from the Site of Application.

    DDT residues are ubiquitous in the aquatic
    environment, especially in aquatic sites
    fed by agricultural watersheds.  Contamina-
    tion of estuarine areas by way of major
    river systems has occurred and coastal
    areas are generally polluted with low levels
    of DDT.  The open oceans contain considerably
    less DDT, but minute levels can be found
    worldwide, even in the polar regions.

DDT Can Persist in Aquatic Ecosystems.

    DDT and its metabolites DDE and ODD are
    commonly found in water, sediment and
    aquatic life.  A dynamic equilibrium
    exists with the main storage reservoir
    being the bottom sediment.
                                                    Loss of DDT from terrestrial to
                                                    aquatic sites due to soil erosion
                                                    will continue to occur for many
                                                    years into the future.

                                                    A gradual decline in residue levels
                                                    of aquatic organisms can be expected
                                                    as the bioavailability of DDT is
                                                    decreased due to the combined factors
                                                    of dispersion, degradation, and
                                                    sedimentation.  Excessive residue
                                                    levels, as noted in fish from the
                                                    Great Lakes in the 1960"s are no
                                                    longer frequent occurrences.  With
                                                    the exception of data on fish from
                                                    the Great Lakes, most available
                                                    residue data are not applicable to
                                                    prediction of long term trends with
                                                    regard to the degradation of DDT in
                                                    aquatic environments.

                                                    Residues of DDT and its metabolites
                                                    can be expected to persist for an
                                                    extended period of time.  Bioavail-
                                                    ability, however, can be expected
                                                    to decrease as a result of dispersion
                                                    degradation and sedimentation
                                                    especially in areas where bottom
                                                    sediments are not subject to continued
                                                    disruption.  Good "baseline" data
                                                    from which future trends can be
                                                    compared and/or predicted are not yet
                                                    available for many types of aquatic
                                                    areas.
                                                           -14-

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                                              SUMMARY

                    REVIEW OF DATA ON FINDINGS SUPPORTING ADMINISTRATOR'S ORDER ON DDT

                              DDT Residues in the Environment and Man (continued)
Administrator's Findings:
Lines of Evidence or
Nature of Finding/
Subfinding
Current Data Situation
                                                   No
                                                   New
                                                   Data
                                                              New Data:
      Confirms
        1972
      Finding
Denies
 1972
Finding
                                                                                          Remarks
The Accumulation in the Food Chain and Crop
Residues Results in Human Exposure.

    DDT and its metabolites DDE and ODD are
    comonly found in human foods,
    especially meat, fish and dairy products.
Human Beings Store DDT.

    DDT and its metabolites DDE and ODD are
    found to store in human adipose tissue.
    DDT residues are found in human popula-
    tions world-wide with higher residues
    usually associated with DDT use in
    underdeveloped countries.
                                                   Gradual declines of total DDT
                                                   residues in certain major food
                                                   commodities began as early as
                                                   1965, but declined rapidly only
                                                   after 1970.  For meat and poultry,
                                                   these declines had stabilized by
                                                   FY 1973.  Levels of the
                                                   metabolite DDE have increased
                                                   relative to DDT over the last
                                                   several years indicating that
                                                   much of the current DDT residual
                                                   is coming from pesticide treat-
                                                   ments applied prior to DDT's
                                                   cancellation in 1972.  Due to
                                                   the persistence of these compounds,
                                                   residues will continue to occur
                                                   for many years, even after
                                                   cessation of DDT use.

                                                   DDT residues in human adipose
                                                   tissue have tended to decline
                                                   in recent years (1971-1973),
                                                   while the percent of DDT stored
                                                   as DDE has moved up only
                                                   slightly.   During this same
                                                   period,  significant declines
                                                   in residues in human food were
                                                   noted.   However,  since FY 1973,
                                                   levels of DDT and its metabolites!
                                                   in food have leveled off so
                                                   that no precipitous change in
                                                   human tissue levels can be
                                                   expected in the near future.

                                                   Human serum levels of DDT in
                                                   samples from occupationally
                                                   exposed individuals showed a
                                                   pronounced downward trend
                                                   between 1971 and  1973 suggesting
                                                   decreased exposure during the
                                                   period.
                                                      -15-

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ECONOMIC ASPECTS

     Cotton was the major use of DDT prior to the cancellation, accounting
for more than 80 percent of domestic DDT use.  DDT was used on about one-
sixth of U.S. cotton acreage in 1971 and 1972 (one-fourth of cotton farms).
Insecticides are an important input to cotton production, contributing to
improved yields, although they account for only about four percent of
total production costs for the average cotton grower.  Insecticides range
to near 15 percent of costs in some regions.

     Alternative insect controls, chemical and non-chemical, are available
although there are pest resistance problems in some areas for certain pests,
and, at times, market scarcities of supplies.

     Costs of growing cotton were affected in the Southeastern United States
where DDT was used prior to the cancellation.  Costs were increased by about
$7.75 million per year on the average in 1973 and 1974.  Nationally this
impact amounted to an increase in costs of slightly over $1.00 per acre
treated with insecticides (all types), equalling an increase in cotton
production costs per acre of about 0.5 percent.  This cost impact was
within the range of estimates in the hearing record (cost impacts up to $54
million per year).  This cost impact was quite significant in the most
affected region as production costs were increased by more than $600 per
farm on the average for about 10,000 farms.  Insecticide costs in this
region were increased by about $6.00 per treated acre, over the 1971/72
average of about $15.50 per acre in 1971/72.  Farms in this southeastern
U.S. region that use insecticides average about 70 acres treated per
farm.  Effects on costs elsewhere were much less significant.

     The cost impact of $7.75 million translates into a nominal impact on the
consumer of cotton, i.e. 2.2 cents per capita per year.  The cost impacts of
the' cancellation are not expected to generate large regional or national
impacts on cropping patterns for cotton and other major agricultural crops,
based on a recent analysis.  Studies are in progress in EPA to evaluate
possible cotton yield effects of DDT and other cotton insect pest manage-
ment options as well as cost impacts which were the prime focus of studies
reported in this review due to data limitations.

     Minor use DDT cancellations have resulted in increased insect control
costs of more than $400,000 per year (estimate for 1973), a nominal impact
nationally.  Production and yields of minor use crops have not been seriously
affected.  Temporary uses of DDT have been permitted in certain emergency
or special cases such as the tussock moth and the pea leaf weevil.  Studies
are underway to better evaluate benefits of DDT and alternative controls
in forest uses under an  EPA/USDA interagency agreement.
                                -16-

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                                                   SUMMARY

                        REVIEW OF DATA ON FINDINGS SUPPORTING ADMINISTRATOR'S ORDER ON DDT

                                           Economic Aspects:   Cotton
Administrator's Finding:
Lines of Evidence or
Nature of Finding/
Subfinding
Current Data Situation
                                                  No
                                                  New
                                                  Data
                                                             New Data:
     Confirms
       1972
     Finding
Denies
  1972
Finding
                                                                                          Remarks
COTKW

General economic context of
DOT cotton cancellation since 1972
                                                    Cotton was the major DDT use
                                                    accounting for more than 80
                                                    percent of domestic use.  DDT
                                                    was used on about 17 percent of
                                                    cotton farms in the U.S. prior
                                                    to the cancellation (18,700)
                                                    and about 25 percent of the
                                                    cotton acreage (1971-72 averages).
                                                    DDT was used only in the S.E.
                                                    U.S. immediately prior to the
                                                    cancellation (S.  Atlantic Region -
                                                    Md., Del., Val.,  W. Va., N.C.,
                                                    S.C., Ga. and Fla.; and the
                                                    East S.Central Region - Ky.,
                                                    Term., Ala., Miss., Ark. & La.).

                                                    DDT was used on more than half
                                                    of the cotton farms and cotton
                                                    acreage in the S. Atlantic
                                                    Region in 1971/72, but less
                                                    than one fourth of the cotton
                                                    farms and acreage in the East
                                                    S. Central Region.

                                                    Insecticides are an important
                                                    input in the cotton industry,
                                                    but less than 5 percent of the
                                                    cost of growing cotton in the
                                                    U.S.  In the S.E. U.S. where
                                                    DDT was used, costs of insecti-
                                                    cides ranged up to 14 percent
                                                    of the budget for growing
                                                    cotton as of 1971/72.

                                                    Economic well-being of the U.S.
                                                    cotton grower is much more a
                                                    function of other factors than
                                                    changes in pesticide regulatory
                                                    policy.  The cotton farmer,
                                                    from year to year, is hard hit
                                                    by such factors as bad weather,
                                                    late plantings leading to pest
                                                    infestation problems and
                                                    declining prices which battered
                                                    the industry in 1974.  This
                                                    outcome followed a banner year
                                                    in 1973, when prices were the
                                                    highest in history and the 15
                                                    cents per pound government pay-
                                                    ment to growers was in effect.
                                                    The unfavorable economic outcome
                                                    for cotton growers in 1974 has
                                                    lead to greatly reduced cotton
                                                    plantings in 1975.

                                                    The cotton industry has been
                                                    able to meet market needs since
                                                    1972, especially in 1974 as
                                                    prices declined sharply when the
                                                    crop came to market.
                                                     -17-

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                                                   SUMMARY

                        REVIEW OF DATA ON FINDINGS SUPPORTING ADMINISTRATOR'S ORDER ON DDT
                                        Economic Aspects:  Cotton  (continued)
 Administrator's Finding:
                      I
Lines of Evidence or  i	
Nature of Finding/    j
Subfinding             No
                                                       Current Data Situation
                                                              New Data:
                                                   New
                                                         : Confirms
                                                         !   1972
Denies
1972
                                                                                        Remarks
                                                   Data  I Finding  I Finding
 AVAILABILITY OF ALTERNATIVES TO DDT

 DDT is useful for the control of certain
 cotton insect pests.
Cotton pests are becoming resistant to DDT.
Methyl parathion and other organophosphate
chemicals are effective for the control of
cotton pests.
                                                    In the DDT Hearing Admission
                                                    No. 2 the USDA considered DDT
                                                    essential to control the
                                                    following insect pests:  budworm,
                                                    boll weevil, cotton bollworm,
                                                    cotton fleahopper, fall army-
                                                    worm, garden webworm, Lygus bugs,
                                                    mirids, thrips, and cutworms.
                                                    However, the 1972 Annual Confer-
                                                    ence Report on Cotton Insect
                                                    Research and Control only
                                                    recarcnended DDT for the bollworm,
                                                    budworm, and cutworm.

                                                    The 1972 Annual Conference Report
                                                    on Cotton Insect Research and
                                                    Control (USDA) stated many
                                                    cotton pests are resistant to
                                                    DDT.  Also, hearing testimony
                                                    stated DDT was not effective
                                                    for the control of the boll
                                                    weevil and that cotton pests,
                                                    including the bollworm, are
                                                    partially or totally resistant
                                                    to DDT.  The trend in use of
                                                    DDT was downward since 19G4,
                                                    presumably, due in part to
                                                    developing pest resistance.

                                                    Alternative pesticides are
                                                    registered by EPA and recommended
                                                    by the states for all cotton insect
                                                    pests and are effective in most
                                                    areas.  However, there may be
                                                    cases where effectiveness of
                                                    some alternatives is limited to
                                                    development of pest resistance
                                                    due to heavy or consistent use
                                                    of chemicals in the past or
                                                    extreme pest infestation outbreak
                                                    conditions.

                                                    The 1975 Annual Conference Report
                                                    on Cotton Insect Research Control
                                                    (USDA) reccrrmended EPA registered
                                                    insecticides for the control of the
                                                    various cotton pests.  Integrated
                                                    pest management programs are
                                                    minimizing the impact of the DDT
                                                    decision by pest scouting and
                                                    improved use of DDT alternatives,
                                                    including non-chemical controls.
                                                        -18-

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                                                         SUMMARY

                              REVIEW OF DATA ON  FINDINGS  SUPPORTING ADMINISTRATOR'S ORDER ON DDT
                                                Economic Aspects:  Cotton  (continued)
Administrator's Findings
Lines of Evidence or
Nature of Finding/
Subfinding
; Current Data Situation
!
!No
JNew
: Data
New Data i
Confirms
1972
Finding
Denies i Remarks
1972 !
Finding
By Using Methyl  Parathion or Other
Means of Pest Control.  Cotton Producers
Can Generally Produce Satisfactory
Yields at Acceptable Cost.
Impacts of DDT Decision on Cotton Insec-
ticide Costs - Comparison of 1971/72 and
1973/74 pre and post-cancell ation periods

The comparison of two year averages for the
periods immediately prior to and following
the 1972 decision provides the basis for
making judgements of impacts on costs of
growing cotton.  Data on the individual
years are not available.

Insecticide expenditures nationally
increased from $64.6 million per year in
1971/72 to $102.9 in 1973/74 (from $10.07
$13.65 per acre treated with an insecticide,
or by $3.58)i  Of this $38.3 million
increase in insecticide costs, an estimated
$6.1 million was due to the DDT cancellation
(about one sixth).   In addition, the can-
cellation led to an estimated increase in
application costs of $1.6 million for an
overall total of $7.75 million.   This
amounts to an average increase of about
$1.04 per acre for all cotton acres
treated in tiia U.S., 1373/74 average
(7.563 million acres).  This impact trtins-
lates into a rather nominal impact on the
consumer, i.e., about 2.2 cents per capita/
year for 1973/74.
                                                                             These cost impacts are well within the
                                                                             estimates in the record at the DDT hearings
                                                                             (up to $55 million per year).

                                                                             Impacts in the two affected regions are
                                                                             much more significant.  In the South
                                                                             Atlantic, increased insecticide and appli-
                                                                             cation costs, for a total of $6.0 million.
                                                                             This equalled about $630 per farm, based on
                                                                             the estimated number of farms that would
                                                                             have been treated with DDT in 1973/74 if it
                                                                             were available (about 10,000 farms).  This is
                                                                             a significant increase in costs, and is
                                                                             at a difficult time for cotton growers
                                                                             because of economic conditions of the
                                                                             industry and the economy generally.

                                                                             The increase in the East South Central was
                                                                             much less significant (about $1.0 million
                                                                             for insecticides plus $0.75 million for
                                                                             application costs for a total of $1.75
                                                                             million).  This would be less than $200 per
                                                                             farm on 9,000 farms.

                                                                             Supplies of some DDT alternatives were not
                                                                             plentiful in 1973/74, as costs increased
                                                                             sharply, particularly in the South East U.S.
                                                                             cotton area.
                                                              -19-

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                                                         SUMMARY

                               REVIEW OF DATA ON FINDINGS SUPPORTING ADMINISTRATOR'S  ORDER ON  DDT
                                                  Economic Aspects:  Cotton  (continued)
Administrator's Findings:
Lines of Evidence or
Nature of Finding/
Subfinding
  Current Data Situat;jn_-
     I     New Data      I
No    Confirms' Den:es  j
New  !   1972   j  1972   j
Data | Finding  ' Finding ;
                                                                                              Remarks
                                                                               Evaluation  of Impacts  of the  DDT/Cotton
                                                                               Cancellation  on  U.S. Agriculture  19"75

                                                                               An  analysis has  been made of  impacts of the
                                                                               DDT/cotton  cancellation  on U.S. agriculture
                                                                               for the year  1975,  utilizing  EPA's  linear
                                                                               programming model  for  U.S.  agriculture.
                                                                               This analysis evaluates  impacts of  changes
                                                                               in  costs  of production upon acreages, total
                                                                               production  and prices  of cotton and other
                                                                               major agricultural  crops for  the  year 1975,
                                                                               as  a typical  year  during the  post-cancel-
                                                                               lation period.

                                                                               The analysis  indicated that the DDT cotton
                                                                               cancellation  had minor impacts on acreage
                                                                               production, costs,  and returns for  cotton
                                                                               and other major  crops.
                                                                  -20-

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                                              SUMMARY.
                   REVIEW OF DATA ON FINDINGS SUPPORTING ADMINISTRATOR'S ORDER ON DDT
                                      Economic Aspects:  Minor Uses
Administrator's Finding:
Lines of Evidence or
Nature of Finding/
Subfinding
Current Data Situation
                                                  No
                                                  New
                                                  Data
                                                             New Data:
    Confirms
     1972
    Finding
Denies
 1972
Finding
                                                                                          Remarks
DDT is useful for controlling insects that
attack the following:  beans (dry, lima,
snap), sweet potatoes, peanuts, cabbage,
cauliflower, and brussels sprouts,
tomatoes, fresh market corn, sweet
peppers, pimentos, onions, garlic, and
ccnitiercial greenhouse plants. _ The use
of DDT is not necessary for the production
of these crops.
Adequate substitute chemicals, namely,
methyl parathlon and other organophosphates—
for the most part—exist for...crops except:"
sweet potatoes in storage, heavy infestations
of corn borer, attacking sweet peppers grcwrT
on the Del Marva Peninsula, and onions
attacked by cutworms.
                                                    A review was made of the yield
                                                    and cost impacts of the minor
                                                    uses contested at the hearings,
                                                    which included these crops.
                                                    No review was made of the
                                                    commercial greenhouse use.
                                                    DDT was not widely used for
                                                    these crops at the time of
                                                    cancellation (2.4 percent of
                                                    U.S. acreage in 1971).  Tomatoes
                                                    and cabbage had the largest
                                                    percentage uses (9 and 16 per-
                                                    cent of U.S. acreage respectively
                                                    in 1971).

                                                    Yield/acre and total produc-
                                                    tion in US for these crops
                                                    have been maintained since
                                                    the cancellation.  The only
                                                    crop with 1973/74 yield/acre
                                                    noteably below the 1968/72
                                                    average was cauliflower for
                                                    which there was no reported
                                                    DDT use in 1971.

                                                    Insecticide costs for contested
                                                    minor crops were estimated to
                                                    increase nominally (by about
                                                    $460,000) due to the DDT
                                                    cancellation based on the
                                                    year 1973.  This would trans-
                                                    late into a rather small impact
                                                    on the consumer.  Costs to
                                                    growers in some local areas
                                                    could have been affected
                                                    significantly but no such
                                                    effects are reported, aside
                                                    from problems with the pea leaf
                                                    weevil, discussed below.

                                                    These uses have been cancelled,
                                                    but since the hearing substitutes
                                                    have been registered for sweet
                                                    potatoes  (stored) and sweet
                                                    peppers.  Cost impacts from use
                                                    of alternatives to DDT for sweet
                                                    peppers were estimated at $76,000
                                                    over the Del Marva area, or
                                                    about $19.00 per acre (4,000
                                                    acres).  In 1972, DDT cost to
                                                    farmers was $6.51 per acre on
                                                    1,100 acres.  The onion use was
                                                    limited to a few acres in California,
                                                    and substitues are available.

                                                    Lack of alternative controls
                                                    for the pea leaf weevil had led
                                                    EPA to authorize temporary
                                                    registration of DDT against this
                                                    pest in Washington and Idaho.
                                                    Testing of alternative controls
                                                    in connection with these registra-
                                                    tions has led to registration of
                                                    alternative controls for 1975.
                                                           -21-

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                                                   SUMMARY

                         REVIEW OF DATA ON FINDINGS SUPPORTING ADMINISTRATOR'S ORDER ON DDT
                            Economic Aspects:  Minor Uses (continued) and Forest Use
Administrator's Finding:
Lines of Evidence or
Nature of Finding/
Subfinding
Current Data Situation
                                                              New Data:
                                                   No
                                                   New
                                                   Data
      Confirms j Denies
        1972   i  1972   i
      Finding  | Finding I
                                                                                         Remarks
DDT is Used for Exterminating Bats and Mice
by the Military,  a) Fumigation and Non-
Chemical Methods can Guard Against Bat
Infestations,  b) Warfarin is Effective
for Exterminating House Mice.

DDT is Considered Useful to Have in
Reserve for Public Health Purposes in
disease Vector Control.
    The Administrator found that potential
    benefits outweighed possible hazards.
                                                       Data requested from the Armed
                                                       Forces Pest Control Board have
                                                       not yet been received and
                                                       evaluated, but probably not a
                                                       great economic impact.

                                                       A very minor use of DDT in
                                                       this country; it was not
                                                       cancelled; substitutes are
                                                       available.
FOREST USES

1.  The forest use of DDT was not contested in the DDT hearings, but since 1972 has been the subject of emergency
    use requests.

2.  DDT had been used extensively against forest insect pests through the mid 1960's when its use was phased out
    as a matter of policy by USDA and USDI because of environmental concerns.

3.  An emergency request by USDA to use DDT against the Tussock Moth in 1973 was denied by 2PA, but a similar
    re4uest was granted in 1974.  Evaluation of the impacts of that action are in process.  Some environmental
    daiTage occurred to fish, wilxilife anu uouestic stock, according to preliminary data.

4. • Benefit evaluations of past forest pest control efforts have been limited by data and methodology.  The
    Forest Service is presently engaged in a major research effort on the biology and control of the gypsy
    and tussock moths.  EPA has recently entered into an interagency agreement with the Forest servi~ to
    cvalv-ate the environmental and economic consequences of the cancellation of. DDT for control of these pests.
    This will be a major study with $250,000 from EPA and $70,000, Forest Service, and should considerably
    enhance our ability to estimate forest pest losses and the benefits of various control strategies, with
    and without DDT.
                                                              -22-

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                       Ill
DETAILED REVIEW OF SCIENTIFIC AND ECONOMIC ASPECTS

-------
                                  INTRODUCTION
     In drafting the Fish and Wildlife Effects Section, we have located,
obtained, and reviewed nearly 500 scientific publications.  Also, we contacted
approximately sixty individual scientists by telephone and visited more than
twenty key scientists with unpublished current information.  We reviewed their
data, verified their protocols, and obtained written and unwritten "personal
communications" and clearance for quotation in this report.  In this manner,
we feel that the review is quite comprehensive and current as of January 1975.

     Many articles collected and reviewed are not cited in this report
because:  1) the sample size of the experiment was too small to allow valid
conclusions; 2) the data were for foreign species; 3) the data were confused
with high residues of other pollutants; 4) the data were not pertinent because
they were for nonwildlife species; 5) the data were obsolete or represented
excessive duplication of quoted experiments; 6) they were negative data about
noneffects, i.e., lack of effects where positive findings would not be expected,
in view of other studies; 7) they were old data and had been discussed in the
DDT Hearings previously.

     Residue and concentration values are cited as reported by the original
authors, although available analytical techniques may not always be as precise
as indicated.
                                      -25-

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                    BIOACCUMULATION IN AQUATIC ORGANISMS


            Administrator's Finding:  DDT eon be concentrated and
            transferred in freshwater and marine plankton, insects,
            molluscs, other invertebrates and fish.


     This issue is concerned with the evidence that DDT is concentrated and
incorporated into body tissues of aquatic organisms at levels much greater
than those occurring in the physical environment and that these high levels
may be transferred upward through the food web, with the highest level consumers
receiving the greatest pesticide load.

     Arguments used to support this issue are:

     1.  Experimental evidence has demonstrated the propensity of
         DDT to bioaccumulate in aquatic organisms and to be trans-
         ferred upward in the food web.

     2.  Because of the persistence and mobility of DDT in the
         environment and its lipophilic properties, DDT is widely
         available to and biologically concentrated by aquatic
         organisms.  Residue data collected in the environment
         demonstrate that DDT is almost ubiquitous in aquatic
         organisms in levels exceeding those occurring in the
         physical environment.

Data as of 1972

     Experimental data presented at the hearing showed that DDT can be bio-
logically concentrated by a variety of aquatic organisms at all trophic
levels.  Phytoplankton, the dominant oceanic vegetation and primary food source
for marine animals, concentrates DDT from seawater into its  cell membranes.  Water-
fleas  (Daphnia), a food source for many freshwater fish species, accumulated
9.0 ppm in tissues after three days exposure to 80 pptr.  This represents a
bioconcentration factor of 112,500 times the exposure level.  Rainbow trout
exposed to 1.0 ppm DDT (wet weight) in food and 10 pptr in water for 84 days
contained 2.3 ppm as whole body residues.  Exposure to food alone resulted
in residues of 1.8 ppm (a concentration factor of 1.8 X) and exposure to water
alone yielded residues of 0.72 ppm (a concentration factor of 72,000 X).  In
fish fed 1 mg/kg DDT/day, 73% of the DDT residues were present 90 days after
the fish were transferred to clean food.

     The ability of ODD (TDE), a metabolite of DDT, to concentrate and be
transferred up the food web is demonstrated by studies at Clear Lake, Calif-
ornia.  DDD was applied directly to the lake between 1949 and 1957 to control
a gnat at levels calculated to be 0.143 ppm in the water.  During the 1950's,
many western grebes were found dead; body fat residues were about 1600 ppm.
Residues in fish from the lake ranged from 40 ppm in carp to 2,500 ppm in
visceral fat of brown bullheads.  Since fish are the primary diet of grebes,
                                   -26-

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it is obvious that DDD levels in fish were transferred upward to the grebes.
As of 1969, residues in grebe body fat were about 350 ppm.  Egg lipid residues
were about 124 ppm in 1969 and 305 ppm in 1970.  In addition to causing mortality
among the grebe population, reproduction was very seriously impaired and resulted
in drastic population declines.  Similar environmental concentration and trans-
fer, where the source was agricultural runoff from onion fields, was found at
Tule Lake, California.  The western grebe, a stationary marsh resident that preys
on the Tule chub, exhibited monthly fluctuations in residues ranging from 1.2 to/
3.7 ppm in the organs and from 2.3 to 142.8 ppm in adipose tissue.              /

     DDT residues in the low parts per trillion were found in all of the Great -
Lakes.  Lake Michigan had the highest concentrations.  Whole body residues found
in some Michigan fish are:  bloater-chub, 8.61 ppm; lake herring, 6.71 ppm; Kiyi
chub, 13.28 ppm; yellow perch, 3.2 ppm; lake trout, 6.96 ppm (lake trout eggs,
4.44 ppm); white-eye chub, 7.50 ppm; coho salmon, 3-4 ppm in the summer of
their second year, rapidly increasing to 12 ppm in late summer as they increased
feeding.  Whole body residues found in fishes in southern waters were:  Mississippi
—small-mouth buffalo, 8.43 ppm, and carp, 13.02 ppm; Texas—gizzard shad (a plank-
ton feeder), 4.17 ppm, channel catfish, 7.27 ppm, and blue catfish, 3.98 ppm;
Alabama—carp, 3.40 ppm, and large-mouth bass, 2.44-5.15 ppm, mullet, 1.56-2.16 ppm;
Arkansas—carp, 2.03-2.09 ppm, small-mouth buffalo, 3.10-7.20 ppm, flathead cat-
fish, 3.26 ppm, and channel catfish, 2.31 ppm; Florida—channel catfish, 57.0 ppm.
DDT also has been found to concentrate in marine organisms, including marine
mammals such as seals and whales.  DDT residue data generally showed lower levels
in organisms in the lower trophic levels and higher levels in organisms higher
in the food web.                                       .
                                                       /
Data since 1972                                       /  \
                                                    ^.j    \
     Data collected and published since the hearing fully 'substantiate that DDT
is virtually ubiquitous in aquatic ecosystems and that most aquatic organisms
(plant and animal) concentrate it from the physical environment and transfer
it through the food web.  Residue determinations on wild organisms provide the
most credible evidence, while laboratory studies supply additional relevant
data and give some insight as to mechanisms.

     Concentration of DDT by bacteria (Aerobacter aerogenes and Bacillus subtilis)
has been documented by Johnson and Kennedy (1973).  The bioconcentration factor
did not change significantly with an increase in the water concentration of DDT
(0.5-5.0 ppb), but was dependent upon the concentration of bacteria in the water.
Uptake was rapid, with 80-90% of the residue being concentrated within the first
30 minutes of the 24-hour test period.  With a water concentration of 0.64 ug/1
and a bacterial concentration of 200 pg/1, A. aerogenes concentrated DDT about
1800 times.  At a similar water concentration and a bacterial concentration of
174 yg/1, B. subtilis had a concentration factor of about 3,200 times.  No evi-
dence was found that DDT was degraded during the tests.  Patil, Matsumura,  and
Boush (1972), in a study of the transformation process of DDT I in marine systems,
took samples of seawater, ocean and estuarine bottom sediments, surface films,
algae and plankton, treated them with radiolabeled DDT at the collection site,
and incubated them for 30 days in the laboratory.  The authors believed that the
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most  significant  observation was  that  DDT  is  not  metabolized  in  plain  seawater.
Most  of  the  strong  degradation  activity was found to be  associated with  the
metabolism of  DDT by algae, plankton,  organisms associated with  surface  films,
and microorganisms.   In  general,  ODD  (IDE) was the principle  metabolite.

      The removal  of dissolved DDT and  DDE  from water by  phytoplankton  has  been
documented by  several authors using a  number  of species.  Rice and Sikka (1973)
found that Skeletonema costatwn removed 93% of the compound from the water;
Cyclotella nana-73%; Isoohrysis gaU>ana-51%\  Olisthodiscus luteus-38%; Amphidiniwn
carteri-bb%; and  Tetraselmis chuii removed 33% of the  available  DDT when these
organisms were exposed to  concentrations of 1 ppb in the medium.  Sodergren  (1971)
determined that when Chlorella  pyrenoidosa was exposed to near saturation levels
of DDE,  the  cells assimilated 82% of  the DDE. No difference  in  uptake was found
between  living and  dead  cells,  indicating  that uptake  is a passive process.   An
inverse  relationship between cell density  and bioaccumulation factors  was  noted
by these authors.  Very  rapid initial  uptake  of DDT by Euglena graoilis  followed
by neither excretion nor degradation  after 5  days has  been documented  by de  Koning
and Mortimer (1971).  Slight metabolism of DDT to DDE  was recorded for diatoms
 (Nitssohia sp.J by  Miyazaki and Thorsteinson  (1972) and  conversion of  up to  12%
was found for  several species of  phytoplankton by Rice and Sikka (1973).

      Parrish (1974)  studied accumulation and  loss of DDT by American oysters
 (Crassostrea wiTg-in-ioa)  which were exposed continuously  to a  concentration of
0.01  ppb DDT for  56 weeks.  Maximum residue concentrations, based on body  weight,
 (yg/g) occurred after 8  weeks of  exposure, but absolute  amounts  of toxicant
accumulated  (yg)  occurred  after 56 weeks of exposure.  After  8 weeks,  whole  body
residue  concentrations (wet weight) averaged  0.46 yg/g (ppm), a  concentration
factor of 46,000  times the exposure level.  Total body residues  averaged 1.0 yg.
After 56 weeks, average  residue concentration was 0.37 yg/g and  the total  residue
average  was  7.0 yg  per oyster.  Residues based on body weight decreased  between
45% and  81%  during  early July and late October, apparently as a  result of  spawning,
and increased  following  these periods. Neither growth nor mortality of  exposed
oysters  was  significantly  different from that of  control oysters at the  0.01
confidence level.  Bedford and  Zabik  (1973) exposed freshwater mussels (Anodonta
grandis) to  concentrations of 0.14-0.62 ppb DDT and found that they concentrate
it about 2400  fold  in lake water. Residue concentrations were highest in  the
digestive and  reproductive tissue and  lowest  in the muscle, mantle, and  gill
tissues.

      Sodergren and  Svensson  (1973) tested mayfly  nymphs  (Ephemera daniea)  in a
flow-through system at a concentration of  761 pptr (parts per trillion)  for  a
period of 9  days  and found accumulation factors (concentration in organisms/
water concentration) ranged from  440  to 8250. p,p'-DDT  added to the system  was
rapidly  metabolized, the principle metabolite being p,p'-DDE. Accumulation
appeared to  follow  a kinetic equation  of the  first order. In experiments  with
the midge (' Chironomus teutons')  Derr and Zabik (1972) found that  exposure of
'0.07-2.2 ppb through the life cycle from egg  to adult  resulted in accumulation
of residues  in excess of 20,000 times  the water concentration.   Accumulation was
dose  dependent with DDE  residues  increasing exponentially with increased concentration
at a  given exposure time.  At any given water concentration,  accumulation
increased with exposure  time.   The process of egg deposition  eliminated  11.6-30.9%
of the adult female DDE  residues. In  a subsequent paper utilizing the same
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organisms, Derr and Zabik (1974) found no difference in the amount of DDE
accumulated by live and dead fourth instar larvae.  However, the amount of
DDE concentrated by the larvae was increased by manipulation of water hardness.
The authors proposed an adsorption-diffusion mechanism to account for the mode
of uptake and biological concentration capabilities of the midge.

     Reinert, Stone, and Bergman (1974, unpublished) studied accumulation from
water and food by lake trout (Salvelinus namaycush) in the laboratory to deter-
mine how fish from Lake Michigan accumulate high concentrations from the
environment where water concentrations are generally less than 0.01 ppb.  Groups
of yearling trout were exposed to concentrations of p,p'-DDT ranging from 0.006
to 0.01 ppb in the water and from 1700 to 2300 ppb in the food.  After 90 days,
the fish exposed only through the water had accumulated body residues of 422 ppb
DDT, fish exposed only through the food contained 464 ppb DDT, and those fish
exposed through both food and water contained 798 ppb DDT.  Maximum DDT uptake
from the food only was noted after 120 days and was 712 ppb.  After exposure to
DDT stopped, elimination of DDT was monitored.  Elimination proceeded very
slowly and after 125 days, the residues of DDT had not significantly declined.
This rapid uptake and slow elimination clearly illustrate why high body residues
of DDT are maintained by some fishes.

     Jarvinen, Hoffman, and Thorslund  (1974 unpublished) subjected fathead
minnows to nominal concentrations of 0,05 and 2.0 ppb DDT in water, with some
groups being exposed to 50 ug/g DDT (  C labeled) in the diet.  The study
lasted 266 days, through a complete life cycle.  In general, residues peaked
by 56 days for fish exposed to the low DDT water concentration and fed clean
food and for controls with DDT contaminated food, and by 112 days for the rest
of the exposed fish.  Residue levels rapidly decreased during the spawning
period (112-224 days) and rose again after termination of spawning activity.
After 266 days, fish exposed to control water, but with DDT contaminated \food,
had a body burden 2.4 times those exposed to low DDT water concentration but
fed clean food.  Fish exposed to the low water DDT concentration plus DDT  \
contaminated food had residues 3 times those exposed to the same DDT concentrations
but fed clean food.  Residues from fish exposed to the high DDT water concentra-
tion and fed DDT contaminated food were about 2 times greater than in fish exposed
to the same DDT water concentration but fed clean food.  The percentage of total
tissue residues attributable to the DDT food source remained relatively constant
after 28 days exposure at about 35% for fish exposed to 2.0 ppb DDT in water plus
DDT food, and 60% for fish exposed to 0.5 ppb DDT in water plus food.  Biocon-
centration factors were 1.2 times from the diet and over 100,000 times from the
water.  Total DDT residues were separated into DDT, DDE, and TDE.  DDE was the
principal metabolite found after 14 days exposure, indicating that DDT was
rapidly metabolized.  In the elimination portion of the study, there was
virtually no DDT elimination for the 0.5 ppb DDT water exposed fish up to 56
days, but fish exposed to this water concentration plus contaminated food had
a rapid elimination within the first 28 days followed by slower elimination.
At 56 days, more than 50% of the total tissue residues were lost and the body
burden was equal to that of the fish fed clean food.

     Several studies applying DDT to either small natural ecosystems or laboratory
model ecosystems have been performed.  Vaajakorpi and Salonen (1973) applied DDT
to a small pond in order to determine the fate of this compound in the aquatic
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system.  They noted that the maximum residues in the living organisms were
attained after the water residues started to decline.  Fifty-nine days after
DDT introduction, the water concentration was <0.01 ppm while concentrations
in perch, carp, and pike were over 1 ppm.  Mesentary adipose tissue taken from
the perch showed the highest DDT concentration at 23.8 ± 6.60 ppm.  Using a
laboratory model ecosystem, Me'tcalf (1972) found that DDT was accumulated by
the mosquitofish (Gambusia affinis) to a level 84,500 times that found in the
environment.

     Residue studies on wild organisms have shown that DDT is virtually
ubiquitous in marine organisms, from plants and invertebrates up through the
tertiary carnivores such as marine mammals.  Levels of the pesticide burden
in body tissues offer ample proof that DDT is concentrated and transferred
up the food web (Bjerk, 1973).

     DDT residues have been found in plankton from widely separated regions
of the oceans.  Residues up to 34 ppb have been reported in plankton from the
Gulf of Mexico and the northern Caribbean (Giam et al, 1973).  Williams and Holden
(1973) reported total DDT residues of 107 ppb in plankton taken from waters north
of Scotland.  This same study indicated that residue concentrations declined
seaward, implying a connection between runoff and open ocean DDT levels.

     Bjerk (1973) analyzed liver and muscle tissue from cod (Gadus morrhua)
taken from Norwegian fjords.  DDT residues in the liver ranged from 3.5 to 95.6
ppm on a wet weight basis (means ranged from 11.7 to 25.2 ppm).  Residues in
the muscle tissue ranged from 0.005 to 0.023 ppm.  Deichmann et al (1972) found
that DDT residues in the abdominal fat of the great barracuda (Sphyraena
barracuda) in Florida waters ranged from 0.03 to 107.7 ppm in young adult fish
(1.14-4.99 kg) and from 3.48 to 28.77 ppm in older fishes (12.5-18.35 kg).  Ripe
gonads contained DDT concentrations of 0.02-4.73 ppm, with lean females contain-
ing the most.  About 75% of the DDT was eliminated during the height of the
spawning period, along with most of the abdominal fat.  Castle and Woods (1972)
analyzed white croakers (Genyonerrrus lineatus) taken from the Los Angeles-
Long Beach Harbor area during the fall of 1971.  DDT residues ranged from 6.36
to 18.56 ppm in fillets without skin and from 9.44 to 30.64 ppm in fillets with
skin attached.  Means were 10.82 and 18.23 ppm, respectively.  During 1971-1972,
Giam et al (1974) collected groupers of the genera Epinephalus and Mycteropera
from six sites in the Caribbean and the Grand Bahamas.  Total residue values
in the muscle tissue ranged from very low levels (1-6 ppb) in the Grand Bahamas
up to 139 ppb in Mycteropera interstitidlis from off the Texas coast.  Kelso
and Frank (1974) analyzed whole body residues of three species of fish collected
from Lake Erie during 1972.  Total DDT residue averages ranged from 0.01 to 0.11
ppm in yellow perch (Perea flavescens), 0.02 to 0.27 ppm in white bass (Morone
chrysops), and 0.01.to 0.26 ppm in small-mouth bass (Micropterus dolomieui).
                  _/
     Plankton and trout samples collected in the Atlantic Ocean by Harvey, Bowen,
Backus, and Grice (1972) contained DDT residues at every level of the marine
food chain examined.  Most zooplankters had residues of less than 1 ppb.
Mesopelagic fish and invertebrates had concentrations ranging from 3 to 12 ppb.
The white tip shark (Carcharinus longimanus) a top carnivore, had liver residues
of 100 ppb.  Sargassum (a brown algae), the only representative of the primary
                                   -30-

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producer level, had residues of about 0.5 ppb.  In the Gulf of Maine, Zitko,
Hutzinger, and Choi (1972) found residues of DDT in sea raven muscle tissue
of 0.24 ppm; liver tissue of the white shark (' Carchayodon carcharias) had 63
ppm.  Numerous species of marine fish contained low concentrations (0.01-0.48
ppm) of DDE.  Residue analyses of invertebrates and fishes taken from Guatemalan
estuaries, where pesticide usage has been heavy, showed DDT levels as high as
45 ppm (Keiser, Amado, and Murillo, 1973).  The molly (Poeoil'La sphenops) , an
important food fish, had the highest levels.  The mullet (Mugil spj had residues
as high as 36.56 ppm.  Offshore fishes and shrimp had residues much lower than .
the estuarine fishes.  Shaw (1972) analyzed eight marine fishes in California
and found that liver residues for five species approached or surpassed the FDA
residue action levels.  Edible tissue residues were highest in the sablefish
(Anoploma fimbria) at 6.3 ppm.  In Hawaii, Bevenue et al (1972) studied residues
in various aquatic systems.  They found that residues in canal water were about
0.03 ppb and residues in the sediments (dry weight basis) were 600 ppb.  Residues
in the biota of the Ala Wai Canal (wet weight basis) were:  algae, 85 ppb; small
fish, 460 ppb; plankton and detrital feeding fish, 606 ppb; and carnivorous-fish,
864 ppb.  Ratios of residues in these organisms to water concentration were:
algae, 2833; plankton and detrital feeders, 20,200; and carnivores, 28,800.  Smith
et al (1974) monitored DDT levels in Utah fish.  DDT was detected in 85% and DDE
in 95% of the fish muscle tissue analyzed.  Levels ranged from 0.011 to 0.175 ppm
DDT and 0.007 to 0.112 ppm DDE.  In Iowa rivers, Johnson and Morris (1974) found
that total DDT levels in fish eggs ranged from 103 to 715 ppb.

     Fairly complete and consistent monitoring records have been kept in some
areas.  From these, some trends can be determined.  Butler (1973) analyzed
molluscs in fifteen coastal states between 1965 and 1972.  In many areas where
the continuity of sample collections was adequate, DDT apparently reached max-
imum levels in 1968-1969.  A pronounced decline has been evident both in size
and incidence of DDT residues in molluscs since that time.  The percentage of
samples containing negligible residues (0.011 ppm) during the last year of
monitoring compared to earlier years increased 85% in 12 of the 15 states
monitored.  In California, New York, and Virginia, the incidence of DDT residues
increased but the number of samples containing more than 0.1 ppm declined by
about 46%.  The data demonstrated that the decline in DDT residues in molluscs
has been nearly universal on the Atlantic, Gulf of Mexico, and Pacific coasts.
In Maine, levels of DDT residues in Sebago Lake salmon have dropped from 17.2 ppm
(wet weight) in 1964 to 1.42 ppm in 1973 (DeRoche, 1973).  MacGregor (1974)
analyzed monitoring data for marine organisms in the ocean off southern Califor-
nia.  He found that between 1949 and 1970, total DDT residues increased in the
biota.  The major source was apparently wastes discharged into the Los Angeles
sewer system by a major manufacturer of DDT.  As measured in myctophid fish,
p,p'-DDT and p,p'-DDE increased for several years until metabolism, excretion,
and dispersion equalled input, at which point the levels stabilized.  The more
persistent, less easily metabolized p,p'-DDE continued to increase throughout
the period studied.  The amount of DDE decreased with distance from the sewer
outfall.  Total accumulated residues of DDT dropped steadily from 4.56 ppm to
4.14 ppm between 1970 and 1973, a percentage decrease of almost 10%.

     Data obtained from Dr. Virginia Stout (personal communication, 1975),
National Marine Fisheries Service, Seattle, indicated several trends.  Residues
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of DDT and metabolites in edible portions of commercially important offshore
Pacific coastal fish show a north-south gradient, with the higher residues
generally occurring in California waters as compared to waters of the State
of Washington.  No time-trend conclusion can be made as the residues appeared
to be relatively stable within broad limits during 1970-1973.  Non-fish samples
were limited, but showed relatively low residues.  It should be noted that many
fish had residues in excess of those which laboratory studies have shown to
cause shell-thinning in certain birds, and in some cases approach the 1-10 ppm
DDE residues found in anchovies eaten by brown pelicans during their extreme
reproductive failures in the late 1960's off the California coast.

     Off Long Island, along with increasing reproductive success of fish eating
birds and dropping DDT residues, upward trends in populations are evident in the
blue crab (Callineotes sapidus) for which concentrations of a few parts per billion
are toxic to the larvae.  This species almost vanished from Long Island's Great
South Bay from the late fifties to the early seventies.  However, it began to
reappear and in 1974, was once again a plentiful and important food resource
(Puleston, 1975).

     Dr. Robert Reinert, Bureau of Sport Fisheries and Wildlife, Ann Arbor, Mich-
igan, has monitored DDT residues in Lake Michigan since the late 1960's.  Reinert
(personal communication, 1975) found that highly contaminated fish in Lake Michigan
are currently showing a downward trend which began in the mid-19601s, corresponding
to the beginning of reduced DDT use.  The trend became more evident when DDT uses
were cancelled in Michigan.  Since the nationwide ban on DDT in 1972, the down-
ward trend has continued through 1974.   Concentrations of DDT in whole
fish for years 1969-1974 are presented in Table IIIA.l.   Residues in
bloaters (Coregonus hoyi)  dropped from 9.94 ppm in 1969 to 1.34 ppm in 1974.
Lake trout (Salvelinus namayoush') levels dropped from 19.93 ppm in 1970
to 9.96 ppm in 1973.   Coho salmon (Oncorhynchus kisutch)  dropped from 11.82
ppm in 1968 to 4.48 ppm in 1973.

     Numerous reports of DDT residues found in marine mammals have been published
in the last few years.  Harbor seals (Phoca vitulina riohardii) from off the West
Coast of the United States were examined by Anas (1974) for DDT residues in the
blubber.  Off San Miguel Island, blubber residues ranged from 380.7 ppm to 2,350.0
ppm with a geometric mean of 610.7 ppm.  The lowest residues were in seals captured
off Alaska with blubber concentrations ranging from 6.8 ppm to 27.8 ppm DDT.
Harbor seals from eastern Canadian waters were found to contain total DDT residues
of 0.38-139.15 ppm in the blubber, from a trace to 2.77 ppm in the muscle, and up
to 0.47 ppm in the cerebrum (Gaskin et al, 1973).  Harp seals (Pagophilus
groenlandicus) from these same waters were found to have blubber residues up to
50.0 ppm DDT.  In European waters, Koeman et al  (1972) reported residues in the
common dolphin (Delphinus delphis).  In the blubber, DDT ranged from 1.8 to 38
ppm, DDE values were 1.8 to 117 ppm, and ODD from 0.67 to 22 ppm.  Total DDT
residues found in British grey seal (Haliehoepus grypus) blubber ranged from
5.59 ± 3.57 ppm to 10.71 ± 3.21 ppm.  In nine seals, mean DDT residues and their
standard deviations were reported for different tissues including:  liver, 1.42
± 1.38 ppm; heart, 0.32 ± 0.25 ppm; brain, 0.19 ±0.12 ppm; and blubber, 12.55 ±
6.23 ppm (Heppleston, 1973).
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Table IIIA.l
                                   DDT Residues in Lake Michigan Fish

                              Data given as whole body residues (wet weight)
                               with 95% confidence intervals in parentheses
Year Species
1969 Bloaters
Lake trout
Coho salmon
1970 Bloaters
Lake trout
Coho salmon
1971 Bloaters
Lake trout
! Coho salmon
U)
1 1972 Bloaters
Lake trout
Coho salmon
1973 Bloaters
Lake trout
Coho salmon
1974 Bloaters
Number of
Fish
120
11
28
18
13
60s-/
20
15
120^
9
10
30
29
130"/
Average length
(mm)
270
621
263
613
651
264
579
674
255
648
693
250
602
620
253
Total DDT
(ppm)
9.94
11.82
9.87
19.19
14.03
6.24
13.00
9.85
4.33
11.31
7.17
2.09
9.96
4.48
1.34
(0.33)
(2.69)
(1.44)
(3.27)
(1.29)
(1.13)
(1.76)
(1.41)
(0.48)
(3.26)
(1.09)
(0.26)
(1.36)
(0.34)
(0.052)
 aj Composite samples, 5 fish/sample

 t>/ Composite samples, 10 fish/sample
Source:  Reinert, personal communication,
         Great Lakes Fishery Laboratory
         US Fish and Wildlife Service,
         Ann Arbor, Michigan, 1975.

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     Female California sea lions giving premature birth were found to contain
DDT mean residues in the blubber 8 times higher (924 ppm) than those females
which carried pups to full term (103 ppm).  Similarly, mean PCB residues in
the blubber were 6.5 times greater (112 ppm as opposed to 17 ppm) in those
females giving premature birth.  Dieldrin residues, when detected, were low.
High mortality among premature pups was observed (DeLong et al., 1973).

     Pearce et al  (1973) provided data on chlorinated hydrocarbon levels in
blubber and liver of three species of seals from the Gulf of St. Lawrence,
Canada.  Up to 6.33 ppm DDE was found in blubber of the harp seal, 3.5 ppm
in the hooded seal, and 24.6 ppm in the gray seal.  Harbor seals from the
Bay of Fundy contained 24.6 ppm DDE; those from the Gulf of Maine contained
33.6 ppm DDE.  Marine phytoplankton represent the primary stage in the pelagic
food web (0.007-1.09 ppm) and several species of fish such as herring and
mackerel (0.09-0.67 ppm) form a secondary stage which in turn are consumed
by seals.

Conclusion

     The evidence supporting the finding that DDT can be concentrated in
aquatic organisms and transferred upward through the food web is irrefutable.
Experimental data have shown that most aquatic organisms will concentrate
residues of DDT in their tissues far in excess of levels occurring in the
surrounding medium and that residues can be transferred upward to predator
organisms.  Monitoring data of DDT residues in wild populations demonstrate
overwhelmingly that they are ubiquitous in aquatic organisms and occur in
tissues at levels much higher than levels present in the physical environment.
Monitoring data are also beginning to show downward trends in tissue residues
of DDT as a result of the ban on its use in this country.
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                          EFFECTS ON PHYTOPLANKTON
            Administrator's Finding:  DDT affects phytoplankton
            species composition and the natural balance in aquatic
            ecosystems.


     This issue is concerned with two main, interrelated, facts:  1) DDT decreases
photosynthesis by different species of phytoplankton; 2) DDT can adversely affect
phytoplankton growth rate.

Data as of 1972

     It has been shown that DDT can, in vitro, decrease the incorporation of
carbon by phytoplankton, thus decreasing the amount of oxygen evolved by these
same plants.  An example of this photosynthetic reduction has been illustrated
by the effect of DDT upon Cyclotella sp., a diatom.

     Reduction of phytoplankton growth rate has been shown for the diatoms
Skeletonema sp. and Cyclotella sp.  Actual reduction in the number of living
cells has been observed after exposure of Scenedesmus quadricauda to 0.1 ppb
and 1.0 ppb of DDT.  After 8 days, the numbers of cells were reduced by 25%
and 51% respectively.

Data since 1972

     Exposure of the freshwater algae Scenedesmus quadricauda to 5 ppm DDT for
95 minutes resulted in the reduction of oxygen production by about 90% compared
to the control culture.  Exposure to 10 ppm DDT for this same period caused
nearly a 98% drop in oxygen evolution compared to the controls (Pritchard and
Dines, 1972).  Work by these same scientists has shown that if these algae are
exposed to 5 ppm or 10 ppm DDT in the dark, then placed in a lighted situation,
photosynthesis will proceed for only 30 minutes before complete cessation.

     MacFarlane et al  (1972) have demonstrated that exposure of the marine
diatom Nitsschia delicatissima to as low as 9.4 ppb DDT resulted in a signifi-
cant reduction in photosynthetic efficiency and a reduction in the amount of
chlorophyll "a" in the cells.  Exposure to 220 ppb DDT reduced photosynthesis
by as much as 82%.  Chloroplast size was reduced and the shape distorted after
exposure to 9.4 ppb DDT.

     In studying the green algae Chlorella pyrenoidosa, Cole and Plapp (1974)
reported at a cell concentration of 1 mg algae/ml and a DDT concentration of
1 ppm, photosynthesis had been inhibited 69.4% after 7 days.

     While studying the effect of DDT on community structure, Mosser et al
(1972) found that a concentration of 10 ppb DDT resulted in a marked change
in the ratio of the diatom Thalassiosira pseudonana to the green algae Dunaliella
tertiolecta.  This altered ratio of the two species within the same system could
change the relative abundance of foods for grazing zooplankton.
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     Another factor affecting phytoplankton production is phytoplankton's ability
to withstand environmental changes.  The bluegreen algae, Anacystis nidulans, is,
under normal conditions, able to withstand waters of relatively low salinity with-
out showing adverse effects.  When exposed to 0.8 ppm DDT, this species lost the
ability to tolerate even a 1% (by weight) solution of NaCl.  This effect may
result from the interference by DDT with Na+ and K* ATPases, compounds intimately
involved in sodium transport (Batterton et al, 1972).  This loss of ability to
tolerate low salinity conditions could be of major importance in estuarine regions
where rivers wash into marine areas.

Conclusion

     Information presented during the Administrative Hearings process and made
available since the end of those hearings has clearly demonstrated that DDT can have
severe detrimental effects on several types of phytoplankton: both marine and
freshwater species.  These effects can have a significant impact upon microscopic
aquatic plants, which are a major source of the world's oxygen.
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            LETHAL AND SUBLETHAL EFFECTS ON AQUATIC INVERTEBRATES
         Administrator's Finding:  DDT oan have lethal and sublethal
         effects on useful aquatic invertebrates3  including arthropods
         and molluscs.
     This issue is concerned with the fact that DDT can result in both acutely.
lethal and chronic sublethal effects on aquatic invertebrates.  These effects
include direct mortality, reproductive failure, altered ecosystem species com-
position, and effects on higher trophic species.

     Arguments used to support this issue include:

     1.  Experimental evidence demonstrates that DDT is highly toxic
         to many aquatic invertebrates.

     2.  Experimental data have demonstrated that very low levels can
         result in reproductive failure and other sublethal effects.

     3.  DDT has resulted in acute kills of aquatic invertebrates in
         the environment.

     4.  DDT has been shown to affect higher trophic levels as a
         result of starvation following kills of prey invertebrates.

Data as of 1972

     The evidence presented in the DDT hearings contains considerable data which
demonstrate that DDT is extremely toxic to aquatic invertebrates and that very
low levels can have adverse sublethal effects.

     Experimental data, based on both static and flow-through tests, show that
aquatic arthropods are extremely sensitive to DDT at levels below about 5 ppb.
Examples of 48-hour median lethal concentrations to freshwater arthropods are:
Daphnia pulex, 0.36 ppb; D. magna, 4.4 ppb; scud, 2.1 ppb; caddisfly (one species),
3.4 ppb; and mayfly (one species), 0.3 ppb.  Similar examples for marine species
(96-hour exposure) are: sand shrimp, 0.6 ppb; grass shrimp, 2.0 ppb; and hermit
crabs, 6.0 ppb.  Additional data on grass shrimp showed that no shrimp exposed
to 2.0 ppb were killed at 10°C, but that over 75% were killed at 30°C.  Temperature
also affects toxicity of DDT to other invertebrates.  It is seven times more toxic
to the scud at 5°C than at 21°C, and twice as toxic to Daphnia at 5 C than at
21°C.

     Adult hard clams (Mercenaria mercenaria) and snails tend to be less suscep-
tible to DDT.  However, shell growth rate in the oyster was reduced by 50% at
concentrations of 7 ppb.

     Exposure at sublethal levels may result in additional effects, such as
immobilization and reproductive impairment.  Exposure for 21 days at sublethal
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levels has been shown to result in immobilization of aquatic insect larvae.
Mayfly and stonefly larvae exposed to sublethal amounts of DDT in one experi-
ment failed to emerge as adults.  In another study, Daphnia held at a 1.0 pptr
concentration of DDT in a flow-through system for 10 days resulted in a 40%
decrease in reproduction when compared with controls.  This type of effect could
reduce species numbers and affect higher trophic levels.

     DDT use has been shown to be responsible for kills of aquatic invertebrates
in field situations, with additional effects on higher trophic levels.  When
applied at 1 Ib/acre to Connecticut forests for control of gypsy moth, a variety
of forest stream insects were killed in great numbers.  Exposure of the stream
invertebrates was a result of drift, inadvertant aerial application over streams,
and runoff water containing soil, leaves, and other organic matter to which DDT
was adsorbed.  This type of organic matter also serves as a food source for
aquatic invertebrates.  Two to 4 years may be required subsequent to a kill for
complete recovery of the populations.  It was noted that less desirable species
were first to repopulate.  Similar results were found after spraying DDT at the
rate of 0.75 Ibs/acre for spruce budworm control in Canada.  Studies in Maine
and Canada found that losses of insects in this manner caused significant trout
and salmon mortality as a result of starvation.

Data since 1972

     Experimental data developed since the hearing on acute effects are in
agreement with those presented in the hearing.  Sanders (1972) using inter-
mittant flow bioassays, found that the scud (Gammarus fasoiatus) had a 96-hour
LCso of 0.80 ppb and that the glass shrimp (TPalaemonetes kadiakensis) had a
96-hour LCso of 3.5 ppb.  At 120 hours, the values were 0.60 ppb and 1.3 ppb,
respectively.  Sanders also studied various life stages of the crayfish
(Orconectes nais) and found that 96-hour LCso values were 0.30 ppb for 1-day-old
crayfish, 0.18 ppb for those 1-week-old, 30 ppb for those 10-weeks-old, and 100
ppb for mature crayfish.  Calabrese (1972) , using static tests in which water
was totally replaced every two days, found that DDT at a concentration of 50 ppb
caused over 90% mortality of oyster larvae and almost completely prevented
growth.  Muirhead-Thomson (1973) found a marked differential effect in predator
invertebrates such as dragonfly naiads (agrionid and libelluid) and Nepa as
compared to prey organisms such as mayfly naiads (Baetis sp.) and Simulium
larvae.  Many dragonfly naiads could survive an exposure to 20 ppm DDT for 1
hour, and live long enough to produce adults, while concentrations as low as
50 ppb for 1 hour could proudce near 100% mortality in Baetis naiads and Simulium
larvae.  Exposure to concentrations of 20 ppb for 1 hour resulted in 82% and 80%
mortality for Baetis naiads and Simulium larvae,  respectively.   This author also
observed that, when DDT was used as an emulsifiable concentrate formulation,
concentrations produced a progressive immobilizing effect on the naiads during
the 1-hour exposure.  This effect continued well into the holding period in
clean water but a high proportion of the naiads eventually recovered.  The
effect was not noted when the wettable power formulation was used.

     New data on reproductive effects also substantiate previous data.  Schoettger
exposed Daphnia to 10, 30, and 100 pptr of p,p'-DDT in a flow-through system and
found significantly reduced population numbers (USDI, 1973).  Reproduction was
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inhibited 10% and 40% by 10 and 100 pptr, respectively.  Derr and Zabik (1972)
studied the effects of p,p'-DDE residues on the egg viability of the aquatic
midge, Chivonomus teutons.  Egg masses were held in a 30 ppb concentration of
DDE and in control water for about 1 month until the adults emerged.  The adults
were allowed to mate and egg masses from exposed and control females were subjected
to 4 treatments:  1) DDE contaminated eggs placed in clean water; 2) DDE contam-
inated eggs placed in 20 ppb DDE contaminated water; 3) uncontaminated eggs placed
in 20 ppb DDE contaminated water; and 4) uncontaminated eggs placed in clean water.
There was significant reduction in the number of adults emerging from aquaria
containing DDE contaminated egg masses, but the presence of 20 ppb DDE in water
with uncontaminated eggs did not result in a significant reduction.  Neither did
the combination of DDE treated water and DDE contaminated eggs show significant
differences from DDE contaminated eggs in clean water.  Egg masses obtained from
DDE exposed females were of a less gelatinous consistency and had a shriveled
appearance compared to control eggs.  It was also found that about 30-34% of an
adult female burden of DDE residue was lost to the extruded egg mass, indicating
that a significantly high amount of residue in the adult was transferred to the
eggs.

     Other sublethal chronic effects of DDT have been demonstrated experimentally.
Engel, Neat, and Hillman (1972) maintained quahog clams (Mercenaria mercenccria.)
in concentrations of 2 ppb in flowing sea water for 30 weeks.  DDT was found to
reduce the glucose-6-phosphate dehydrogenase content of gill tissue to negligible
levels and to cause a consistent decrease in fructose diphosphatase activity,
which indicate that this chemical may interfere with gluconeogenesis.  Nimmo
and Blackman (1972) determined that concentrations of sodium and potassium were
lowered in the heptopancreas of shrimp (Penaeus azteaus and P. duorarum), ex-
posed to concentrations of 0.05 and 0.10 ppb of DDT for a period of 30 days.
For shrimp held at 0.1 ppb, significant differences (P^ 0.01) occurred in sodium
in all samples while significant differences (P<_0.05) did not occur in potassium
levels until the 20th day.  Significant differences in both of the cations were
found in shrimp exposed to 0.05 ppb DDT only on the 20th day of exposure.  By
the 30th day, differences were no longer significantly different.  The authors
noted that the experimental levels were equivalent to amounts of DDT which had
been shown to enter the Gulf of Mexico.

     The only recent field information pertaining to effects of DDT on aquatic
invertebrates is contained in an interim report by the Interagency Monitoring
Committee and unpublished data submitted by Steven G. Herman, The Evergreen
State College, Olympia, Washington.  This information was generated through
monitoring of environmental effects resulting from the use of DDT in the forests
of the northwestern United States for tussock moth control during 1974.  Herman
(personal communication, 1975) monitored three streams, two within the spray
boundaries and a control in a non-spray area.  In the control stream, numbers
of riffle-dwelling insects in all major taxa increased steadily throughout the
study period.  One stream in the spray area received a very light\DDT deposit
(equivalent to 0.0-0.023 Ib/acre).  Insects in this stream were little affected,
with the exception of blackfly larvae (Diptera, Simuliidae) which suffered
drastic reduction, but recovery began in 2-3 weeks post-spray.  The other stream
in the spray area received the equivalent of 0.0-0.6 Ib/acre DDT.  The treat-
ment resulted in almost total elimination of the aquatic insect fauna and no
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significant recovery was detected a month later.  Information contained in the
interim report by the Interagency Monitoring Committee consists of "casual field
observations" by environmental monitoring personnel in the field.  No hard data
are contained ^therein.  However,  the qualitative observations are in agreement
with Herman that adverse effects on the aquatic invertebrates were substantial.

Conclusion

     Data presented in the hearing record and obtained subsequently are in
substantial agreement that DDT can produce lethal and sublethal effects on
freshwater and marine invertebrates.  Experimental data and data derived from
monitoring the effects of DDT use in the field demonstrate that many aquatic
invertebrates are killed, with subsequent recovery of populations being a slow
process; that reproductive impairment and other sublethal effects may have
serious adverse effects on populations; and that higher trophic levels can be
seriously affected as a result of starvation.
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                            DDT TOXICITY IN FISH
               Administrator's Finding:  DDT is toxic to fish.


     This issue is concerned with the fact that DDT can be acutely toxic to fish.
This may occur immediately or sometime after initial exposure.

     Two central arguments support this finding:  1) Experimental laboratory data
show that DDT will kill most fish species at very low levels; 2) DDT has resulted
in numerous fish kills.

Data as of 1972

     The evidence presented in the DDT Hearings is replete with experimental
data demonstrating acute toxicity to both freshwater and marine fish.  DDT
levels which produced statistically calculated 50% mortality were normally below
about 30 ppb, with the more sensitive species being killed at less than 1 ppb.
Examples of 96-hour median lethal concentrations to freshwater fish are: fathead
minnows, 32 ppb; bluegills, 16 ppb; goldfish, 27 ppb; juvenile striped mullet,
0.9 ppb; larger mullet, 3.0 ppb; Atlantic silversides, 0.4 ppb; killifish, 1.0
ppb; and bluehead, 7.0 ppb.

     Experiments with brook trout have shown that DDT can significantly increase
mortality during the spawning period caused by natural stress factors (i.e.,
starvation, cold, and physiological changes).  DDT also has been shown to cause
delayed mortality occurring when residues are mobilized during periods of stress.
For example, when rainbow trout fed at the rate of 1 ppm wet weight and held in
a water concentration of 10 pptr for 140 days, were later fasted and subjected
to 28 days of forced swimming to simulate their spawning run, DDT was mobilized
into the brain at the rate of 0.1 ppm/day.  At the end of 28 days, 80% of the
treated fish had died.

     Fish kills resulting from DDT use have been documented on numerous occasions.
For example, dead and dying fish have been observed when heavy rainfalls followed
applications of DDT to Mississippi cotton fields.  Top predator fish are absent
from this otherwise favorable habitat.  Attempts to restock Wolfe Lake in
Mississippi with large-mouth bass were unsuccessful.  In addition, carefully
monitored DDT programs for the spruce budworm in Canada have resulted in almost
total kills of some year classes of salmon, with severe economic losses to the
commercial fisheries.

Data since 1972

     Acute toxicity data developed since the hearings in 1972 are sparse, pri-
marily because additional data would be redundant.  Korn and Earnest (1974)
tested small (14-83 mm standard length) striped bass  (Marone saxatilis) in
intermittently flowing sea water with a mean salinity of about  28 parts per
thousand.  The 96-hour LC5Q value was 0.53 ug/1 (ppb). These authors noted
that DDT levels in bay water in Tiburon, California, an important striped
bass habitat, were found
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to vary from 3-21 pg/1.  Earnest and Benville (1972) determined acute toxicity
values to the shiner perch (Cymatogaster aggrega+-a) and the dwarf perch (Micrometrus
minimus) held under both static and intermittent conditions.  The 96-hour median
lethal concentration for the shiner perch was 7.6 ppb in the static system and
2.6 ppb in the intermittent flow system.  Similar values for the dwarf perch were
4.6 ppb and 0.26 ppb, respectively.  It should be noted that the static values
are less reliable than those from the intermittent flow system because of the
small sample size and test conditions.  Gardner (1973) approximated 24-hour LCso
values for small brook trout (Salvelinus fontinalis) at about 30 ppb for p,p'-DDT
and about 45 ppb for p,p'-DDE in a flow-through system.  These values were
approximate due to small sample size.

     Jarvinen, Hoffman, and Thorslund (1974, unpublished) studied chronic effects
of DDT on fathead minnows (Pimephales promelas) during a period of 266 days, in-
cluding the reproductive phase of their life cycle.  They found that two separate
mortality periods occurred, indicating increased susceptibility to DDT at both the
fry stage up to 73 days of age and at the spawning stage when highly colored males
were most susceptible.  Fish that died during the spawning period were in relatively
poor condition and were not observed to feed.  The authors suggest that these fish
probably, utilized their fat reserves, which resulted in a release of stored DDT
into the blood where it could become toxic.  This agrees with results showing
that the fish that died had predominately lower lipid values than live fish at
the same time.  It was also observed that fish fed DDT contaminated food had a
greater mortality rate, which lasted longer before reaching a plateau, than did
fish exposed at a corresponding DDT water concentration but fed clean food.

     Reports of fish kills resulting from DDT use since 1972 are presently
lacking except very incomplete data obtained from the Tussock Moth Spray
Program in 1974.  Herman (personal communication, 1975) noted that 643 sculpin
fry were found dead in one stream within 72 hours after DDT drift reached the
stream.  The interim report by the Interagency Monitoring Committee stated
that fish populations in index areas "did not appear" to be adversely affected
by the spray project.  It was also noted, however, that fish in one of the
streams were observed gorging themselves on large numbers of dead and dying
insect larvae.

Conclusion

     Data presented in the hearing record and developed subsequent to the
hearing demonstrate that DDT is highly toxic to fish on an acute basis and
that use of DDT has resulted in fish mortality in the field.
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                      DDT EFFECTS ON FISH REPRODUCTION
                Administrator's Finding:  DDT can affect the
                reproductive success of fish.


     This issue is concerned with the fact that concentrations of DDT which
may show no adverse effects on parent fish may significantly increase the mortality
of the eggs or fry and thus result in reproductive impairment.  Because DDT is
highly lipophilic, residues are concentrated in the yolk of the eggs, eventually
utilized by the fry, and can result in their death.  DDT has also resulted in
delayed maturation of lake trout.

     Arguments supporting this issue can be delineated as follows:

     1.  DDT can be highly concentrated in fish and stored in lipids,
         which results in greater concentrations being stored in the
         eggs.  This can result in increased fry mortality during
         the stage when the fry are utilizing the yolk, which is high
         in lipid content where DDT is stored.

     2.  Egg residues have been correlated with increased fry mor-
         tality, both experimentally and from the field.

     3.  Experimental results have shown that DDT can result in delayed
         maturation of lake trout.

Data as of 1972

     Evidence presented in the hearings indicated that DDT was responsible for
the death of lake trout fry hatched from eggs taken from Lake George, a tributary
of Lake Champlain.  It has also been implicated in excessive mortality of Lake
Michigan coho salmon fry, and salmon eggs from a Maine lake exhibited lowered
hatchability when DDT levels reached 3 ppm in the eggs.  In 1969, residues of
DDT in sea trout in the Laguna Madre (Texas) were correlated with residues in
menhaden, a major food of the trout.  Reproductive impairment had been observed
since 1964 as evidenced by a decline from 30 to 0.2 juvenile trout per acre.
After residues in menhaden declined, the sea trout populations returned to 1964
levels.

     Experimental results have shown that DDT at 2.95 ppm in the eggs of lake
trout induced fry mortality and that brook trout fry reacted similarly.  Brown
trout were somewhat less sensitive.  In addition, DDT fed to fish can result
in delayed maturation.  In one study, 3-year-old lake trout failed to spawn
after being fed DDT.

Data since 1972

     Additional evidence has been published since the hearings supporting the
argument that DDT can impair fish reproduction.  Dacre and Scott (1971) reported
that an unusually high mortality (44.6%) occurred in rainbow trout (Salmo gairdneri)
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eggs and fry obtained from Lake Taupo in New Zealand.  Total DDT residues in
the fry were 4.63 ppm.  This level is above that which previous studies have
shown result in fry mortality in other species.  Smith and Cole (1973) subject-
ed male and female winter flounder (Pseudopleuroneotes americanus) to five test
treatments: 1 ppb DDT + 1 ppb dieldrin; 2 ppb DDT; 2 ppb dieldrin; an acetone
control equal in amount to the highest concentration administered with an insect-
icide treatment; and an unaltered seawater control.  Length of exposure was
variable, but was based upon previous experimentation and was generally suf-
ficient to duplicate gonad levels found in a previous field study.  In three
spawnings the percentage of fertilization differed markedly from that of the
control matings (mean = 97.8%).  Eggs containing 4.60 ppm DDT and 0.01 ppm
dieldrin had 40% fertilization, while 12% fertilization occurred in eggs contain-
ing 0.17 ppm DDT and 1.74 ppm dieldrin.  There was no fertilization in eggs with
no detectable DDT but with 1.74 ppm dieldrin.  However, in two other spawnings,
eggs which contained 3.70 and 2.39 ppm DDT, but no dieldrin residues, had 99 and
80% fertilization, respectively.  Similarly, eggs which had 0.61 ppm dieldrin and
a small amount of DDT (0.39 ppm) had over 99% fertilization.  The relations be-
tween DDT concentration in the eggs and mortality by the end of the 4th day of
development indicated dose-dependent effects.  Mortality in eggs with DDT concen-
trations of 1.62 ppm or greater was frequently associated either with failure to
gastrulate or with abnormal gastrulation where the blastulae, instead of under-
going involution as in normal gastrulation, exogastrulated and development
ceased.  At hatching, there was a much higher incidence of severe vertebral
deformities in the larvae treated with DDT than in those from the untreated
adults.  The mean incidence of deformed larvae was 39% with a range of 2 to 77%.
No abnormal gastrulation occurred in the controls and incidence of vertebral
deformities was less than 1% in both the control larvae and the larvae from
adults treated only with dieldrin.  Bone erosion and hemorrhaging at the vertebral
junctures were often observed in conjunction with the vertebral deformities when
DDT in the eggs equalled or exceeded 2.39 ppm.

     Jarvinen, Hoffman, and Thorslund (1974, unpublished) exposed fathead
minnows (Pimephales promelas) to two DDT concentrations in the water, one in
the diet, and combinations of water and diet for 266 days through a reproductive
period of their life cycle.  Fish were held in aquaria at nominal concentrations
of 0.5 and 2.0 ppb DDT, while clams used as food received water containing a
nominal concentration of 2.0 ppb DDT.  Water was supplied by a proportional
diluter, with flow rates adjusted to maintain dissolved oxygen levels at greater
than 65% saturation.  The DDT concentration contained in clam tissue fed to
fish was 50 ug/g.  Presence of DDT in the food did not significantly alter
embryo hatchability, but hatchability was significantly reduced (P=0.05) in the
2.0 ppb concentration.  In addition, there was no survival of fry beyond 5 days
in the 2.0 ppb DDT concentrations, with or without DDT contaminated food.  When
groups of fry spawned from adults under these conditions were transferred im-
mediately to clean water, the fry from adults exposed to DDT in both food and
water experienced about 2 times greater mortality than those from adults exposed
in water only.  These data agree with egg residue which show almost 2 times
greater residue levels in fry from adults in the former group.  Fry survival
was not significantly different from controls at the 0.5 ppb concentrations.
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Conclusion

     Data presented in the hearing record and developed subsequent to the hearing
are in substantial agreement that DDT has the potential to adversely affect the
reproductive success of a number of fish species and that it has, in fact,
contributed to reproductive impairment for some species in the wild.
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                      SUBLETHAL EFFECTS ON FISH
            Administrator's Finding:  DDT has a variety of sublethal
            physiological and behavioral effects on fish.


     This issue addresses all sublethal physiological and behavioral effects
on fish including:

     1. DDT differentially affects the normal utilization of some amino
        acids.

     2. DDT inhibits thyroid activity in fish.

     3. DDT has been shown to alter the temperature regime selection of
        fish.

     4. DDT can affect the impulse transmission in the lateral line of
        fish.

     5. DDT can affect learning processes of fish.

     6. Some fishes can avoid DDT containing waters.

     7. DDT has been shown to disrupt cellular energy utilization.

Data as of 1972

     Information presented during the DDT Hearings addressed this issue
as a series of sub-issues, or topics.

     After laboratory exposure to DDT, rainbow trout were exercised,
leading to abnormal utilization of 14 of 19 amino acids.

     DDT stimulated at low levels, and at near lethal doses suppressed,
normal operation of the thyroid gland in some fishes.  This gland re-
gulates metabolic rate and other important body functions.

Exposure of some fishes to DDT has led to their selecting temperature
regimes which proved lethal to the selecting fish.  This temperature
selection has been related to fish kills in nature.

     DDT can, under some conditions, affect the impulse transmission in
the lateral line of fishes.  The lateral line is one of the primary sensory
systems in most fishes.

     The ability to learn required responses and to demonstrate "natural"
behavior can be inhibited by DDT.

     The ability of some fishes to avoid waters containing DDT has been
demonstrated.  In the case of the sheepshead minnow (Cyprinodon varie-
gatus) this avoidance of DDT can lead to deflection from spawning areas.
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     The action of ATP and its enzymes are affected by DDT.  This
ATPase activity is one of the main driving forces of cellular syn-
thesis, and, in fish, NaKMg ATPase is deeply involved in osmoregu-
lation.

Data since 1972

     Information published recently has further documented the effect
of DDT upon temperature selection in fishes.  Javaid (1972a, 1972b)
has determined that exposure to DDT can alter both temperature selec-
tion and the absolute amount of fish activity at the resulting selec-
ted temperature.  He found that when exposed to DDT, Atlantic salmon
(Salmo salar) selected lower than acclimation temperatures (0-10 ppb
DDT), and higher than acclimation temperatures (10-100 ppb DDT).  Cold
temperature shock was noted for Atlantic salmon and brook trout (Sal-
velinus fontinalis).   DDT exposed Atlantic salmon displayed decreased
activity when compared to control fish.  Rainbow trout (Salmo gaivdneiri-)
showed selection only for higher than acclimation temperatures, and
exhibited symptoms of warm temperature shock which were followed by
death.  The mechanism affecting changed temperature selection was post-
ulated to be altered metabolic rate.

      These effects on fish by DDT also have been noted by Peterson (1973)
and Gardner (1973), but the mechanism postulated by Peterson was desta-
bilization of the nervous system by action on neuron membrane function.

     Several behavioral alterations have been tied to exposure to DDT.
Hansen (1972) found that when mosquitofish  (Gccmbusia affinis) had been
exposed to 5, 10, or 20 ppb DDT they selected waters of significantly
greater (P=0.05) salinity than did the control fishes.

     DDT avoidance by mosquitofish  (Hansen et al, 1972) was found to
occur only when the fish could choose between uncontaminated and con-
taminated waters, and then only when the DDT concentration was above
the 24-hr LC^Q.  When presented with a choice between two contaminated
waters, the fish either did not discriminate or they chose the water
with the higher DDT level.

     Exposure to DDT at near the 96-hr LC^Q for 24 hours caused Atlantic
salmon parr (Salmo solar) to become hypersensitive to external stimuli
and temporarily improved their ability to learn a conditioned response
(Hatfield and Johansen, 1972a).  Exposure to this level of DDT for 24
hours did not seem to affect the ability of Atlantic salmon parr to es-
cape predation by brook trout  (Salvelinus fontinalis) (Hatfield and
Johansen, 1972b).

     The effect of DDT upon "natural" behavior of fishes has also been
documented.  Exposure of goldfish (Carassius auratus) to 10 ppb of p,p'-
DDT for 4 days has resulted in the disruption of normal, nonrandom
exploratory behavior (Davy et al, 1973) and the alteration of normal
spontaneous locomotive display patterns (Davy et al, 1972).  The changes
in the pattern of locomotive display may be due to DDT's effect on short-
term memory.
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     After a 7-day exposure to 1 ppb DDT and subsequent placement into clean
water for 3 days, the normal swimming and schooling behavior of goldfish was
significantly affected (Weis and Weis, 1974).  The treated goldfish swam faster
(P<0.001), turned more often (P<0.005), and occupied a greater area (P<0.02) than
did control fish.  When disturbed, the goldfish schools scattered further and
regrouped more slowly than did control schools.  This change in schooling lessens
the protective advantage of schools.

     Investigations into the disruptions by DDT of processes involved in cellular
energy utilization and transfer have provided more than ample evidence that DDT
is capable of interfering with adenosine triphosphate phosphohydrolases (ATPases).

     Concentrations of 10~5M DDT have resulted in 23% inhibition of NaKMg ATPase,
15% reduction of NaK ATPase, and 34% reduction of Mg ATPase in rainbow trout gill
microsomes.  Further inhibition was reported for ICT^M DDT.  Inhibition of NaKMg
and Mg ATPases was higher when DDD was used instead of DDT (Davis et al, 1972).

     The effect of DDT on mucosal ATPases (Na+, K+, and Mg2+) has been invest-
igated by Janicki and Kinter (1971a, 1971b).  Inhibition of these ATPases, which
are involved in sodium transport suggests that DDT may interfere with the osmo-
regulatory ability of fishes.  More recent work by Weisbart and Feiner (1974),
although it does not prove a connection between DDT and osmoregulation, did find
abnormalities in the ionic makeup of blood plasma from goldfish exposed to 0.035
ppm DDT.

     Not specifically addressed by the Administrator is the finding that p,p'-DDT
can cause developmental defects in fish.  Fry of grunion (Leuresthes tenuis), after
being exposed to p,p'-DDT at a concentration of less than 1 ppb, showed evidence
of significant pectoral ray asymmetry.  When eggs taken from relatively polluted
waters off California (a region of relatively high past DDT input) were not exposed
to further DDT, their fry showed significantly greater pectoral fin ray asymmetry
than did fry from a nonpolluted area (Valentine and Soule,  1973).

Conclusion

     The Administrator's findings concerning the sublethal physiological and
behavioral effects of DDT on fish have been supported by investigations published
since those findings, although data on avoidance suggests that this phenomenon
may not occur at environmental levels.  Additional behavioral and developmental
effects of DDT have been illuminated which further reinforce the conclusion that
DDT can cause changes in fishes that are less immediately noticeable than death,
but may lead to an inability of those affected fish to successfully compete in
the aquatic environment, thus having the same ultimate effect.
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                 BIOACCUMULATION IN TERRESTRIAL ORGANISMS
          Administrator's Finding:  DDT can be concentrated and trans-
          ferred through terrestrial invertebrates3 mcamals, amphibians,
          reptiles, and birds.


     The 1972 opinion of the Administrator, EPA, listed among the findings
a major heading, Activity in Food Chain and Impact on Organisms.  Basic find-
ings indicated that DDT is concentrated in organisms and transferred through
food webs, and more precisely, that DDT can be concentrated in and transferred
through terrestrial invertebrates, mammals, amphibians, reptiles, and birds.
These statements infer that most wild vertebrates are exposed to DDT and
metabolites in their diet and these contaminants are bioaccumulated in the
tissues.  Kinetics, or movement and change, describes the action and metab-
olism of chemicals entering the animal body.  In the body, chemicals can make
changes or be changed, accumulate in tissues, and ultimately leave through
excretion, lactation, deposition in eggs, or placental transfer to unborn
young.  The pattern of events may be somewhat variable, depending upon whether
exposure is at sublethal levels or sufficient to cause death of the organism.

Data as of July 1, 1971

     A vast body of information on DDT residue accumulation was presented in
exhibit and transcript form during three years of intensive administrative
inquiry into the uses of DDT.  Experimental studies as early as 1947 showed
that poultry fed diets containing DDT accumulated DDT in their eggs and tis-
sues, particularly in fat.  A similar residue accumulation in wild birds was
first demonstrated in 1958 when death of birds followed DDT applications.
The early literature on food web relationships on land involved contaminated
soil and leaves •*• earthworms -*- robins trophic level movement.  Fish-eating
birds,  (such as ospreys and pelicans) and flesh-eating avian predators (hawks,
owls, eagles), absorbed concentrations which affected reproduction, behavior,
and sometimes resulted in death.  Very minute residues, some in the parts-per-
trillion range, may be lethal to the larvae of marine organisms.  Wild mam-
mals accumulated DDT residues from food and were affected variously depending
upon their ability to metabolize or excrete the parent material and metabolites.
Residues in a wide variety of organisms confirmed the world-wide distribution
of DDT  and metabolites through contamination of soil, air, and fresh and
marine waters.

Conclusion

     Data published since cancellation of most DDT uses have corroborated and
provided a more substantial data base to confirm earlier findings.  Recent
data can be summarized as follows:

     1.  DDT and metabolite residues continue to be found world-wide
         in all trophic levels of the terrestrial ecosystem.
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     2.  Certain species (fish-eating birds and raptors) at the top
         of the food web are still affected adversely as evidenced
         by behavioral changes or reproductive failure.

     3.  Widespread agricultural and forestry uses of DDT in North
         America and northern Europe have declined markedly since
         the mid-1960's.  Concurrent with reduced application, there
         has been a gradual decline of residue body burdens in
         certain nontarget species, e.g., songbirds and ospreys.
         Slight, but encouraging, recovery of some nearly decimated
         local nesting populations has been observed.

     4.  Means of transport for this persistent pesticide point
         towards ultimate deposition in the ocean environment.  Res-
         idues in ocean waters may already have peaked.

Data since July 1, 1971

     Bioaccumulation in Invertebrates and Lower Vertebrates

     The effects of organochlorine insecticides on earthworms have been
reviewed (Davey, 1963).  Results reported vary, but establish that worms are
more tolerant of DDT than arthropods, with little risk of causing worm popu-
lation reductions.  However, consumption of DDT-residue laden worms by birds
or insectivorous mammals is of concern.  In the case of robins, die-offs
have resulted from this route of exposure.  DDT concentrations in worms in-
creased from 0.15 ppm when soil residues were 1 ppm to about 45 ppm where
soil levels were 64 ppm (Davis, 1971).

     Worms in soils containing 1 ppm DDT accumulated the maximum amount of DDT
residues from the soil (from 1-4 ppm DDT) after about 1 month followed by a
slight loss, and then reached an equilibrium at 3-4 ppm DDT plus DDE in 5 or
6 months (Edwards and Jeffs, 1974).

     Almost all micro- and macroarthropod forest litter taxa analyzed by
Klee et al (1973) metabolized the two major isomers of DDT (o, p'-DDT and
p,p'-DDT) into p,p'-DDE after introduction into the food chain via resistant
carrier Collerribola.  Manley (1971) pointed out that p,p'-DDE accumulates very
little in microarthropods compared with macroarthropod predators.

     The effects of pesticides on soil microflora have been studied exten-
sively, but those on soil protozoa have been neglected.  Predatory protozoa
play an important role in ecosystems such as soil, water, rumen fluid, and
sewage by regulating bacterial populations (Alexander, 1969).  Any effect a
pesticide has upon these protozoa may be reflected in the bacterial popula-
tion of the particular ecosystem.  Euglena and PaTamec-lim concentrated DDT
in their cells 964 times when exposed to 1 ppm aqueous mixture of the insec-
ticide without obvious adverse effects.  Applications of p,p'-DDT to a
garden soil at rates of 5 and 50 ppm inhibited soil protozoa (MacRae and
Vinckx, 1973).
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     Dindal and Wurzinger (1971) showed that the terrestrial snail, Capaea
hortensis, accumulated high whole body levels of DDT wet weight residue
after 3 hours exposure (24 ppm) but were reduced and stabilized after 1 day
at 11 ppm.  This invertebrate serves as a food source of concentrated pes-
ticide to vertebrate predators.  Snails and slugs as nontarget organisms
accumulated DDT residues at concentrations equal to or considerably higher
than the surrounding environment.  The concentration factor varied from
0.14 to 17.93 times that of the surrounding'terrestrial ecosystem.

     Gish (1970) reported that snails in two agricultural areas of the
United States averaged 3.5 ppm total DDT residues.  Slugs in the same sites
contained up to 200 ppm, and earthworms up to 50 ppm.  Earthworms in other
sites sometimes contained 500 ppm.  Thus snails in some agricultural areas,
particularly in the United States, are likely to have suffered reduced shell
growth as evidenced by Roman snails (Helix pomatid) treated with various
amounts of p,p'-DDT from 2 weeks of age to hibernation (Cooke and Pollard,
1973).  Relatively low doses of DDT significantly reduced shell and oper-
culum weight whereas higher doses of DDT did not cause this response.  Res-
idues varied from 7.2 to 160 ppm, depending on the rate of exposure.

     Snakes collected near Texas land treated with DDT and in untreated
areas were analyzed for residues.  All snakes contained some residues from
a trace to over 1000 ppm DDE.  The mean total residues from the pesticide
use area were 14 to 386 times greater than in the nonuse area.  Insecti-
cide residues were higher in semiaquatic snakes than in terrestrial species.
In a female cottonmouth, total residues in brain (1.4 ppm) and muscle (0.4
ppm) were 308 and 1080 times less, respectively, than those in fat.  Residues
(396 ppm) in the fat of embryos from this snake were similar to the maternal
fat,but whole yolk residues were only 28.5, indicating placental transfer
(Fleet et al, 1972).  Crocodile eggs from Rhodesia were found with residues
of 1.75 ppm total DDT (Billing and Phelps, 1972).

     Bioaccumulation in Birds

     Because of its persistence in the environment, widespread appli-
cation, and dissemination through food and water, DDT is found virtually
all over the world in both terrestrial and aquatic ecosystems.  By 1958, there
were indications that DDT and its metabolites might be associated with declines
in avian populations at the top of food chains.  Even small migratory songbirds,
not at the highest trophic level, carry body burdens of DDT and metabolites.
Such migrants are conspicuously obese, especially in the autumn, when subcu-
taneous and abdominal fat depots comprise 30% or more of body weight.  Anal-
yses of 10 species of migratory songbirds killed when they flew into tele-
vision towers in Florida showed a progressive decline of contaminants in their
fat from 1964 to 1973.  In 1969, the mean for 5 species was 17.8 ppm but in
1973 the mean was only 2.06 ppm.  This decline is apparently associated with
the decreased usage of DDT in the United States during the same time (Johnston,
1974a).
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     Osprey, or fish hawk, population size has been carefully monitored for
many years.  A significant decrease in bird numbers in many East Coast nesting
colonies had been noted for more than 20 years.  Now an important reproductive
increase has been documented on Gardiners Island off Long Island, New York.
The number of fledged young dropped from about 600 in 1948 to a low of only 4
each in 1965 and 1966.  This increased to 18 in 1973 and 26 in 1974.  Eggs
(unhatched and overdue) collected in the mid-1960's contained 11.3-13.8 ppm
total DDT.  One such egg collected in 1974 contained only 3.59 ppm total DDT
and a dead 3-day-old chick, 1.34 ppm (Puleston, 1975).

     Six osprey and two eagle eggs were collected and analyzed from the Gulf
of Bothnia near Finland.  Eagle eggs contained about 175 ppm and osprey eggs
about 15 ppm DDE.  The higher amounts in eagle eggs were suspected from
1) the longer life-span of the eagle and 2) its higher position on the food
chain (Koivusaari, 1972).

     In 1971 only one-fifth of 113 hen sparrowhawks in a 500 knr area in
Scotland hatched all their eggs successfully, two-fifths had at least one
egg disappear, in one-fifth all eggs vanished, and another fifth failed to
nest.  Some causes of failure were thin eggshells, egg breakage, and embry-
onic death.  These factors contributed to a reduced potential young output
of 61 percent.  Significant organochlorine residues were found in all ten
eggs taken from the area.  DDE varied from 48-441 ppm, dieldrin from 10.0-
110.6 ppm, and PCB from 32-159 ppm.  The proportion of occupied sparrowhawk
sites increased between 1967 and 1971, but the proportion of pairs producing
young and the mean brood size in successful nests remained consistently low
(Newton, 1973).

     There were some 160 peregrine falcon eyries in Ireland in 1955.  Those
which successfully fledged young decreased from 36 in 1967 to 14 in 1970
(Chambers and Norris, 1971).  Changes in land use, afforestation, and road
building may be partially responsible.  Residues (wet weight) in tissue
samples (48 birds of 13 species) were p,p'-DDE (0-1.85 ppm) and dieldrin
(0-0.71 ppm).  In 1970, peregrine falcon eggs contained 9.8 ppm p,p'-DDE.

     A preliminary note on organochlorine residues in eggs of fish-eating
birds on the Florida west coast showed that the eggs contained DDE ranging
from 2.46 for a brown pelican to 20.9 ppm (oven dry weight) for a snowy egret.
Other species showed DDE egg residues in ppm as follows:  black skimmer - 4.5:
least tern - 3.17; laughing gull - 11.7: white ibis - 8.74; great egret -
10.36; and great blue heron - 20.0 ppm (Lincer and Salkind, 1973).

     Residues of p,p'-DDE in double crested cormorants ranged from 8.63-29.4
ppm  (wet weight), in herring gulls from 2.83-5.67 ppm, and black ducks
averaged 1.50 ppm.  Sampling sites were from the Bay of Fundy, Canada (Zitko
and Choi, 1972).

     Cormorants in The Netherlands increased from 800 breeding pairs in 1962
to 1500 in 1971.  Spoonbills declined from 500 pairs in 1950 to 150-200 pairs
                                     -52-

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in 1971.  Purple heron increased to 900 in 1971.  Heron declined from 8500 in
1935 to 3750 in 1964.  Sandwich terns reached a low of 650 pairs in 1965 and
then increased to 2900 pairs by 1971.  Chlorinated hydrocarbons were believed
responsible.  Early in the 1960's, the common tern population greatly de-
clined from approximately 10,000 pairs to a few thousand.  Little tern de-
clined until the last nests were unsuccessfuly reared in 1957.  There was no
breeding in 1972.  Kingfishers declined 80% in the last 25 years from 250-500
to 50-100 pairs in 1970.  Persistent pesticides may have a lethal effect on
such piscivorous birds as those referred to above at the top of a food chain.
Population declines, in most cases, are of a local or temporary nature
(Rooth and Jonkers, 1972).

     The use of organochlorine insecticides has been restricted almost exclu-
sively to terrestrial areas.  Nevertheless, several recent investigations
have revealed substantial concentrations of residues in vertebrates in
marine environments.

     Herring gull eggs from Norway varied from 0.2-5.4 ppm DDE and common gull
eggs from 0.2-3.5 ppm.  DDT occurred from 0.1-0.3 ppm in only herring gull
eggs.  There were only slight differences evident in eggshell thickness
(Bjerk and Holt, 1971).

     Swan and pochard eggs from two locations in Denmark were collected and
examined.  Swan eggs from one site contained mean values of 0.151, 0.333, and
1.02 ppm of DDT, DDE, and PCB, respectively.  The DDT was believed to come
from the Baltic Sea.  Swan eggs from the second site contained 0.335 ppm DDE
and 3.34 ppm PCB; pochard eggs contained 2.015 ppm DDE and 40.7 ppm PCB.
This high PCB content may be attributed to the pollution from an adjacent
town.  Pochards are higher on the food chain and contain more residues than
swans (Bloch and Kraul, 1972).

     Levels of chlorinated hydrocarbon pesticides were determined in Rhode-
sian animals.  Pesticide residues were widespread, the highest levels being
from agricultural regions.  Residues ranged from none found to 43.41 ppm
total DDT in a black flycatcher liver (Billing and Phelps, 1972).

     Quail from Alabama soybean fields with a previous history of insecticide
application had DDT residues averaging 17.0 ppm in their meat, while quail
from soybean fields with little or no previous insecticide application aver-
aged 1.68 ppm in their meat (Causey et al, 1972).

     Laying Japanese quail were given 9 mg/kg/day of p,p'-DDT.  Egg produc-
tion, egg weight, and eggshell thickness were not altered.  The mean total
residue level in control birds never exceeded 1 ppm.  The p,p'-DDT metabo-
lite reside in treated birds ranged from 27 ppm in the liver to 444 ppm in
fat.  The DDE residues ranged from 8 ppm in the liver to 82 ppm in fat.  ODD
was highest in the liver at 15 ppm.  DDT and metabolites in eggs and fat
reached a peak at 6 weeks (McBlain et al, 1974).

     DDT and its metabolites were studied in a diverse Arizona ecosystem
downwind from an area of insecticide application.  Soil residues ranged from
3.6 to 6700 ppb and samples of Harlequin and Gambel's quail livers ranged
from 500 to 2800 ppb (Laubscher et al, 1971).
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     Bioaccumulation in Mammals

     The ubiquitous nature of DDT and metabolite bioaccumulation in mam-
malian tissues is illustrated by the following examples:

     DDT was analyzed in the brain tissues of shrews, voles, and mice from
DDT contaminated Canadian forest areas.  Residues occurred in low, but detec-
table,amounts in brain tissue.  The average concentrations for shrews, voles,
and mice were 0.039, 0.024, and 0.027 ppm, respectively.  Shrews, which are
at a higher trophic level, accumulated higher residues than voles or mice
(Sundaram, 1972).

     Residues of DDT and its metabolites ranged from 6-929 ppb in white-footed
mice and up to 2770 ppb in cotton rats from the Tucson-Nogales area of Ari-
zona (Laubscher et al, 1971).  Deer fat samples ranged up to 107 ppb, rabbits
to 235 ppb, and packrats to 2.9 ppb from the same region.

     Two species of shrew, Blarina brevicauda and Sorex dneveus, were studied
in a 4.05 hectare old-field ecosystem treated with 0.92 kg/ha ^"CL-ring-
labeled DDT in 1969.  The mean radioactive DDT levels in Blarina liver (10
ppm), muscle (10 ppm), brain (4 ppm), and fat (135 ppm) were the same in 1970-
1971.  Consumption of slugs may have caused DDT peaks in fat of 243 ppm in
1970 and 236 ppm in 1971.  Sorex3 unlike Blarina, had increasing DDT from
1969 to 1971.  Mean levels of DDT residue in muscle (4 ppm) and viscera (3 ppm)
were not influenced by sex, but by breeding condition (Forsyth and Peterle,
1973).

     Five short-tailed shrews, Blarina brevieaudaj were fed earthworms con-
taining about 16.55 ppm DDT for 3 weeks, and five were fed DDT-free earth-
worms.  After 4 weeks, the DDT-exposed shrews had a mean DDT level of 7.59
ppm in liver and 14.70 ppm DDT in fat.  No DDT was found in control shrews
(Braham and Neal, 1974).

     Samples of rabbit and deer meat from Alabama soybean fields subjected to
varying degrees of insecticide use were analyzed.  DDT and its metabolites
were the only insecticides occurring consistently, averaging 3.00 and 2.47 ppm,
respectively, for deer and rabbits from treated fields.  Fields with little or
no history of insecticide use averaged 0.10 and 0.05 ppm DDT, respectively,
for deer and rabbits (Causey et al, 1972).

     Residues of DDT and its metabolites from Mississippi deer collected in
1970 ranged up to 1.29 ppm (Baetcke et al, 1972).

     DDT was sprayed in 1964 at 1 Ib/acre on a 525,000 acre area in Idaho with
the periphery of 41,000 acres receiving 0.5 Ib/acre (Benson and Smith, .1972).
Deer were analyzed in 1964 and 1969.  In 1964, total adipose tissue DDT was
<0.1 ppm in control animals, but deer from the sprayed area had a mean of
19.36 ppm.  The mean level of p,p'-DDE in exposed deer was 17 times higher
than controls and 350 times higher than controls for p,p'-DDT.  Adipose pes-
ticide residues in deer from an unsprayed area in 1969 differed little from
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those in 1964 (mean of 0.08 versus 0.05).  The mean total DDT of animals in 1969
from the sprayed region was only 0.18 ppm compared to 19.36 ppm  in 1964.

     Chlorinated hydrocarbon insecticide residues were measured in wild mink
by Franson et al (1974).  Total residues of DDT and related compounds in the
adipose tissue ranged from 0.27-9.51 ppm.  Of the total, p,p'-DDE comprised
23-80%, p,p'-DDT 4-50%, p,p'-DDD 6-41%, and p,p'-DDT 2-34%.

     Total DDT in fish fed to mink ranged from 0.12 to 18.23 ppm.  No clini-
cal signs were observed on mink with this diet although reproduction was
lessened.  Two months of feeding 10 ppm PCB's plus 10 ppm DDT produced a highly
significant reduction in growth and, after 4 months, loss of weight (Aulerich
et al, 1973).

     Badgers in the Netherlands contained up to 0.50 ppm DDE, 0.13 ppm ODD,
and 0.13 ppm DDT.  The badgers were not threatened by this degree of pesti-
cide contamination (Keij and Kruizinga, 1972).

     Black bear were analyzed for pesticides in Idaho.  The highest p,p'-DDE
level found in any bear was 2.055 ppb; total DDT was only 2.89 ppb.  The
lowest amount was 0.320 ppb total DDT.  Bear meat had little or no signifi-
cant pesticide residues to endanger the health of people (Benson et al, 1974).

     Analysis of 30 British bats from 1963 to 1970 showed 100% contained DDE
in the liver (0.30-53.7 ppm), and 82% contained DDT (1.3-28.6 ppm).  The
mean levels of these materials in the liver were 10.68 and 4.62 ppm, respec-
tively.  Pipistrelles were very sensitive, and when fed DDT, none died at
less than 45 mg/kg, half died between 45-90 mg/kg, and all died when fed
more than 90 mg/kg.  Mortality began when liver and whole body residues of
DDT plus DDE reached 43 and 45 ppm, respectively (Jeffries, 1972).

     Five samples of adult Australian bats (88 animals) had a mean of 15.9
yg total DDT in their bodies while two samples of juvenile bats (28 animals)
contained only 8.8 pg total DDT/bat.  One wild bat contained 56 pg total DDT.
The DDT levels in these bats are a cause for concern particularly since this
was not an area of extensive DDT use (Dunsmore et al, 1974).

     Livers from Rhodesian herbivores were analyzed for DDT and its metabolites.
Elephants and impalas showed traces of ODD,  DDE,  and DDT; total DDT in waterbuck
liver reached a high mean of 0.24 ppm (Billing and Phelps,  1972).
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                    TOXICITY OF DDT TO BIRDS
          Administrator 's Finding:  Birds can mobilize lethal amounts
          of DDT residues.
   Some wild birds have been affected adversely by mobilized DDT and its
metabolites.  The residues are absorbed from their diet and bioaccumu-
lated into tissues.  The identification of lethal and sublethal toxic
residue limits has been well documented under controlled conditions.
Of particular importance is the movement or mobilization of residues
through the body.  Sex, age, and stress conditions (migration, cold
weather, starvation, etc.) are proven contributing factors affecting both
residue limits and species tolerance.  While it is difficult to assess
the impact in field populations, the identification of abnormal toxicant
levels  (consistent with those established under laboratory conditions)
justifies the assertion that ,DDT and its metabolites are responsible for
increased avian mortality and, at sublethal levels, may cause mutagenicity.
Birds can contain concentrations in amounts sufficient to prevent carrying
out normal functions; death can be caused if conditions favor mobilization
of stored residues to sites of action or target areas such as the brain.
Only the presence of toxic residues, consistent with levels known by con-
trolled study to be associated with lethality, can justify the conclusion
that a certain chemical agent is responsible for mortality.

Data as of 1972

     Birds are endangered when DDT and ODD residue levels reach 30 or
more ppm in the brain.  Birds store DDT in their fat.  Under stress,
body fat is utilized, DDT enters the bloodstream, and hence, finds its
way to the brain.  The brain does not tend to lose its fats and accumulates
DDT from other body parts.  Death from mobilization can occur more than 4
months after DDT intake has ceased.  DDT and ODD body residues as low as
10.10 ppm can concentrate to 41.27 ppm in the brain.

     Heavy application of DDT in forests (up to 5 Ibs/acre) have
eliminated or reduced local bird populations in Pennsylvania, Maryland,
and Texas.  Many birds died when elms were treated for Dutch Elm disease
in urban areas.  DDT has proven lethal to ducks, pheasant, and black birds
exposed to treated rice; songbirds feeding in treated vegetable plots; and
thrushes in apple orchards.

Data since 1972

     DDT residues are hazardous to birds during stress periods.  DDT stored
in fat deposits can be metabolized and eliminated very slowly without
apparent ill effects as long as the organism does not utilize fat reserves
for energy.  Deprivation of food was used to simulate the stress situation
encountered on long migratory flights.   Prior to their semiannual  migrations,
birds build up large fat reserves to be used as energy sources for their
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long flight.  Robins wintering in colder areas are often exposed to condi-
tions requiring mobilization of fat reserves (Sodergren and Ulfstrand,
1972).  Fat metabolism proceeds at an accelerated rate and residues are
relocated via the bloodstream.  When the carcass loses some fat, levels of
organochlorine residues, in terms of fresh weight, decrease.  Consequently,
due to the remaining low fat content, residue levels, in terms of fat
weight on a ppm lipid basis, increase.  Although the fat content decreases
in the breast muscles, the residue levels, in terms of both fresh and fat
weight, increase.

     Van Velzen et al (1972) evaluated in cowbirds the lethal mobilization
of DDT and the effects of food deprivation on the distribution and loss of
DDT, ODD, and DDE.  Cowbirds were fed 100 ppm DDT for 13 days, followed by
a full ration of untreated food for 2 days.  The following 4 days, the
ration was reduced to 6 grams food/bird/day and then for 10 days untreated
food was presented.  During the 4 days of food restriction, 7 of 20 birds
died.  No birds died when fed 100 ppm DDT or when the ration was reduced,
indicating that neither weight loss nor dosage alone was sufficient to
cause mortality.  Also, 2 male kestrels died after 14 and 16 months on a
diet containing 2.8 ppm DDE (Porter and Wiemeyer, 1972).  The kestrels
died during the season weight loss and depletion of fat reserves caused by
the stress associated with reproduction and molting.

     When fat reserves are utilized, there is an increased concentration of
DDT and its metabolites in the fat tissues, as well as a corresponding in-
crease in other tissues because DDT is generally lipophilic and found in
lipid-rich organs and tissues.  Bobwhites fed 100 ppm DDT for 10 weeks had
a much higher quantity of liver lipids than birds not fed DDT (15.4 versus
12.9 percentage dry weight) (Haynes, 1972).  This increase in liver lipids
is enhanced by an accelerated mobilization of lipids from the adipose tis-
sue during food deprivation.  Mobilization is known to be affected both by
substances toxic to hepatic cells and hormonal influences.  Bobwhites, de-
prived of  food  after DDT administration, had liver lipids of 34.4 percentage
dry weight  for  DDT-fed birds compared to only 20.6 percentage dry weight for
birds not  given DDT.  This  increase in liver weight, liver residues, and
percentages of  lipid in the liver was also noted by Dieter  (1974) for coturnix
and Jefferies and  French  (1972)  for pigeons.

     During stress periods  resulting  in weight loss, toxicants stored in
fat are  released as lipids, are  discharged into the blood, and are redeposited
at other sites.  When sufficient quantities of toxicants are present in
the brain,  death results.   The brains of the 2 dead kestrels contained DDE
residues of 213 and 301 ppm (wet weight) compared to 14.9 ppm for 11 adult
males not  dead  after 16 months  (Porter and Wiemeyer, 1972).  Weight loss
for birds  on a  DDT diet was much greater than for birds not given DDT.  DDT-
dosed cowbirds  on  full ration lost 0.2% body weight while untreated birds on
full ration gained 2%  (Van  Velzen et  al, 1972).  Cowbirds, that died during
weight loss, exhibited a rapid increase in the brain residues when compared
to birds sacrificed immediately  before food restriction  (61 versus 5 ppm
total DDT).
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     To better establish the role of DDT as the cause of illness and
death in wild birds, the effects of various dietary levels of DDT on
several species were studied by Hill et al (1971).  Weight losses in
farm-reared bobwhite quail were significant when concentrations of
DDT reached 400 ppm in the diet (about 3%).  The average wet weight
of DDD + DDT residue levels in brain associated with death were: house
sparrow, 43.2 ppm (with 32.6 ppm giving an indication of DDT poisoning);
wild bobwhite, 31.3 ppm; farm-reared bobwhite, 28.4 ppm; cardinal, 26.7
ppm; and bluejay, 23.0 ppm.  With the latter species, only 20-25 ppm
appeared to implicate DDT as the lethal agent.

     Comparison of stressed versus.unstressed birds ascertained that
stress was associated with increased brain and liver residues, but
decreased carcass residues.  Penned cormorants were fed daily 2, 5,
and 10 mg of DDT, DDD, and DDE, respectively (Greichus and Hannon, 1973).
At 9 weeks, food was cut in half for some birds, creating a stress
situation.  A marked increase in the proportion of DDE and a decrease
in DDD and DDT was found in the brains of stressed birds compared to
controls.  Brain:carcass residue ratios were higher in stressed than
nonstressed groups.  Average brain concentrations of DDD ranged from
24-85 ppm wet weight in cormorants which died from the toxic effects
of DDT, DDD, and DDE and from 0.4-29 ppm in survivors.  Apparently,
30 ppm was diagnostic of lethality.   DDT residues, in carcasses of cowbirds
dying during weight loss, decreased from 119 to 97 ppm wet weight (Van
Velzen et al, 1972).  Cowbirds, sacrificed prior to food restriction,
showed no such reduction in DDT residues.  In contrast, DDD and DDE
residues increased from 19 to 41 ppm and 8 to 18 ppm, respectively; birds
sacrificed prior to food restriction showed no increase in residues.
Stress caused a mobilization and redistribution of DDT residues from the
carcass to the brain.

     Sex and age also influence the quantity of DDT-related residues
present in the system of birds.  DDE residues were more variable and
attained higher levels in male mallard and black ducks than in females
of the same species (Heath and Hill, 1974).  This may be due, in part,
to the female's ability to eliminate some pesticide residue through
eggs.  Grocki and Johnston (1974) found that adult cuckoos had higher
total DDT levels than first-year birds (1.55 versus 0.95 ppm lipid weight
total DDT); an adult would have more time to accumulate pesticides than
an immature bird.

     An accurate assessment of the cause of wild bird abnormalities or
death is extremely difficult because many pesticides are present in the
environment.  Body residues in these birds may not be uncommonly high
and even less than the normal range of toxicity.  DDE residues ranging
from 0.16-78 ppm wet weight were detected in 39 bald eagles found sick
or dead in 1969-1970 (Belisle et al, 1972).  All 37 bald eagles found
sick or dead in 1971-1972 contained DDE (Cromartie et al, 1975).  Dieldrin,
PCB's, mercury, and other foreign substances also were present emphasizing
the difficulty in identifying cause of death.   Belisle et al (1972) found
one eagle containing a possible lethal level in the brain of 385 ppm DDE.
A warbling vireo, found dying in tremors nearly four weeks after a field
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was sprayed with up to 0.75 Ib/acre of DDT, had 459 ppm total DDT wet weight
in the brain (Herman, 1975).  DDE residues in the brains of 7 white-faced
ibis found dead or dying in Texas in 1970 ranged from 0.1-0.7 ppm (Flick-
inger and Meeker, 1972).

     A significant relationship between liver and whole body residues of DDE
in dead guillemots occurred as 40% of their body weight was lost and depot
fat mobilized in their livers contained 18.8 percent DDE (Parslow and
Jefferies, 1973).

     The incidence of abnormal chicks (feather loss, and eye, bill, and foot
deformities) in 2,000 common and 800 roseate terns in Long Island increased
from 0.1 to 1.3% from 1969 to 1970 (Hays and Risebrough, 1972).  Median con-
centrations, of DDE and PCB in the breast muscles of young terns were 2.1 and
25 ppm wet weight, respectively.  The search- for the causes of wild bird
abnormalities is made difficult by the nature of the relationship between
environmental teratogens and the incidence of observed effects.  Exposure of
a large population of organisms to comparable concentrations of a teratogen
could be expected to produce abnormalities in only a few individuals.  Con-
centrations of the chemical responsible could be as high in apparently normal
birds as in those with obvious abnormalities.  Increasing the level of ex-
posure, however, would increase the probability and, therefore, the incidence
of the effects.  Within a given ecosystem, such as the marine ecosystem sup-
porting the terns on Long Island, it may not be possible to relate the ab-
normalities to concentrations of any one or a combination of pollutants in
the birds.

     Biologists are constantly alert to new situations concerning pesticide-
wildlife relationships.  Of particular importance, is the continual moni-
toring on a yearly basis of wildlife species.  This is an important action
because when birds are subjected to heavy pesticide concentrations, their
resultant death frequently goes unnoticed.  Ducks collected in Iowa in 1969-
1970 had higher total DDT residues in the fat than other tissues, ranging
from 67-662 ppb wet weight (Johnson et al, 1971).  The breast muscle con-
tained from 6-97 ppb and the liver residues ranged from 8-247 ppb.  Analyses
of 5,200 mallard and black duck wings in 1969-1970 revealed DDE as the pre-
dominant organochlorine residue, ranging from 0.06-5.27 ppm (Heath and Hill,
1974).  These concentrations alone, however, would not be hazardous to duck
populations, but coupled with stress conditions could contribute to sickness
or death.

     Although almost all chukar, pheasant, and waterfowl samples taken in
Utah from 1970 through 1971 contained pesticides, no pheasant or chukar
breast muscle tissues exceeded the 5.0 ppm tolerance guideline for DDT +
DDE residues established by the Food and Drug Administration for edible
portions of fish (Smith et al, 1974b) .  Mourning dove breast muscles, col-
lected in 1970-1971 in the Eastern United States, were found to contain'
DDT + DDE + ODD in all 145 samples tested.  The average residue level was
0.068 ppm wet weight (Kreitzer, 1974).  The amounts identified are not
considered hazardous to higher order .carnivores.
                                    -59-

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     Birds sampled in areas of high pesticide use, as expected, contained
higher residues than those from nonuse areas.  Bobwhite quails collected
in Alabama in 1968-1969 (Mclntyre and Causey, 1971) from untreated fields
contained an average of 1.68 ppm DDE fat basis (range of 0.55-3.10 ppm)
while quail from nearby treated fields (DDT, Toxaphene, or methyl para-
thion) averaged 17.08 ppm DDT fat basis (range of 2.07-46.40 ppm).  This
concentration exceeds the 7 ppm tolerance guideline established by the
Food and Drug Administration for commercial poultry.  The same results
were obtained from bobwhite in South Carolina in 1969-1970 (Percival et al,
1973) and from ring-necked pheasants in Idaho in 1969 (Messick, 1972).

     When residues are detected in areas where there has been little or no
pesticide use, it can be concluded that they were transported from other
areas.  A survey was made during 1970 and 1971 of organochlorine pesticide
residue in the fatty tissues of two bird species (about 47 individuals) in
Australia (Best, 1973).  In areas far from human agricultural activity,
total DDT was found in birds ranging from <0.01-4.12 ppm fat basis. It has
been suggested that DDT levels above 2 or 3 ppm in the tissues may cause
serious damage to bird populations.

     Greichus et al (1973) examined cormorants and pelicans for pesticide
residue concentration.  The p,p'-DDE was the most prevalent contaminant,
reaching 154.50 ppm wet weight in pelican fat and 107.84 ppm in cormorant
fat.  Penned cormorants approaching toxicosis had 20 yg/g of ODD in the
brain.  Stress conditions for cormorants (migration or disease) may cause a
decrease in body lipid stores and it is quite possible that 20 yg/g of ODD
could occur in the brains.  Analyses of ten wild cormorants from South
Dakota showed average concentrations of 0.56 ppm DDE in the brain, 9.12 ppm
in the carcass, and 2.70 ppm wet weight in the liver (Greichus and Hannon,
1973).  Carcass levels in these cormorants were 20 times greater than in penned
birds, although brain concentrations differed little.  This evidence suggested
storage of residues in body fat as a means of adjusting to residue intake and
maintaining low brain levels.  Low brain residue levels indicated the wild
birds were in no immediate danger.

     Most species continually monitored exhibited a gradual decline in
amounts of pesticide residues associated with decreased DDT use.  When 319
migratory songbirds were sampled in Florida, all contained DDT in their
fat deposits (Johnston, 1974a).  There was a decline in DDT from 17.80 ppm
in 1969 to 2.06 ppm lipid weight in 1973.  The same result was evident in
songbird species which contained 15.48 ppm in 1969 compared to 1.66 ppm
in 1973 (Johnston, 1974b).  Samples of Louisiana woodcock in 1971 had
lower mean DDE residues (6.88 ppm) in the carcass than did the 1965 sample
(17.90 ppm) (Clark and McLane, 1974).  Starlings also showed a decline
from residue levels of 1.9 ppm in 1967-1968 to 1970 values of 1.0 ppm (Martin
and Nickerson, 1972).   The decline in DDT residues in starlings in 1972 was
not as great as that shown in the 1970 values but generally still decreasing
(Nickerson, 1972).   These declines are attributed to decreased usage of DDT
in the United States.
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     Exposure to organochlorine pesticides remained relatively constant
from 1965 to 1970 for golden eagles in the United States (Reidinger and
Crabtree, 1974).  DDE was the most prevalent residue ranging up to 84 ppm
in the fat.  Exposure was apparently through diet and not sufficient to
warrant concern for direct nonsynergistic acute toxic effects.  Sublethal
effects are not precluded, however.

Conclusion

     DDT residues present an intensified hazard to birds during stress
periods including migration and partial food deprivation even with normally
sublethal concentrations.  Mortality occurred when birds were fed DDT
simultaneously with food restriction.  However, there was no mortality when
the same DDT dosage or the same food restriction was applied separately in-
dicating that neither weight loss nor dosage alone was sufficient to cause
mortality.  Under stress, body fat is utilized; DDT is mobilized and may be
translocated via the bloodstream to the brain in sufficient amounts to
cause death.  Death from mobilization of stored DDT residues can occur long
after the dosage has been eliminated.

     An accurate assessment of cause of death in the field is extremely
difficult because many pesticides are present in the environment.  Birds
carrying DDT residues may have traveled long distances from DDT contact
points making it difficult, if not impossible, to relate the cause of
death to one pollutant.

     The conclusion reached from the new data agrees with the Administrator's
prior decision:  DDT is toxic to birds and can be mobilized from tissues in
lethal amounts.
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                     EGGSHELL THINNING AND REPRODUCTION
           Administrator's Finding:  DDE can cause thinning of bird
           eggshells and thus impair reproductive success.


     Certain wild birds, in their natural breeding areas, are affected by
DDT-related residues in the diet and bioaccumulated into tissues in such
a way as to produce reproductive impairment.  This impairment is associated
with the production of eggs with shells thinner than the historical norms
and results in such deleterious phenomena as cracking, crushing, egg-eating
by the parents, and nest abandonment.  These phenomena result in reduced
reproductive success among natural populations, and in some cases, failure
of large breeding colonies to reproduce the young needed to sustain the
population.  These effects can result ultimately in partial or complete
loss of whole species.

     The statement that DDT-related residues produce this eggshell thinning
is based upon at least three lines of evidence:  1) museum eggshells of the
affected species show that a marked decline in average thickness occurred
during the late 1940's corresponding to the time DDT came into prominent
use;  2) affected species have a negative correlation between the concen-
tration of DDT-related residues in the egg, bird, or colony and the thick-
ness of eggshells.  These kinds of residue correlations along with shell
thickness, population status, and reproductive failures are field research
evidence;  3) controlled studies on this chemical effect on shell thickness
have shown the phenomenon to be repeatable in the laboratory.

Data as of 1972

     Testimony presented during the hearings included pro and con information
regarding each of the three lines of evidence.  Museum studies were presented
by Dr. Joseph Hickey and others describing the decline in shell thickness of
certain species in the US.  Testimony was also presented showing a lack of
change in certain other species.  Testimony was presented showing a negative
correlation between shell thickness and egg residues for some species and no
correlation for others.  Earlier laboratory studies, such as those of the
University of Wisconsin and the Patuxent and Denver Wildlife Research Centers
of the USDI, were presented which showed that dietary or single oral dosages
of the DDT complex, particularly DDE, could cause shell thinning in some species
but not in others.  While several witnesses expressed the opinion that DDE-
impaired calcium metabolism was responsible, no definitive biochemical mechanism
was demonstrated, though several possible mechanisms were proposed.  (Public
Hearings on DDT, 1971-1972)

Data since 1972

     Since the Administrative Hearings, more information has become available.
An excellent, in-depth review of shell thinning in avian eggs has been written
                                    -62-

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(Cooke, 1973).  Any serious student of the phenomenon should read this well-
referenced 68-page review for a thorough grasp of the subject's history and'
an analysis of research to that time.  Other recommended background reading
is the most comprehensive American study of eggshell thickness ever con-
ducted (Anderson and Rickey, 1972).

     These reports document the decreased shell thickness certain American
species have displayed since the late 1940's.  Species of wild birds studied
in North America not demonstrating any significant shell thinning included
the golden eagle, great horned owl, gyrfalcon, rough-legged hawk, whooping
crane, and mourning dove.

     Species in North America showing recent decreases in shell thickness
include the peregrine falcon, bald eagle, prairie falcon, osprey, red-
tailed hawk, merlin, white pelican, brown pelican, double-crested cormorant,
common egret, great blue heron, guillemot, herring gull, and ashy petrel.

     The species showing thinning are generally among those at the top of food
chains, such as fish-eaters, bird-eaters, and other flesh-eating birds.  Her-
bivorous species such as pheasants, quail, and certain waterfowl have not
displayed this shell thinning.

     Numerous authors present graphs of shell thickness plotted against time.
The decreases first appeared to have happened in the period 1946-1952, typi-
cally in 1947, continuing in many cases to the present.  In certain cases,
thickness increases toward historical norms have occurred very recently
(Anderson and Rickey, 1972).

     The degree of shell thinning in affected wild colony populations has
varied from over 34% (with eggs collapsing as a result) for the California
brown pelican (Keith, Woods, and Hunt, 1970) to none for many species.
Within a given species there are geographical differences in average degrees
of shell thinning.

     There are many research papers giving negative correlation coefficients
between the degree of shell thinning and the concentration of DDT-related
residues for affected species (Blus et al, 1974; Faber and Rickey, 1973;
Cade et al, 1971).

     Blus et al (1972) have developed^the mathematics for the relationship
between DDE residues and shell thinning for several species.  The relation-
ship between the logarithm of the dose and the response is well known in
toxicological theory.  Blus et al extend this to the association between
residue and response.  His calculations show a concentration-effect rela-
tionship involving the logarithm of DDE (wet weight basis) in eggs and the
thickness of the shells for affected species.  The resulting regression is
linear and similar for different species.  However, he notes that this re-
lationship operates on a different level for different species.  For exam-
ple, in the brown pelican, which seems to be extremely susceptible, a 15%
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thinning is associated with DDE residues of 4-5 ppm.  In contrast, the herring
gull shows no thinning at 4-5 ppm and only 11% thinning at 80 ppm.

     In certain cases, this shell thinning-DDE residue correlation led to pop-
ulation studies and on-site reproduction assessments.  One set of studies con-
cerned the brown pelican off the coast of California and Baja, California.  A
report, prior to 1972 (Risebrough et al, 1971), showed this population exper-
iencing extremely low reproduction in association with thin shelled-egg pro-
duction and abnormally high DDE residues.  The residues resulted from the
brown pelicans' diet of northern anchovies and other fish carrying high DDE
residues.

     Dr. Daniel Anderson (personal communication, 1974) is studying this popu-
lation.  His data demonstrate that a change has occurred since the 1960's for
the islands of Anacapa and Coronados off the southern California coast.  A
significant drop in the average levels of DDE, DDT, and TDE in the anchovies
began in 1971.I/  A significant improvement in the reproductive success of the
brown pelicans has occurred since 1971.  For 1969, it was reported (Risebrough
et al, 1971) that the colony was littered with eggs that had collapsed under
the weight of the incubating adults.  Shells of these eggs averaged 53% thin-
ner than those collected before 1943.  In 1969, a maximum of five young
hatched from 1,272 nesting attempts.  In 1970 and 1971, there was little im-
provement.  More improvement occurred in 1972 and 1973.  For 1974, Anderson
has data showing that approximately 1,200 young were successfully hatched from
the Island of Anacapa.  This reproductive improvement was associated with a
significant improvement in shell condition, as well as increased survival of
eggs and reduced DDE residues.  This reproductive success is attributed both
to improved rate of reproduction and an increased number of breeding adults by
1974.  The increase in number of breeding adults is thought to be brought
about by possible recruitment of first breeders from more southerly popula-
tions as a response to an increased food supply (fish).

     This increased reproductive success is not enough to be called "normal"
for these pelicans.  Anderson states it as a "chronic lower level of adverse
effects" as opposed to the acute problem of almost total reproductive failure
which had just previously occurred.  The numerical data supporting this his-
tory have been evaluated and are to be published.

     James 0. Keith, of the Denver Wildlife Research Center, has also been
involved in the on-site study of West Coast brown pelicans for many years.
_!/  Montrose Chemical Company, DDT manufacturer, installed a separate treat-
ment system and no longer used the Los Angeles sewer system in 1971; this
accounts for some of the lower DDT related residues thereafter.
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He states (personal communication, 1975) that "the average productivity of
brown pelicans in the Gulf of California during the last five years
appears to be inadequate to maintain their population."  Whereas existing
data on mortality rates for the species suggest that a recruitment
standard of from 1.2 to 1.5 young per adult pair is necessary (Henny, 1972)
to maintain the population, production has averaged less than 1.0 young per
pair in the Gulf.  Average productivity was reduced primarily by two kinds
of inadequate performance on the part of adult pelicans.  In two of the
[last] five years, only about one-half and one-third of the adults came to
the colonies to breed; the remaining proportion of the adults did not pro-
duce young during those years.  In addition, during every year a proportion
of the adults (10 to 95%) deserted eggs or young sometime during production.
Keith notes that, in addition to DDE residues carried by the adult pelicans,
food availability was possibly related to this inadequate performance.^/
Keith's research on food deprivation and its effect on birds carrying DDE
residues is reviewed elsewhere in this report.

     Like Gress (1970), Keith noted erratic behavior in the field such as a
tendency of breeding adults to leave normal nests unattended.  He also noted
that a tendency toward less intense courtship behavior than normal was cor-
related with higher DDE residues than occurred in "normal" pairs.  Experi-
mental evidence has substantiated this phenomena under controlled conditions
and is presented elsewhere in this report.

     Schreiber and Risebrough (1972) described the historical status of
brown pelicans throughout the United States and its relationship to DDE
residues.  Risebrough (personal communication, 1974) was concerned about the
biochemical mechanism by which DDE could cause thin shells.

     Blus et al (1974) studied egg effects from 13 or more colonies of brown
pelicans from South Carolina, Florida, and California in 1969 and 1970.
 They observed a 17% eggshell thinning in South Carolina which was associated
with subnormal reproductive success.  Since the DDT cancellation, there has
been a significant decline in residues of DDE, ODD, and DDT in eggs (brown
pelicans in South Carolina); at the same time, reproductive success of the
pelicans returned to near normal for the first time in many years (Blus,
personal communication, 1975).  This is consistent with other findings for
brown pelicans off the California coast (Anderson, personal communication,
1974) and ospreys in the Eastern US (Stickel, personal communication, 1974).

     Controlled laboratory studies, both before and after the cancellation,
have demonstrated the shell-thinning phenomenon to be reproducible.  Chickens
and related wild gallinaceous birds have shown little or no thinning upon
exposure to DDT or DDE in the diet (Davison and Sell, 1972).  On the other
I/ Restricted food intake can lead to mobilization of DDE residues from
body fat.
                                   -65-

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hand, waterfowl, such as the mallard (Davison and Sells, 1974) or black duck
(Longcore et al, 1971; Longcore and Samson, 1973), ring doves (Haegele and
Hudson, 1973), and sparrow hawks (Peakall et al, 1973) have shown signifi-
cant shell thinning of a degree impairing reproduction even when the eggs
are artificially incubated.  Studies have not been performed in the labora-
tory with the same species showing reproduction problems in the wild, with
the exception of the prairie falcon and sparrow hawk.  The reason for this
is the other species are not amenable to laboratory rearing practices.

     To determine if mercury or lead compounds caused significant shell
thinning or synergized the thinning caused by DDE, Haegele et al (1974) fed
them singly and in combination with DDE, to mallard ducks.  DDE alone caused
15% reduction in shell thickness; but neither mercury nor lead caused sig-
nificant thinning or additive thinning, either alone or in combination with
DDE.  Furthermore, Haegele and Tucker (1974) orally administered fifteen
common environmental pollutants to both coturnix and mallards to determine
if pollutants, other than DDE, caused shell thinning.  The chemicals tested
included Aroclor 1254, 2,4-D, dieldrin, heptachlor, chlordane, parathion,
sodium arsenite, Toxaphene, and tetraethyl lead.  Results showed that several
chemicals and pesticides caused temporary production (2-5 days) of thin-
shelled eggs in association with treatment levels producing severe signs of
intoxication.  When the overt intoxication remitted, the next eggs subse-
quently returned to normal thickness, except for the DDE-treated groups where
thinning persisted throughout the 18-day study, in the absence of signs of in-
toxication.  These authors studied DDE-produced shell thinning in mallards which
persisted in excess of a year after the birds were returned to normal, uncon-
taminated diets (Haegele, personal communication, 1974).  Peakall et al (1975a)
studied the prolonged nature of this thinning using the white Pekin duck.  They
concluded that recovery of shell thickness following cessation of exposure to
DDE was less than half-way to normal in 27 weeks and that DDE residues in egg
yolks produced at that time had decreased 40%.  The authors noted that recovery
would be slower in the wild for affected species since they lay far fewer eggs.
Eggs are a major route by which female birds rid their bodies of DDE residues.

     Some significance of shell thinning is shown by Longcore and Sampson
(1973) who fed black ducks just 3 ppm wet weight p,p'-DDE.  The ducks pro-
duced eggs with shells 22% thinner than normal.  When the hens were allowed
to incubate these eggs, the increase in total percentage of eggs with
cracked shells was statistically highly significant (57.7%), four times the
percentage of cracked control eggs (12%).  Only 18.7% of the eggs laid by
DDE treated ducks hatched, compared to 86% of control eggs.  Most other
studies utilized artificial incubation techniques and thus, in part, missed
the cracking effect.  These authors in prior years conducted the same study
but artificially incubated the eggs and found that of the control eggs,
2.2% cracked and of the DDE group eggs, an unimpressive but statistically
significant 11.0% cracked.

     One major thrust of current laboratory shell-reproduction research has
been to elucidate the biochemical mechanism by which DDE could cause thinning.
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Previously, a number of mechanisms, all related to calcium metabolism, had
been proposed.  One by one, each proposed mechanism has been either dis-
missed as further experimental evidence became available, or been relegated to
a minor role.

     Such mechanisms proposed and studied include carbonic anhydrase
inhibition, thyroid destruction via liver enzyme induction, premature ovi-
position, parathormone dysfunction  hydroxylation of the steroid vitamin D
causing poor calcium absorption from the gastrointestinal tract, hormonal
changes, and numerous other theories.   These were thoroughly discussed by
Cooke (1973)  and,more recently, by Mueller and Leach (1974).

     In the last few months some very important breakthroughs have been made.
The most popular theory of the early 1970?s, carbonic anhydrase inhibition by
DDT, has now been rather successfully refuted by Maren et al (1974) .  Car-
bonic anhydrase inhibition in the shell gland by DDE had been presumably
demonstrated by previous authors and should have been responsible for reduced
laying down of calcite (CaCOo), the major constituent of eggshells.  Previously,
Pocker et al (1971) showed in assays that a false inhibition resulted from co-
precipitation with insoluble DDT, thus occluding carbonic anhydrase from solu-
tion.  Maren et al (1974) , using DMF with ultrasonication to keep any carbonic
anhydrase and DDT in suspension, demonstrated a lack of inhibition of anhy-
drase activity by DDE and DDT.  Peakall et al (1975b) have now shown that DDE
does not reduce blood calcium levels in either the Pekin duck or the ring dove,
both of which are susceptible to shell thinning.  Thus, the mechanism had to
involve the function of the shell gland in laying down calcite rather than
decreased calcium supply to the gland.

     Finally, Miller et al (1975) reported that calcium ATPase present in the
shell gland may act as a calcium pump to produce the active transport of cal-
cium ions across the avian shell gland from the blood to the developing shell.
Their experiments demonstrated that calcium ATPase in the shell gland of Pekin
ducks is strongly inhibited by DDE both in vivo and in vitro.  As little as
0.2 ppm DDE in the shell gland produced inhibition in the susceptible duck
species.  If this biochemical explanation is valid, one should expect little
or no calcium ATPase inhibition in the shell gland of a DDE-treated chicken.
In fact, this has been verified in recent weeks (Kinter, personal communication,
1975), thus finally explaining the difference between susceptible species and
the nonsusceptible chicken.

Conclusion

     Based upon previous data available to the Administrator and additional
material which has since become available, we conclude:

     1.  Because there is a mass of information showing that the shell-
         thinning phenomenon was not a problem prior to the introduc-
         tion of DDT into the environment, and because there is a cor-
         responding remission in severe shell thinning in many affected
         species taking place across the nation since the cancellation,
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         we feel a clear-cut time relationship exists between thin-
         shell production, concomitant reproductive failures, and
         DDT use in North America.

     2.  There is a spatial relationship showing that the areas,
         colonies, and birds of susceptible species most exposed
         and carrying the highest residues have been the most
         affected.

     3.  Time and time again, negative correlations between the
         DDE content of eggs and parents versus thickness of shells
         produced have been shown.  The only exceptions, to our
         knowledge, were the lack of correlation found by one
         mosquito abatement district manager on a few eggs and one
         graduate student who found yet another negative correla-
         tion coefficient, albeit a nonstatistically significant
         one (Switzer et al, 1971).

     4.  Controlled studies have shown repeatedly that many
         species are susceptible under laboratory conditions of
         exposure to environmental levels of DDE.  However,
         chickens and related gallinaceous birds are generally
         refractory both in laboratory studies and their natural
         habitat.  A plausible explanation for how thinning occurs
         in susceptible species but not in chickens or other non-
         susceptible species is the biochemical mechanism (calcium
         ATPase inhibition in the shell gland) previously discussed.

     5.  No other chemical has been shown to produce the degree
         and duration of shell thinning produced by DDE.

     For all these reasons, we conclude, as did the Administrator, that DDE
can cause thinning of bird eggshells, thus impairing reproductive success.
This phenomenon has been so general and widespread as to, in our opinion,
present serious environmental risk to the many avian species involved.
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Franson, J.C., P.A. Dahm, and L.D. Wing.  Chlorinated hydrocarbon insecticide
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Keiser, R.K., Jr., J.A. Amado, and R. Murillo.   Pesticide levels in estuarine
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Longcore, J.K., and F.B. Samson.  Eggshell breakage by incubating black ducks
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MacFarlane, R.B., W.A. Glooschenko, and R.C.  Harris.  The interaction of
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Puleston, D.  Return of the osprey.  Nat. History 84(2):52-59, 1975.

Reidinger, R.F., Jr., and D.G. Crabtree.  Organochlorine residues in golden
  eagles, United States - March 1964-July 1971.  Pestic. Monit. J. 8(1):
  37-43, 1974.

Reinert, R.E., L.J.  Stone, and H.L. Bergman.  Dieldrin and p-p'-DDT:
  Accumulated from water and food by lake trout in the laboratory.  (In
  press)

Reinert, R.E.  Personal communication, 1975.

Rice, C.P., and H.C. Sikka.  Uptake and metabolism of DDT by six species of
  marine algae.  J.  Agric. Food Chem. 21(2) :148-152, 1973.

Risebrough, R.W.  Personal communication, 1974.

Risebrough, R.W., F.C. Sibley, and M.N. Kirven.  Reproduction failure of the
  brown pelican on Anacepa in 1969.  Am. Birds 25:8-9, 1971.

Rooth, J., and D.A.  Jonkers.  The status of some piscivorous birds in the
  Netherlands.  Side-effects of persistent pesticides and other chemicals on
  birds and mammals in the Netherlands.  TNO-nieuws 27:551-555, 1972.

Sanders, H.O.  Toxicity of Some Insecticides to Four Species of Malacostracean
  Crustaceans.  US Department of Interior, 1972.  19 pages.   fBSFW Technical
  Paper No. 66]

Schreiber, R.W., and R.W. Risebrough.  Studies of the brown pelican.  Wilson
  Bull. 84(2):119-135, 1972.

Shaw, S.B.  DDT residues in eight California marine fishes.   Calif. Fish Game
  58(1) :22-26, 1972.

Smith, R.M., and C.F. Cole.  Effects of egg concentrations of DDT and dieldrin
  on development in winter flounder Pseudopleuronectes americanus.  J. Fish. Res,
  Board Can.  30:1894-1898, 1973.
                                   -79-

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Smith, F.A., R.P. Sharma, R.I.  Lynn, and J.B.  Low.   Mercury and selected
  pesticide levels in fish and  wildlife of Utah.   I.  Levels of mercury,
  DDT, DDE, dieldrin, and PCB in fish.  Bull.  Environ. Contain.  Toxicol.
  12(2):218-223, 1974a.

Smith, F.A., R.P. Sharma, R.I.  Lynn, and J.B.  Low.   Mercury and selected
  pesticide levels in fish and  wildlife of Utah.   II.   Levels of mercury,
  DDT, DDE, dieldrin and PCB in chukars, pheasants  and waterfowl.  Bull.
  Environ. Contam. Toxicol. 12(2):153-157, 1974b.

Sodergren, A.  Accumulation and distribution of chlorinated hydrocarbons
  in cultures of Chorella pyrenoidosae (Chlorophyceae).  Oikos  22:215-
  220, 1971.

Sodergren, A., and S. Ulfstrand.  DDT and PCB relocate when caged robins
  use fat reserves.  Ambio 1(1):3.6-40, 1972.

Sodergren, A., and B. Svensson.  Uptake and accumulation of DDT and PCB
  by Ephemera danica (Ephemeroptera) in continuous-flow systems.  Bull.
  Environ. Contam. Toxicol. 9(6) :345-350, 1973.

Stickel, W.H.  Personal communication, Patuxent Wildlife Research Center,
  1974.

Stout, V.F.  Personal communication, Pacific Utilization Research Center,
  NOAA, Seattle, Washington, 1975.

Sundarum, K.M.S.  A Study of DDT Residues in the Brain Tissues  of Small
  WjLld Mammals.   Ottawa, Canada, Chemical Control Research Institute,
  1972.  51 pages.  [Internal Report CC-16]

Switzer, B., V.  Lewin, and F.A. Wolfe.  Shell thickness, DDE levels in
  eggs and reproductive success in common terns in Alberta.  Can. J. Zool.
  49(l):69-73, 1971.

Tr    Public Hearing on DDT, Transcript, Office of .the Hearing Clerk,
  Environmental Protection Agency,  Washington, D.C., 1971-1972.

US Department of the Interior.   Toxicity of aquatic contaminants to fresh
  water invertebrates.  In:  Progress in Sport Fishery Research, 1971,
  pp. 3-4.  Washington, D.C., US Government Printing Office, 1973.
  [Resource Publication 121]

Vaajakorpi, H.A., and L. Salonen.  Bioaccumulation and transfer of ^C-DD
  in a small pond ecosystem.  Ann.  Zool. Fennici pp. 539-544, 1973.

Valentine, D.W., and M. Soule.   Effects of p,p'-DDT on developmental sta-
  bility of pectoral fin rays in the grunion, Leuresthes tenuis .  Fish.
  Bull. 71(4) :921-926, 1973.
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Van Velzen, A.C., W.B. Stiles, and L.F. Stickel.  Lethal mobilization of DDT
  by cowbirds.  J. Wildl. Manage. 36(3) :733-739, 1972.

Weis, P., and J.S. Weis.  DDT causes changes in activity, a schooling behavior
  in goldfish.  Environ. Res. 7:68-74, 1974.

Weisbart, M., and D. Feiner.  Sublethal effect of DDT on osmotic and ionic
  regulation by the goldfish Carassiue auratus•  Can. J. Zool.  52:739-744,
  1974.

Williams, R., and A.V. Holden.  Organochlorine residues from plankton.  Mar.
  Pollut. Bull. 4(7):109-111, 1973.

Zitko, V., and P.M.K. Choi.  PCB and p,p'-DDE in eggs of cormorants, gulls,
  and ducks from the Bay of Fundy, Canada.  Bull. Environ. Contain.  Toxicol.
  7(l):63-64, 1972.

Zitko, V., 0. Hutzinger, and P.M.K. Choi.   Contamination of the Bay of Fundy -
  Gulf of Maine area with polychlorinated biphenyls, polychlorinate
  terphenyls, chlorinated dibenzodioxins,  and dibenzofuran.  Environ. Health
  Perspect. pp. 47-50, 1972.
                                    -81-

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       Ill
B.  HUMAN EFFECTS

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                       CARCINOGENICITY OF DDT IN MICE
          Administrator's Findings:  1)  Experiments demonstrate
          that DDT causes tumors in laboratory animals.  2)  There
          is some indication of metastasis of tumors attributed to
          exposure of animals to DDT in the laboratory.
Data as of 1972

     In a published preliminary note, 18 male and 18 female (C57BL/6 x C3H/
Anf) Fl mice and a similar number of (C57BL/6 x APR) Fl mice were given
single doses of 46.4 mg/kg bw p,p'-DDT by stomach tube at 7 days of age.
The same absolute amount was given daily until the animals were 28 days of
age; they were then transferred to a diet containing 140 ppm p,p'-DDT.
Mice were killed at 81 weeks.  In both strains, about 30% of the females
died during treatment.  Hepatomas (liver cell tumors) were found in 11/18
male and 4/18 female (C57BL/6 x C3H/Anf) mice compared with 8/79 male and
0/87 female controls, and in 7/18 male and 1/18 female (C57BL/6 x AFR) Fl
mice compared with 5/90 male and 1/82 female controls.  In addition, 6/18
(C57BL/6 x AFR) Fl females died with malignant lymphomas, compared to 4/82
controls (Innes et al, 1969).

     A 5-generation experiment, originally devised to investigate the effects
of DDT on behavior, provided animals for a carcinogenicity study.  One test
and one control group of BALB/c mice were taken from each of the 5 gener-
ations and their tumor incidence studied.  A total of 683 received a diet
containing 3 ppm p,p'-DDT and 406 a control diet.  Lung carcinomas were
observed in 16.9% of the treated mice and 1.2% of the controls (the inci-
dence of lung adenomas is not reported, although the authors note an average
incidence of 5% in their colony of mice).  The incidence of lymphomas was
4.8% in treated and 1.0% in control mice; leukemias 12.4% and 2.6%, and
other tumors 5.3% and 1.0%, respectively (Tarjan and Kemeny, 1969).

     At this time, the multigeneration Lyon study was ongoing and prelimin-
ary data indicated that International Agency for Research on Cancer (IARC)
also had observed an increased incidence of hepatomas in mice but no con-
clusive data were available for publication (IARC, Scientific Advisory Com-
mittee to EPA Administrator, personal communication, 1972).  The committee
agreed at this point that the unpublished evidence made available to them,
indicated an overwhelming production of hepatomas in mice by DDT.  However,
they admittedly were in disagreement at this time, for lack of evidence,
whether or not hepatomas signified eventual development of carcinomas.
The presence, however, of lung carcinomas and malignant lymphomas (lymph
gland tumors) in addition to the hepatomas signaled the ability of DDT to
produce cancerous growths in other tissues and gave weight to the potential
carcinogenicity of this chemical in other mammalian systems.
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Data since 1972

     A 2-generation dose-response study on the feeding of DDT to CF1 mice
involving a total of 881 treated and 224 control mice has been reported
(Tomatis et al, 1972).  Dietary concentrations of 2, 10, 50, and 250 ppm
technical DDT were, administered for lifespan (approx. 18 months).  In
both parent (P) and offspring (Fl) generations, there was excess mortality
from week 60 onward among mice receiving 250 ppm DDT.  Only the incidence
of liver-cell tumors was affected by exposure to DDT, and in the two sexes,
it ranged as follows:

                                 Male*          Female*

                                 25/113          4/111

                                 57/124          4/105

                                 52/104         11/124

                                 67/127         13/104

                 250 ppm         82/103         69/90

          (* Number of animals demonstrating the appearance of the
          first tumor at any site.)

     The excess of liver-cell tumors in mice of both sexes fed 250 ppm DDT
over the controls was significant at the 1% level.  The excess of liver-
cell tumors in males fed 2, 10, or 50 ppm over the controls was significant
at the 1% level in animals surviving more than 60 weeks.  In females, all
liver-cell tumors were found after 100 weeks of age, and the excess over the
controls was significant at the 5% level only in the group fed 50 ppm DDT.
Four liver-cell tumors, all occurring in DDT-treated mice, gave metastases.
No remarkable differences were observed between P and Fl mice in this study.

     These results were confirmed by a later study reporting the effect of
DDT on 6 consecutive generations of CF1 mice.  CF1 minimal inbred mice of
6 consecutive generations  (parents, F1-F5) were fed technical DDT mixed
into the diet at dose levels of 2, 10, 50, and 250 ppm for their lifespans.
The experiment involved 3,987 mice, including DDT-exposed and negative and
positive controls.

     Exposure to all 4 levels of DDT significantly increased liver tumors
(hepatomas) in males (50-55.9% in the 2, 10, and 50 ppm groups and 86% in
the 250 ppm DDT groups, compared to 29.5% in male controls).  In females,
hepatoma incidence increased considerably only after exposure to 250 ppm
DDT (65.5% compared to 4.7% in controls).  Ten and 50 ppm DDT only
slightly increased the incidence (9% and 13% respectively).  No effect
was seen at the 2 ppm level in females.
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     The average lifespan of males with hepatomas decreased in DDT-treated
groups (84 wk at the 250 ppm DDT level, 101-104 wk at the 2, 10, and 50 ppm
levels, as compared to 114 wk in controls).  In females, only the highest dose
level shortened the average lifespan of hepatoma-bearing mice (94 wk compared
to 104 wk in controls).  DDT did not alter tumor incidence at sites other than
the liver, although an apparent, but not significant, increase in lung tumor
incidence was noted at the levels of 2 and 10 ppm DDT.  No progressive increase
of hepatoma incidence from generation to generation was noted in DDT-treated
mice.  However, considerable variations in the incidence of tumors of the liver,
lungs, and hematopoietic tissue were observed between the generations within
each treatment group, including controls.  One metastasizing hepatoma was found
in controls and 13 were found in 4 DDT-treated groups.  Malignant liver tumors,
tentatively termed hepatoblastomas, also occurred, with a slightly increased
incidence in the 10 and 50 ppm groups (3.9% and 3.1%, respectively, as compared
to 0.9% in controls) and a significant increase in the 250 ppm group (7.1%).
Ten of 56 tumors of this type found in DDT-treated mice metastasized to the
lungs (Turusov et al, 1973).

     In a 2-generation study, a total of 515 females and 431 male BALB/c mice
were administered dietary concentrations of 0, 2, 20, or 250 ppm technical DDT
for lifespan.  Only liver-cell tumors were found in excess, and only the 250
ppm dose level was effective.  In females, the survival rates were comparable
in all groups, and liver-cell tumors were found in 0/131 control mice, 0/135
mice fed 2 ppm, 1/128 mice fed 20 ppm and 71/121 mice fed 250 ppm DDT.  In males,
early deaths occurred in all groups as a consequence of fighting and (at highest
dosage level) because of DDT toxicity.  In males surviving over 60 weeks of age,
liver-cell tumors were found in 1/62 control mice, 3/58 receiving 2 ppm, 0/48
receiving 20 ppm, and 15/31 receiving 250 ppm DDT.  Liver-cell tumor distribution
was unrelated to the litter of origin.  No metastases were found.  The tumors
grew after transplantation into syngenetic animals (Terracini et al, 1973a).

     Confirmatory results were obtained in two subsequent generations of BALB/c
mice fed DDT, although F1-F3 mice, exposed to DDT both in utero and after birth
for lifespan developed more liver tumors than did P mice exposed to DDT only
after weaning (Terracini et al, 1973b).

     In a multigeneration study in A strain mice, DDT in 0.1 ml sunflower-seed oil
was administered to 234 mice by stomach tube at doses of 10 ppm.  In two control
groups a total of 206 mice received either no treatment or sunflower-seed oil
(0.1 ml) alone.  Similar treatments were applied to the FO, Fl, F2, F3, F4, and
F5 generations.  An additional 30 mice were given doses of 0.1 ml of a 50 ppm
solution which adversely affected pregnancies, thus no subsequent generations were
obtained at this level.  Approximately 30-50% of the animals in the treated groups
died before 6 months; all animals were killed after 12 months.  Only lung
adenomas were found.  The incidences in FO-F5 generations treated with 10 ppm
DDT were:
                                   -85-

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     FO, 8/42 (19%); Fl, 4/26 (15%); F2, 6/25 (24%); F3, 19/41 (46%);
     F4, 16/37 (43%); F5, 8/63 (13%); controls FO-F5, 15/206  (7%).

Of the 30 mice receiving 50 ppm doses, 14 died before 6 months, and 3 of
these (21.5%) had lung adenomas; of the 16 dying after this time, 8 (50%)
had lung adenomas.  The average number of lung nodules/mouse, about 7.2,
was similar in both sexes, compared to 1.0-4.7 nodules/mouse in the 6
generations receiving 10 ppm doses and 1.0 nodule/mouse in controls (Shabad
et al, 1973).

     Diets containing 50 or 100 ppm p,p'-DDT were administered to groups of
30-32 CF1 mice of each sex for 2 years.  The control groups included 47 mice
of each sex.  In males given 0, 50, and 100 ppm, liver tumors occurred in
13%, 37%, and 53% of the animals, respectively.  In females, the corres-
ponding incidences were 17%, 50%, and 76%.  The ratio of liver tumors, char-
acterized by simple nodular growths of solid cords of parenchymal cells,
classified as benign tumors (type a), to tumors growing with papillary or
adenoid growths with cells proliferating in confluent sheets with necrosis
and increased mitosis (type b) was greater than 3:1 in the treated group; no
type b tumors occurred in controls.  The incidences of other tumors were
comparable in control and DDT-treated mice.  Metastases were found in one
treated female (Walker et al, 1973).

     In a subsequent study 30 male and 30 female CF1 mice were fed 100 ppm
p,p'-DDT for 110 weeks.  The animals were not autopsied until the ultra-
abdominal masses reached a size causing the animals to become anorexic or
clinically affected.  In this experiment, 79% of the males and 96% of the
females compared with 24% and 23% in the controls developed liver tumors
within 26 months.  The ratio of type a to type b tumors was about 1:1 in
the DDT-treated mice (Thorpe and Walker, 1973).

Conclusion

     As a result of additional studies concluded after 1972, the hepato-
carcinogenicity of DDT by the oral route has been demonstrated in several
strains of mice.   Liver-cell tumors have been produced in both sexes, and
in CF1 mice were found to have metastasized.  An increased incidence of
hepatic tumors has been observed with doses of DDT as low as 2 ppm.
                                    -86-

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                 TUMOR PRODUCTION IN MICE AS AN INDEX OF
               POTENTIAL CARCINOGENICITY IN OTHER SPECIES


          Administrator's Findings:  1) Not all chemicals show the
          same tumorigenic properties in laboratory tests in animals.
          2) Responsible scientists believe tumor induction in mice
          is a valid warning of possible carcinogenic properties.


Data as of 1972

     Tomatis el al (1973) in a review of the literature containing over 350
references dating from 1937 through 1972 concluded that a positive correlation ap-
pears to exist between the capacity of a chemical to induce liver tumors
in the mouse and its capacity to induce tumors at any site in the rat or the
hamster.  The strongest positive correlation was found when the chemical,
given to the mouse during adult life, induces tumors of the liver in both
sexes as well as tumors at other sites.  However, the induction of liver
tumors in the mouse by a chemical does not necessarily imply that the liver
would be the target organ in the rat or the hamster.

     Tomatis, in the same review, further indicated that among the 58 chemicals
considered, seven are recognized or suspected human carcinogens  (3N-benzopyrene
4-aminobiphenyl, benzidine, auramine, 2-naphthylamine, stilbestrol, and afla-
toxin) .  With the possible exception of aflatoxin, there is no evidence that
the target organ for man would be the liver.  All were hepatocarcinogenic in
the mouse and six were carcinogenic for the liver and/or other organs in the
rat.  In the hamster, four were tested and found carcinogenic.

Data since 1972

     The chemical vinyl chloride when given by inhalation has been observed
to produce lung adenomas and mammary carcinomas in mice and hepatic angiosarcomas
and angiomas of the liver in mice and rats (Maltoni and Lefemine, 1975).
Angiosarcomas of the liver have also been observed in workers employed in the
manufacture of polyvinyl chloride resins (Creech and Johnson, 1974; Creech et
al, 1974).

     Current studies on carcinogenicity of DDT and metabolites in mice and rats
at the National Cancer Institute are to be completed within the next 12 months.

Conclusion

     Although the target tissue may be different, the mouse can, in specific
cases, serve as a reliable and proven indicator of the carcinogenicity of a
chemical in other species including man.  However, although carcinogenic
effects in mice are valid when dealing with certain chemicals, the results can
vary greatly depending on the compound tested and may not always be a reliable
basis for extrapolation to other species.
                                   -87-

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           CARCINOGENICITY OF DDT IN OTHER MAMMALIAN SPECIES
          Administrator's Finding:  There are no adequate nega-
          tive experimental studies in other mammalian species.
Data as of 1972

Rat

     In two 2-year experiments started at an interval of 1 year, a total of
228 Osborne-Mendel rats received diets containing technical DDT (as a powder
or solution in oil) at concentrations of 0 ppm (24 males and 12 females),
100 ppm (12 males), 200 ppm (24 males and 12 females), 400 ppm (24 males and
12 females), 600 ppm (24 males and 24 females), and 800 ppm (36 males and 24
females).  Of the 192 rats exposed to DDT, 111 died before 10 months of
treatment; only 14 rats given 800 ppm, 23 rats given 600 ppm, 14 given 400
ppm, 24 given 200 ppm, 6 given 100 ppm and 20 controls were alive at this
time.  Tumor incidences for each dose level were not given.  Among the 81
rats surviving at least 18 months, 4 had low-grade hepatic-cell carcinomas
(measuring up to 0.5-1.2 cm) and 11 showed nodular adenomatoid hyperplasia
(nodules measuring up to 0.3 cm).  No liver lesions were found in control
rats (Fitzhugh and Nelson, 1947).  Hepatic-cell tumors are reported by these
authors to occur spontaneously in 1% of the rats in this colony, and nodular
adenomatous hyperplasia is reported to be rare.

     Two experiments on Osborne-Mendel rats reported from the same institu-
tion, exposed groups of 30 males and 30 females for at least 2 years to
either 80 or 200 ppm DDT (recrystallized, purity unspecified) and compared
them to two control groups of 30 animals of each sex.  Undifferentiated
bronchogenic carcinomas were seen in 8/60 rats fed 80 ppm DDT, in 2/60 con-
trols and in none of the animals receiving 200 ppm DDT.  Incidences of other
tumors were similar in control and treated rats (Deichmann et al, 1967;
Radomski et al, 1965).  These results are inconclusive since carcinogenic
effects were not seen at 200 ppm.

     A group of 15 male and 15 female Fischer rats was given doses of 10
mg/rat DDT (unspecified composition) by stomach tube, 5 times/week, starting
at weaning.  Treatment lasted 1 year, and survivors were observed for a
further 6 months; the average survival was 14.2 months.  No hepatomas were
found.  No data are available on the occurrence of other tumors (Weisburger
and Weisburger, 1968).

Hamster

     Groups of 25-30 Syrian golden hamsters of each sex were fed a diet con-
taining either 500 or 1000 ppm, p,p'-DDT in olive oil for 44 out of 48 weeks.
Survivors at 50 weeks were 70/115 treated versus 59/79 control animals; all
treated animals and 62/79 controls were dead by the 90th week.  Eleven
treated animals developed tumors at different sites (including 1 hepatoma),
as did 8 controls  (Agthe et al, 1970).
                                   -88-

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Dog

     A total of 22 animals, approximately equally divided by sex, were
fed either 0 (2 dogs), 400 (2 dogs), 2000 (4 dogs), or 3200 ppm  (14 dogs)
DDT.  Only the control dogs, the 2 dogs given 400 ppm, and 2 of  the dogs
receiving 2000 ppm survived to the time of sacrifice  (29-49 months).
Functional liver damage but no tumors were observed (Lehman, 1952, 1965).

Monkey

     Dietary concentrations of either 5 or 200 ppm technical DDT were given
to rhesus monkeys (Durham et al, 1963).  Seven and a half years after the
beginning of treatment, 3/5 animals fed 200 ppm were alive and clinically
well.  In 2 additional groups totaling 6 animals receiving 200 ppm DDT
(either technical or the p,p'-isomer), 3 were alive after 3.5 years.  Animals
which did not survive died from intercurrent diseases not related to carcino-
gensis.

Data since 1972

     No studies, other than in mice, were reported concerning long-term
DDT testing after 1972.

Conclusion

     No studies have become available since 1972 to adequately demonstrate
the presence or absence of carcinogenic effects of DDT in species other than
the mouse.

     With animals such as the dog and monkey, which live considerably longer
than mice, the studies cited are of short duration, and too small a sample
size to yield any reliable information relevant to carcinogenicity.

     Although the evidence presented is limited in scope, it is apparent
that DDT did not consistently enhance the growth of well-defined hepatic
lesions in rats or hamsters.  However, the experiments available using species
other than the mouse are too limited to make definite conclusions.
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                       CARCINOGENICITY OF DDT IN  HUMANS
           Administrator's  Finding:   There  is  no  adequate  human epi-
           demiologioal data on the  oaroinogeniaity  of DDT,  nor is
           it likely  that it can "be  obtained.
 Data as of 1972

      In the first study,  40  men ranging in age  from 39-50 years  engaged in
 the manufacture  or formulation of  DDT were medically examined (Ortelee,
 1958).   Twenty-four workers  had also been exposed to other pesticides.
 The length of exposure was less than 1 year for 2 workers, 1-4 years  for
 21 workers, and  5-8 years for 17 workers.  Examination included  a complete
 medical history, physical and neurological examinations,  hemoglobin titre,
 white blood cell count and differential, plasma and erythrocyte  cholines-
 terase  determinations, and measurement of urinary DDA concentration.  DDT
 intake  was calculated from urinary DDA for 38 workers; in 10 cases it was
 10-20 mg/man/day, 30 mg/man/day in 15 and 40 mg/man/day in 13.  No evi-
 dence of neoplasia was found among the 40 workers at the  time of investi-
 gation.

      Another study was carried out on 35 workers with intensive  occupational
.exposure exclusively to DDT  (Laws  et al, 1967).  Ages ranged between  30 and
 63 years.  The range of exposure was 11-19 years.  Investigations include
 medical histories, physical  examinations, chest x-rays, blood  and urine tests,
 and measurements of fat,  urine, and serum concentration of DDT residues.  On
 the basis of DDT storage and DDA excretion, the daily intake of  DDT was esti-
 mated to be 3-6  mg/man in 3  workers with low exposure, 6-8 mg/man in  12 with
 moderate exposure, and 17-18 mg/man in 20 with  high exposure. No cancer was
 reported in any  of the workers.

      A  study involving 24 volunteers from a penitentiary  was started  in 1956
 (Hayes  et al, 1971).  The average  age was 34 years, and exposure to DDT lasted
 21.5 months.  Four men were  used as controls, and technical DDT  was given at
 daily doses of 3.5 mg/man to 6 men and 35 mg/man to 6 other men.  Another
 group of 8 men received 35 mg/man  day p,p'-DDT.  Two men  in each group  were
 kept under supervision until 4 years after beginning of the study, and  the
 remainder completed an additional  year.  However, no cases of tumors  were
 recorded although adipose tissue concentration  of DDT reached 280.5 ppm in
 the high dose group.

      Autopsy studies have been performed attempting to correlate cancerous
 diseases to the  amount of DDT stored in tissue  (Hoffman et al, 1967).  In
 one investigation, an average concentration of  9.6 + 6.5 ppm  total DDT  and
 DDE in  abdominal wall fat was reported among 292 patients with cancer;  this
 did not differ significantly from  an average of 9.4 t 6.5 ppm among 396
                                     -90-

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patients with other diseases.  Another study dealing with autopsy-material
from 38 persons aged over 36 years revealed that, of 19 patients with lower
tissue levels of organochlorine (total DDT + dieldrin + heptachlor epox-
ide), 4 had malignant tumors, whereas the corresponding figure for 19
patients with higher levels was 9 (Casarett et al, 1968).  In another in-
vestigation, the average level of DDT in fat tissues at autopsy was 21.96
ppm in 40 cases of carcinoma, 21.37 ppm in 5 cases of leukemia, 13.66 ppm
in 5 cases of Hodgkin's disease, and 9.75 ppm in 42 control cases.  Samples
from 6 patients with brain tumors showed fat and brain levels of DDT res-
idues comparable to those of controls.  In patients with nonneoplastic
liver diseases, fat and liver concentrations varied considerably throughout
all groups, and, therefore, reliable statistical analysis of differences in
group averages was not possible.

Data since 1972

     Since the 1972 DDT Hearings, no additional human studies with DDT in-
volving detailed medical followup over an extensive period have been
published.

Conclusion

     The epidemiological studies discussed are of too short duration and
too limited sample size to permit conclusions regarding carcinogenicity.
No additional studies have become available since 1972.  The studies ex-
amining DDT residues in adipose tissue of terminal cancer patients are
inconclusive since patients with nonneoplastic liver diseases also showed
higher adipose tissue levels of DDT than controls.
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                    CARCINOGENICITY OF DDT METABOLITES
     The activity of hepatic microsomal enzymes varies greatly between dif-
ferent strains of the same animal species, different animal species and
animals and man.  Since DDT is metabolized by hepatic microsomal enzymes,
its degradation in vivo may be affected by drugs and chemicals which induce
drug metabolizing enzymes.  Drugs such as diphenylhydantoin and phenobarb-
ital have been shown to induce (accelerate) the hepatic metabolism of DDT
in animals (Conney, 1967) and man (Edmundson et al, 1969; Schoor, 1970).
In fact DDT, being an inducer, also could conceivably accelerate its own
metabolism.  Consequently, it is of importance to review the in vivo metab-
olism of DDT and evaluate the activity of its metabolites.

Metabolism in animals

     DDT is metabolized in a variety of mammalian species by reductive de-
chlorination of TDE (Klein et al, 1964) and/or by dehydrochlorination to
DDE (Mattson et al, 1953; Pearce et al, 1952).  Both TDE and DDE are further
degraded in the liver and kidney to more polar metabolites which are ex-
creted in the urine or bile (Datta, 1970; Suggs et al, 1970; Judah, 1949;
Pinto et al, 1965).

     A considerable species variation exists in the rates of detoxification
of DDT to TDE or DDE giving rise to variable storage levels of DDE in the
adipose tissue (Ortega et al, 1956; Durham et al, 1963).  An example is the
higher ratio of DDE versus TDE in liver and perirenal fat after DDT adminis-
tration to Swiss mice, compared to the corresponding values in hamsters
(Gingell and Wallcave, 1974).

     Conversion of DDT to TDE also has been reported to occur via rat intes-
tinal flora (Mendel and Walton, 1966).

Storage in animals following continuous feeding

     A comparative study with mice and hamsters showed that following a 6-week
administration of a diet containing 250 ppm p,p'-DDT, levels of total DDT in
both liver and fat were 7-8 times greater in mice than in hamsters, i.e.,
56-70 ppm and 8-9 ppm in mouse and hamster liver, respectively, and 2400-2500
ppm and 290-310 ppm in mouse and hamster fat, respectively.  It must be taken
into consideration that food consumption in mice per kg body weight was 3 times
greater than in hamsters.  DDE residues in fat represented less than 1% in
both species; in the liver, DDE represented about 20% of residues in mice and
2% of residues in hamsters, the DDErTDE ratio being about 0.5 in mice and
0.02 in hamsters (Gingell and Wallcave, 1974).

     Feeding rats 200 ppm p,p'-DDT for 140 days led to fat concentration of
DDT in the order of 500 ppm in males and 1500 ppm in females; 10% of this was
present as ODD.  DDT and DDE concentrations in the liver were in the order of
13-25 ppm, with a DDT:DDE ratio of about 5:1 (Dale et al, 1962).
                                    -92-

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Metabolism and storage of DDT and its metabolites in man

     Ingested DDT yields, following a reductive dechlorination, IDE, which is
further degraded and readily excreted in the urine as DDA (Roan et al, 1971).
DDT is also slowly converted, by dehydrochlorination, into DDE (Morgan and
Roan, 1971), which is retained in adipose tissue (Abbott et al, 1968; Hayes
et al, 1971; Wasserman et al, 1967).  No increase in the urinary excretion of
DDA was noted after the oral ingestion of DDE by human volunteers; however,
such an increase was observed after ingestion of TDE or DDT (Roan et al, 1971).
The observations of Laws et al (1967) of occupationally exposed people indicate
that urinary levels of DDA are correlated to the levels of exposure to tech-
nical DDT and that DDT and its metabolites are stored in adipose and other
tissues.

     DDT is also excreted in human milk (Curley & Kimbrough, 1969; Quinby et
al, 1965; Zavon et al, 1969; Hornabrook, 1973; Kroger, 1972; Ritcey et al,
1972; Newton and Green, 1972; Wilson et al, 1973) and transferred through the
placenta (Curley et al, 1969; O'Leary et al, 1970; Zavon et al, 1969).

     The ingestion of technical or p,p'-DDT during 21.5 months was studied in
human volunteers.  The concentration in adipose tissue after administration
of technical DDT to man at a dose of 35 mg/man/day rose from a preexposure
level of 4.1 ppm to 280.5 ppm after 21.5 months.  After a recovery period of
37.8 months, 56.8 ppm DDT were still present.  The concentration of DDE
amounted to 8-11% of the total DDT in adipose tissue during the dosing period;
its proportional concentration relative to that of DDT increased during re-
covery phase and represented 47% at the end of this period (Hayes et al, 1971).
A high percentage of DDT is also stored as DDE in the general population
(Durham, 1969).

Carcinogenicity

     TDE (DDD)

     Mouse:  A group of 59 female CF mice was fed a diet containing 250 ppm
p,p'-TDE for lifespan, and tumor incidences were compared to a control group
of 98 males and 90 females.  Hepatomas were found in 52% of treated and 34%
of control males and only sporadically in females.  Incidences of lung tumors
were 86% in males compared with 54% in controls, and 73% in females compared
with 41% in controls (Tomatis et al, 1974).

     Rat_;  A group of 10 adult male Wistar rats was fed a low-protein, low-
riboflavin diet containing 600 ppm o,p'-TDE and killed at intervals from
                                   -93-

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24-469 days.  Testicular damage was observed from the second month onward.
Of the 3 animals killed after 348 or more days, one rat had microscopic
adenomatous nodules and 2 had tumors of the interstitial cells of the testes.
These lesions are considered related to specific degenerative changes in-
duced on the adrenal cortex by o,p'-TDE.  (Lacassagne and Hurst, 1965).

     DDE

     Mouse;  A group of 53 male and 55 female CF mice was fed a diet con-
taining 250 ppm p,p'-DDE for lifespan, and tumor incidences were compared to
those observed in a control group of 98 males and 90 females.  Hepatomas
were found in 74% treated males and 98% treated females compared with 34%
and 1% in the controls.  Incidences of other tumors were not increased
(Tomatis et al, 1974).

Conclusion

     The DDT metabolites, p,p'-DDE and TDE (ODD), were tested by oral admin-
istration to mice.  An increase in hepatomas was observed with both metab-
olites; also an increase in lung tumors occurred with TDE.  Hepatomas were
not observed in rats with a high dose of 60 ppm o,p'-TDE although testicular
damage was seen.  It is interesting that, in a comparative feeding study,
residues of DDE in rat livers were 10 fold greater (as a fraction of total
liver DDT levels) than amounts observed in hamster liver (Gingell and Wall-
cave, 1974).  These studies with DDT metabolites are limited and results are
not conclusive.  The fact that these metabolites and DDT accumulate in
adipose tissue of animals and man, and the fact that they do have tumor
producing potential, would suggest that the metabolites may act with DDT
or other DDT metabolites in vivo to potentiate a tumor producing capability;
or that the metabolites themselves may be the active tumorigens in mice.
                                    -94-

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                  EFFECTS OF DDT SUBSTITUTES ON HUMANS
          Administrator rs Findings (VI3  Matters Relating to Methyl
          Parathion):  A.  Basic Findings  1) Many poisonings have
          been attributed to the use of methyl parathion.   2) Un-
          trained users of methyl parathion are frequently not
          sufficiently careful in its use despite label directions.
          3) Methyl parathion can be used safely.  4) Training pro-
          grams are useful in averting the negligent use of methyl
          parathion.  5)  Methyl parathion is a substitute for most
          crop uses of DDT.  B.  Ultimate Findings  1) Methyl parathion
          is dangerous to users and presents a risk to them.  2) An
          opportunity to train users will minimize the risks and
          keep down the number of accidents.


Data as of 1972

     The availability of efficacious alternatives to DDT which would not
present undue or unreasonable risks to man was addressed in some detail
in the Administrator's Decision to cancel DDT (particularly part V.B).   The
above findings were a key element in the decision leading to the cancellation.
Methyl parathion was found to be the principal substitute for most crop uses
of DDT.  Though many poisonings were attributed to the use of methyl parathion,
it was found that it can be used safely (Tr:6366; Tr:248).  Many accidents
connected with the use of methyl parathion are the result of untrained
workers who are not sufficiently careful in its use (Tr:6406).  Therefore,
training programs were found to be useful in averting the improper use  of the
pesticide (Tr:3118).

Data since 1972

     A source of information on acute (and chronic) effects of DDT substitutes
is the reviews conducted by the Criteria and Evaluation Division, Office of
Pesticide Programs, EPA,  under the Substitute Chemical Program (SCP).  The SCP
was initiated under Public Law 93-135 of October 24, 1974, to "provide  research
and testing of substitute chemicals."  The legislative intent was to prevent
use of substitutes, which may be more deleterious to man and the environment
than a problem pesticide (one that has been suspended, cancelled, deregistered,
or in an internal review for suspected "unreasonable, adverse effects to man
or his environment").  Fourteen substitutes for DDT are being studied under
the SCP.  Excerpts from the studies on DDT substitutes published thus far in
this SCP series relative to acute human health hazards are presented in
Appendix IIIB1.

     These evaluations of occupational safety hazards associated with the SCP
reviextfs are based on available state and federal accident monitoring systems.
Analysis of the Pesticide Accident Surveillance System (PASS), shows that
between 1972 and 1973 parathion and methyl parathion were associated with 78%
of the reported episodes  (Osmun, 1974).

     A more recent analysis of data based on EPA's Pesticide Episode Reporting
System (PERS) tends to confirm the impression developed in the SCP reviews


                                   -95-

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(see Appendix IIIB2).   That is, it appears that the above-named compounds
together with methomyl and several registered substitutes have been associated
with numerous reports  of occupational poisonings (Appendix IIIB2).   Yet, it
appears that in many cases, these accidents were avoidable had label pre-
cautions been heeded.   In fact, on the whole, there is no evidence  in
available state and federal accident monitoring systems which would indicate
the DDT decision has increased the number of accidents associated with the
use of substitute pesticides.

     One must move with caution, however, in assessing available data.  The
most reliable accident data appears to be reported from two state sources —
California and Florida— but, neither of the states were major DDT users.
Thus, in order to evaluate the DDT decisions, we must return to the national
data in the EPA's PASS and PERS.  However, careful examination of all the
episodes in these systems indicates that these data are not sufficient to
rigorously evaluate impact of the DDT decision, in specific use patterns where
DDT was used.  Although the national reporting systems are being strengthened,
for present purposes,  they do not permit establishing incident rates by com-
pound and crop or other use patterns.  Until this is accomplished,  precise
evaluations will not be possible on the relative occupational safety of various
pesticides.

     Since the cancellation, there have been several EPA program actions
taken to forestall and evaluate the possibility of adverse effects  stemming
from the use of acutely toxic pesticides.  These are discussed below.

     Immediately following the DDT cancellation, concern for the possibility
of poisonings among former DDT users unfamiliar with the hazards of the
more acutely toxic substitutes prompted the initiation of Project Safeguard
(1972).  Small acreage cotton growers were designated as a key target group
in this effort.  The program was organized jointly by EPA and USDA and funded
by EPA (about $2 million) and USDA.  The target area included Alabama, Arkansas,
Florida, Georgia, Kentucky, Louisiana, Mississippi, Missouri, North Carolina,
Oklahoma, South Carolina, Tennessee, Texas, and Virginia.  New Jersey was added
to the project later because it was considered a "pocket problem" area.

     Project Safeguard's first priority was contacting farmers but, dealers,
applicators, formulators, and medical personnel were contacted also in an
effort to produce an integrated safety program.  Safeguard was successful in
its efforts, its major strengths being:  the ability to effectively reach
small-acreage farmers  and ancillary populations; the production of  effective
literature and media;  and the spirit of cooperation fostered among  various
federal agencies, state governments, community groups, and industry.  Some
weaknesses existed in the program due to its short-term, rapid implementation
nature.  For example,  some concern should be raised about the extent to which
non-English speaking groups were sensitized to the danger.  Despite these
problems, Project Safeguard proved quite effective in getting pesticide
safety information to  the target audiences, to prevent an increase of pesticide
poisonings (Cannon, 1974).

     More recently EPA has taken an additional programmatic step to forestall
accidents associated with agricultural use of  toxic pesticides.  In March
                                  -96-

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1974, the Office of Pesticide Programs, EPA, proposed promulgation of health
and safety standards for field workers potentially subject to poisoning by
toxic pesticides (EPA, 1974).  These standards were based on a variety of
inquiries designed to specify the problem, including a series of public
hearings in various regions of the country.  The thrust of these standards
is the setting of a minimum unprotected worker re-entry standard (48 hours)
for yields treated with specific toxic pesticides, e.g., ethyl and methyl
parathion.  Anyone entering the field prior to the conclusion of this safety
interval is required to wear protective clothing.  These worker re-entry
standards are now in effect.

     During FY 1975, two contract research efforts were initiated by EPA in
order to examine acute toxicity safety standards more closely.  The first
was concerned with estimation of the extent to which soil, air, and plant
surface residues are available for exposure of the field worker.  This is
a continuing study through FY 1976.  The second study, now nearing completion,
was concerned with the extent of health effects from ethyl parathion
exposure of workers in peach orchards in Washington state.  Preliminary indi-
cations in the peach study are that workers are suffering no ill effects from
exposure.

     EPA's applicator certification and training programs now in process of
implementation will contribute to safer application of DDT alternatives.

     The Administrator, in his decision, quite clearly took into account the
acute health risks of DDT alternatives, specifically methyl parathion.
Later in this report data will be presented on use patterns of pesticides
on cotton which indicate that there were several other registered alternatives
for most cotton pests and that increases occurred in the use of other
alternatives.  Use of Toxaphene/methyl parathion combinations on cotton
increased greatly.  However, ethyl and/or methyl parathion use actually de-
clined slightly in 1973-1974.

Conclusion

     At the present time, there is no basis in the available evidence to
link the DDT decision to a precipitous increase in pesticide poisonings
among those shifting to new or heavier reliance on the registered alternatives
to DDT.

     As will be seen later in this report, methyl parathion (and some of the
other more acutely toxic insecticides) were already in general use prior to
the cancellation, in the case of cotton the major DDT use.  DDT was not
generally used alone, but in combination with one or more of the chemicals
which replaced it.  For this reason, as of 1973, most farmers who had been
using DDT had some knowledge of or working experience with acutely toxic DDT
substitutes.  However, dosage and frequency of applications may have increased
in some areas, thus increasing risks to exposed persons.  Some of the DDT
substitutes are not highly acutely toxic, e.g. Toxaphene.
                                   -97-

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Report of the Committee on Pesticides.  Pharmacologic and toxicologic prop-
  erties of DDT (chlorophenothane).  J. Am.  Med. Assoc. 145:728, 1951.

Ritcey, W.R., G. Savary, and K.A. McCally.   Organchlorine insecticide res-
  idues in human milk, evaporated milk and some milk substitutes in Canada.
  Can. J. Public Health 63:125, 1972.

Roan, C.C., D.P. Morgan, and E. Paschal.   Urinary excretion of DDA follox^ing
  ingestion of DDT and DDT metabolites in man.  Arch. Environ. Health 22:
  309, 1971.
                                  -102-

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Roe, F.J.C., and G.A. Grant.  Inhibition of germ-free status of development
  of liver and lung tumors in mice exposed neonatally to 12-dimethylbenz-
  (A)-anthriacine:  Implications in relation to tests for carcinogenicity.
  Int. J. Cancer 6:133, 1970.

Sanchez, E.  DDT-induced metabolic changes in rat liver.  Can.  J.  Biochem.
  45:180, 1967.

Schoor, W.P.  Effect of anticonvulsant drugs on insecticide residues.
  Lancet 2:520, 1970.

Shabad, L.M., T.S. Kolesnichenko, and T.V. Nikonova.   Transplacental and
  combined long-term effect of DDT in five generations of A-strain mice.
  Int. J. Cancer 11:688, 1973.

Suggs, J.E., R.E. Hawk, A. Curley, E.L. Boozer, and J.D. McKinney.  DDT
  metabolism:  Oxidation of the metabolite 2,2-bis (p-chlorophenyl)ethanol
  by alcohol dehydrogenase.  Science 168:582, 1970.

Tarjan, R., and T. Kemeny.  Multigeneration studies on DDT in mice.  Food
  Cosmet. Toxicol. 7:215, 1969.

Terracini, B., M.C. Testa, J.R. Cabral, and N. Day.  The effects of long-
  term feeding of DDT to BALB/c mice.  Int. J. Cancer 11:747, 1973a.

Terracini, B., R.J. Cabral, and M.C. Testa.  A multigeneration  study of
  the effects of continuous administration of DDT to  BALB/c mice.   In:
  Deichmann, W.B., Ed.  Pesticides and the Environment, a Continuing Con-
  troversy (Proceedings of the 8th Inter-American Conference on Toxicology,
  Miami, Florida, 1973), p. 77.  New York, London, Intercontinental Medical
  Book Corp. , 1973b.

Thorpe, E., and A.I.T. Walker.  The toxicology of dieldrin (HEOD).  II.
  Comparative long-term oral toxicity studies in mice with dieldrin, DDT,
  phenobarbitone, g-BHC and y-BHC.  Food Cosmet. Toxicol. 11:433,  1973.

Tomatis, L., V. Turusov, N. Day, and R.T. Charles.  The effect  of long-
  term exposure to DDT on CF-1 mice.  Int. J. Cancer 10:489, 1972.

Tomatis, L., V. Turusov, R.T. Charles, and M. Boicchi.  Effect  of long-
  term exposure to l,l-dichloro-2,2-bis(p-chlorophenyl)ethylene, to 1,1-
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  bined on CF-1 mice.  J. Natl. Cancer Inst. 52(3):883-891, 1974.

Tomatis, L., C. Partensky, and R. Montesano.  The predictive value of
  mouse liver tumor induction in carcinogenicity testing - A literature
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Tomatis, L., V. Turusov, B. Terracini, N. Day, W.F.  Barthel, R.T.  Charles,
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  mouse tissues following long-term exposure to technical DDT.   Tumori
  57:377, 1971.

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  CF-1 mice exposed for six consecutive generations  to DDT.   J.  Natl.
  Cancer Inst. 51:983, 1973.

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  (HEOD).  I.  Long-term oral toxicity studies in mice.  Food Cosmet.
  Toxicol. 11:415, 1973.

Warwick, G.P.  Metabolism of liver carcinogens and other factors influenc-
  ing liver cancer induction.  In:  Liver Cancers (Proceedings  of a work-
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  body fat of people in Israel.  Arch. Environ. Health 11:375,  1965.

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  cinogens:  On the concept of zero tolerance.  Food Cosmet. Toxicol. 6:
  235, 1968.

Wilson, D.J.M., D.J. Locker, C.A. Ritzen, J.T. Watson, and W. Schaffner.
  DDT concentrations in human milk.  Am. J. Pis. Child. 160:196, 1969.

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  content of the neonate.  Ann. N.Y. Acad. Sci. 160:196, 1969.
                                  -104-

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                           Ill
C.  MONITORING OF DDT RESIDUES IN THE ENVIRONMENT AND MAN

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                         PERSISTENCE OF DDT IN SOIL
          Administrator 's Finding:  DDT can persist in soils for
          years and even decades.


     A typical degradation curve for DDT in soil leads to half-life values
ranging from several years to a decade or more.  The major DDT metabolite
in soil, under normal conditions of aeration, is DDE.   This compound is
also highly persistent.  Since DDT and DDE are strongly adsorbed to soil
particles and are highly insoluble in water, they do not move readily from
their site of application and therefore a substantial amount will remain
at the site of application for long periods of time.

Data as of 1972

     The high degree of persistence of DDT, under many typical environmental
conditions, has been well established by many investigators.  Precise pre-
diction of the long-term disappearance rate, however, is very difficult since
a large number of factors can affect soil persistence:  1) rate of applica-
tion, 2) mode of application, 3) soil type, 4) soil fertility, 5) type of
formulation, 6) topography, 7) climatic conditions, 8) cropping practices,
and 9) soil pH.

     Breakdown of DDT in soil can proceed by several routes depending in
part on the redox potential of the soil matrix.  Under aerobic conditions,
slow conversion to DDE  [l,l-dichloro-2,2 bis(p-chlorophenyl)ethylene] will
normally occur.  Under  flooded anaerobic conditions, direct and rapid con-
version to ODD (TDE), l,l-dichloro-2,2-bis(p-chlorophenyl)ethane can occur
which, in turn, can be  converted to more polar compounds such as DDA,
[bis(p-chlorophenyl) acetic acid].  DDE is quite resistant to microbial
attack and unless lost  from the soil it can be stable for extended periods.

     A study of DDT persistence in Oregon orchard soils indicated that
40% of the total amount originally applied remained at the end of 20 years
(Tr:721-722).  Another  study in a Maine forest showed no significant decline
of DDT after a 9-year period following aerial treatment for spruce budworm
control (Tr:3523).  The National Soil Monitoring Program showed that at
least five states had soil residues averaging greater than 1 ppm DDT
(Tr:3535).

Data since 1972

     A number of studies related to time decline of DDT in soils have been
reported.  Some of the  more significant reports are described:

     Kuhr et al (1972)  in a study on New York vineyard soil showed that after
24 years, 22% of applied DDT could still be recovered.  Of this amount, 27%
was present as DDE.
                                 -106-

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     Another study (Chisolm et al, 1972) gave a half-life value of 15 years
for DDT in a field experiment conducted in Nova Scotia on sandy loam soil.
The authors also claimed that significant reductions in bean crop yields
were associated with the high DDT residues.

    - Ware, Estesen, and Cahill (1974) reported an "almost imperceptible"
decline in total DDT residues in Arizona soils over a 4 year period follow-
ing the 1969 DDT state moratorium.

     Additional studies on DDT residues in forest soils have become
available on Canadian land sprayed for spruce budworm control (Yule, 1973).
Treatments totalling 70 oz DDT/acre had been applied between 1956 and 1967.
Samples were taken between 1967 and 1971.  A projection of the average loss
rate for DDT residues found on the plots give an estimated half-life in the
order of 10 years.

     Wiersma et al (1973) surveyed"total DDT residues in soils from eight
major US cities.  Levels varied significantly among cities with the average
level varying from a high of 5.98 ppm to a low of 0.35 ppm.  Residue levels
in lawn areas were significantly greater than in unkept urban areas.

     A taiga forest, treated for control of mite encephalitis with 4.44 Ibs
DDT/acre,showed 7.4 ppm in the upper soil horizon after one year.  After 14
years, this level decreased to 0.47 ppm (Konstantinov, 1972).  Since the
combined residues of TDE and DDE represented less than 10% of total residues,
loss mechanisms other than microbial degradation are suggested.

     Other new information relating to persistence concerns various environ-
mental parameters which can affect the longevity and nature of DDT residues
in soils.  Collyard et al (1972) showed that DDT in soil can be degraded to
TDE in the presence of cattle manure.

     Albone et al (1972) demonstrated a new nonpolar metabolite from anaerobic
microbial decomposition, bis(p-chlorophenyl)acetonitrile or p,p-DDCN.   Jensen
et al (1972) found up to 0.6 ppm of this product in aquatic bottom sediments
from Lake Maeloren, Sweden.

     Several studies involving in vitro microbial degradation under anaerobic
conditions have been reported (Jensen et al, 1972; Pfaender, 1972; Albone,
1972; Zoro, 1974).  In all cases, substantial amounts of TDE were formed
which did not further degrade.  Similar findings in natural ecosystems have
not been reported.  Striking differences in degradation rate of 14c-labeled
DDT in estuarine sediment in' situ compared with laboratory incubated samples
under hydrogen were noted by Albone et al (1972a).  These observations are
consistent with real life situations where only small conversions of p,p'-DDT
to dehydrochlorinated products occur in many aquatic systems, even over a
period of many years.

     Also, the stability of DDT and related compounds was studied under
alkaline conditions.  Based on data developed, normally encountered environ-
mental pH variations should have little if any effect on the dehydrohaloge-
nation reaction (Smith, 1972).
                                    -107-

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     The quantitative aspects of pesticide decomposition have recently
been reviewed by Hamaker (1972) and it is clear that degradation pro-
cesses of many pesticides, including DDT, cannot be defined in terms of
simple reaction kinetics.  Until superseded by better descriptions, the
concept of Wheatley (1964) seems most appropriate where the logarithm
of the half-life is related directly to time on a linear basis.  This
affirms much of the current field persistence data wherein high initial
loss phases are succeeded by slower changes.

     Base-line data for DDT in US soils have been established by the
National Soils Monitoring Program.   Therefore, future time-rate declines
should be comparatively simple to establish by means of programmed re-
sampling.  The monitoring programs for FY 1969 and FY 1973 showed that
DDT levels in soil have significantly decreased.  The overall average de-
creased from 0.36 ppm to 0.23 ppm, and the geometric mean estimate, with
95% confidence levels shown in parenthesis, decreased from 0.015 ppm
(0.017-0.013 ppm) to 0.010 ppm (0.011-0.008 ppm) (Carey, personal communi-
cation, 1975).

Conclusion

     The preponderance of evidence clearly demonstrates that DDT is
stable in soil under natural environmental conditions.  While under
certain conditions, transformations to the metabolites DDE and TDE can
occur, these also resist further degradation.

     Due to the severe restrictions placed on the use of DDT in recent
years coupled with DDT's high degree of persistence a gradual leveling
out of the residues of DDT can be anticipated.   Future residue levels in
crops grown in soils last treated with DDT in 1972 can be expected to
remain at current or only slightly lower levels.

     While average levels of DDT are expected to decline slowly, the ratio
of DDE to DDT can be expected to increase.  As noted elsewhere in this
document, levels of DDE relative to DDT have increased constantly in many
food commodities in recent years, reflecting the slow trend in soils away
from parent DDT pesticide to the DDE metabolite.
                                  -108-

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               TRANSPORT OF DDT FROM AERIAL APPLICATION SITES
DRIFT
          Administrator's Finding:  DDT can be transported by drift dur-
          ing application,                                ^


     Pesticides drifting as minute particles, especially from aerial applica-
tion, have caused widespread contamination of nontarget portions of the en-
vironment.  Since about only 50% of an aerially applied pesticide reaches
the target area, a substantial portion of the environment is exposed to such
drift.  Localized drift has contributed significantly to contamination of
food and feed, whereas more distant movement has probably contributed sub-
stantially to the world-wide distribution of DDT.

Data as of 1972

     Drift of DDT, when applied aerially, is "virtually impossible to prevent"
(Tr:749).  Even with the most up-to-date aerial application devices, up to 6%
of an aerial spray can exist as particles with diameters of less than 50 microns
(Tr:467; 502).  These particles are known to be highly mobile and it is impos-
sible to control their movement to nontarget sites.

Data since 1972

     Insecticide application technology has not improved in the last several
years so as to significantly reduce drift problems.

Conclusion

     Problems encountered with the drift of DDT can be expected to recur if
DDT were to again come into general use as a pesticide.

VAPORIZATION


          Administrator's Finding:  DDT can Vaporize from crops
          and soils.

     DDT, like many organic pesticides, tends to vaporize.  DDT lost to the air
can contribute to air pollution, soil residue declines, and to low-level crop
residues by redeposition.  Quantitative estimates of these various factors are
extremely important with regard to predicting long-term changes in environmental
residues of DDT and its metabolites.

Data as of 1972

     DDT may substantially vaporize given the proper physical environment (Tr:
727).  Once vaporized, the pesticide can attach itself to suspended particulate
                                    -109-

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matter (Tr:718) and be carried to the far reaches of the Earth (Tr:741-742;
EDF-16; EDF-17).  It has been estimated that up to 250,000 pounds per year
can vaporize from southern cotton soils alone (Tr:7757).

Data since 1972

     Additional data (Cliath and Spencer, 1972) are provided in support of the
high relative volatility of p,p'-DDE as compared to DDT with the suggestion
that the major pathway of loss is probably via this route.  An attempt to mod-
ify the volatility of DDT residues in soil was by means of flooding and organic
matter amendments (Spencer et al, 1974).  Only minor changes in vapor concen-
tration were noted but, regardless of treatments, DDE remained the major con-
stituent to volatilize.  Total DDE volatilizing from such treatments will ulti-
mately be decreased, since TDE rather than DDE is the major product from
flooded soil (anaerobic) degradation.  The volatilization of DDT or DDE, as a
major source of global atmospheric contamination, was discounted by Freed et al
(1972) primarily on theoretical grounds.

     The translocation of chlorine-36-labeled DDT in an-old-field ecosystem was
studied by Bandy (1972).  The leaves of 10 herbaceous plant species carried DDT
residues at one or more periods during the growing season.  DDT vaporization
from the soil, followed by condensation on the plant surfaces, is thought to be
the mechanism of contamination.  The exact role of volatilization versus root
translocation in terms of low-level residues in feed and forage crops is worthy
of additional study.

     Plimmer et al (1970) and Moilanen and Crosby (1973) have shown that DDT can
be photochemically converted to polychlorinated biphenyls (PCB's).  The impli-
cations of this finding in light of additional environmental PCB burden is dis-
cussed by Maugh (1973).  However, Harvey  (1974) and Plimmer and Klingebiel (1973)
discount the significance of this finding.  Their reasoning is that PCB's de-
rived from DDE would contain a much lower percentage of chlorine than those
normally encountered in the environment.

     Kerner et al (1972) report two new photoproducts of DDE from vapor phase
photolysis.  Physical properties of these products are not described, so that
their lipophilic (bioaccumulative) potential cannot be estimated.  Miller et al
(1973) report that a triplet sensitizer, decyl bromide, can sensitize the pho-
tolysis of DDT by way of the intermediate TDE.

     Several additional reports on measurements of particulate matter, rainfall,
or fallout of DDT in various parts of  the world are available:  particulate
matter (Lloyd-Jones et al, 1972; Prospero et al, 1972), rainfall (Edwards, 1973;
Craig et al, 1973; and Hughes et al, 1972).  None of these adds significantly to
previous observations that low levels of DDT can indeed be transported by air to
the far reaches of the world.  Cramer (1973) proposed a model for the global
transport and accumulation of DDT based on a low mean residence time in air and
a low rate of transfer from land to air.

     Sodergren (1972) measured fallout with silicone-impregnated nylon filter
nets near Swedish agricultural areas.  Levels ranged from 100 to 2,000 mg/m^/month
depending on the season.  It could not be established whether the DDT originated
within the local agricultural region, or had been transmitted from far away.

     No additional air monitoring data are available on DDT.


                                  -110-

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Conclusion

     Vaporization of DDT and DDE from soils is qualitatively well established.
However, the contribution such volatilization makes to overall global
dispersal has not as yet been determined.  DDT may be deposited on plant
surfaces and may be volatilized from the surface; these processes are
dynamic in nature and will ultimately approach an equilibrium.
SOIL EROSION
                   Administrator's Finding:  DDT can be attached
                   to eroding soil particles
     Runoff of soil particles has long been established as a primary route
of chemical transfer from terrestrial to aquatic sites.  Vast quantities
of particulate matter are yearly carried by water to low-lying areas and,
to a certain extent, on into the oceans.  Some of our richest agricultural
areas (delta lands) are associated with the end product of numerous suth
annual occurrences.  Since DDT is extremely insoluble in water but readily
adsorbed on soil particles, soil erosion is a major transport mechanism
from agricultural areas into aquatic environments.  Similarly, DDT can be
transported by means of treated sewage sludge draining from sewer systems
into aquatic sites.

Data as of 1972

     Runoff is a major source of DDT contamination in aquatic environments,
occurring particularly after heavy rainfall.  DDT is strongly bound to
soils (Tr:717) and erosion of soil particles has been established as the
principal means of contamination of lakes, streams (Tr:729; R-107; R-26),
rivers, and estuaries.

Data since 1972

     A number of studies concerning aquatic sediment fractions as they
relate to pesticide content of water systems have been described.  Some
of the most relevant studies are described below:

     Bradley, Sheets, and Jackson (1972) found that over a 6-month period
following DDT application to cotton plots, 2.83% of the DDT applied was
present in runoff waters.  Of this amount, 96% of the DDT was associated
with the sediment fraction.

     High residues in certain portions of bottom sediments from a Salinas
River monitoring program (Routh, 1972) were found to be associated with a
fine-particle, light-weight sediment as compared to a different textured
                                    -111-

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material collected from other sampling sites.  Sediments precipitated from
the collected water samples contained about 3 times as much total DDT as
bottom sediments from the same sites.

     Ahr (1973) discussing long-lived pollutants in sediments from the
Laguna Atascosa National Wildlife Refuge, Texas, suggests that environ-
mental studies made by geologists are needed to assess the significance
of sedimentary layers which may ultimately be relocated by post deposi-
tional, biological, or mechanical processes.

     Contamination of cisterns with DDT-laden sediment is a frequent occur-
rence on the island of St. John in the Virgin Islands.  Previously DDT was
used extensively in agriculture on these islands (Lenon et al, 1972).

     Schulze, Manigold, and Andrews (1973) determined that pesticide con-
centrations in western streams were always highest in water samples con-
taining appreciable amounts of suspended sediments.

     Several studies have been reported dealing with the adsorption of DDT
on soil particles.  For example, Weil, Duke, and Quentin (1973) determined
the heat of adsorption of DDT to humic substances to be 2.5 kcal/mole.
Biggar, Doneen, and Riggs (1966) reported on the adsorptive behavior of
various insecticides, including DDT in solution, onto soils.  The adsorp-
tion of 14C DDT on coloring colloids in surface water also has been deter-
mined (Poirrier et al, 1972).

     Finally, the ability of sodium humate to solubilize DDT is discussed
by Khan and Schmitzer (1972).  Such a phenomenon could possibly increase
the total amount of DDT solubilized from bottom sediments and thereby
make it more available to fish and other aquatic life.

Conclusion

     All available evidence suggests that erosion is a significant source
of transport for DDT via runoff of particulate matter.  Continued long-
term contamination of aquatic sites from agricultural soils can be antici-
pated since localized flash flooding of fresh plowed fields can never be
controlled and such events can lead to significant losses of particulate
matter.  Some decline of the environmental burden of DDT can be expected
from the continued sedimentary deposition of DDT residues into the upper
soil horizons coupled with overlayering of fresh sediments containing
smaller amounts of adsorbed DDT.  This may lead to a partial decline of
available DDT per unit area of surface.
                                    -112-

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                  CONTAMINATION OF THE AQUATIC ENVIRONMENT
          Administrator 's Finding:  DDT is a contaminant of fresh waters,
          estuaries and the open ocean, and it is difficult or impossible
          to prevent DDT from reaching aquatic areas and topography
          nonadjacent and remote from the site of application.
     DDT residues are ubiquitous in the aquatic environment, especially
downstream from tributary waterways draining either urban or agricultural
areas.  This contamination generally permeates the major river systems
and the estuaries receiving land based runoff.  Transport into remote
ocean areas can take place in a number of ways including movement on sus-
pended particulate matter; dissolved in ocean water; movement of plankton
by ocean currents; and as an accumulated residue in free swimming fish.
A final source of transfer is rainfall which can carry not only volatilized
DDT from other water bodies but also DDT adsorbed on particulate matter
directly from terrestrial environments.

Data as of 1972

     DDT is commonly found in lakes, streams, ponds, estuaries, and ocean
sediments  (Tr:3808; Tr:5730; Tr:3699-3700).  Although these levels are
often quite low, DDT is concentrated and magnified in aquatic organisms
(Tr:3714) and is being transported into the ocean (EDF-30).  Residue
buildup in fish and other aquatic organisms is also transferred to marine
mammals and birds (Ref-1) and to remote sections of the world such as
Antarctica (Ref-2).

Data since 1972

     Leland et al (1973) found a strong relationship between quantity of
adsorbed total DDT on Lake Michigan bottom sediments and organic content
of sediment.  DDT was the principal component of sediments except in the
eastern edge of the South Basin where reducing conditions (anaerobic)
are found.  Here, the predominant form was TDE.

     Oertzen et al (1972) calculated that 2.78 x 10^ tons of DDT are
introduced into the ocean each year by precipitation or runoff.  Georgii
(1973) calculates a similar amount.

     Two reports stemming from the National Water Monitoring Program
have been issued recently.  One deals with pesticide levels in selected
western streams over the period 1968-1971 (Schulze et al, 1973) and
another with chlorinated hydrocarbons in sediments from tributary streams
of San Francisco Bay (Law et al, 1974).  Both authors show the ubiquity
of DDT residues stemming from watersheds within the United States.
Similar stream monitoring projects are underway in Canada.  A recent
report by Harris et al (1973) reviews results of a 1971 survey of streams
                                      -113-

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draining agricultural, urban-agricultural, and resort areas of Ontario.
Of these areas, the greatest total DDT transport was noted in the Muskoka
River which drains a resort area where DDT was used for control of biting
flies until 1966.  A peak of 11.8 Ibs total DDT/week was recorded in May
with a May to October average of 1.9 Ibs/week.

     DDE contamination off the southern California coast (MacGregor, 1974),
stemming primarily from sewage plant effluents from a DDT manufacturing
plant, is approaching a maximum level where metabolism and dispersion of
DDT equal system input.  DDT was entering the coastal system from 1949-
1970.  A best fit accumulation formula, based on residue patterns in
myctophid fish between 1950 and 1966, utilized 2%/year as the value of DDE
degradation.  This suggests half-life values for DDE numbering in decades.

Conclusion

     Contamination of aquatic areas with DDT and its metabolites can be
expected to remain for a considerable period of time.  Much contamination
is associated with aquatic sediments and therefore, the ultimate fate of
DDT will depend on what happens to this material.  For example, DDT-laden
sediments can be overlayed with fresh uncontaminated sediments; or they
may be resuspended at a later time only to be redeposited elsewhere.

     Persistence of a chemical in an aquatic ecosystem implies a dynamic
relationship between the various components within the system, slow degrada-
tion of the chemical in question, and a high retention index within the
system.  In the case of DDT and its significant metabolites, the bottom
sediments act as the primary reservoir or storage compartment for excess
quantities of DDT.  These bottom sediments are composed of mineral fractions
having a wide distribution of particle sizes along with organic matter
including animal detritus and humic substances associated with eroded
soil.  DDT in excess of the water solubility (0.0012 ppm) is adsorbed
onto these sediments and in turn is available for direct ingestion by
bottom dwelling organisms or for resolubilization back into the aqueous
phase.  In turn, the DDT solubilized in the aquatic phase is available
for direct incorporation to varying degrees into all trophic levels of
the aquatic food web.  Eventually, much of this DDT is recycled back to
the sediment reservoir from which it can again become available.
                                    -114-

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                     PERSISTENCE IN AQUATIC ECOSYSTEMS
             Administrator's Finding:  DDT can persist in aquatic
             ecosystems.
     DDT and its lipid-soluble metabolites, DDE and TDE, adsorb readily
onto aquatic sediments and from this storage reservoir transfer to the
benthos and free-swimming organisms including plankton, crustaceans,
and fish.  The aquatic phase, per se, can hold only a limited amount of
the total DDT in many existing contaminated environments and serves
mainly as a transfer mechanism between the sediment and aquatic organisms.
Much DDT is constantly recycling, but with time is also slowly metaboliz-
ing.  DDE, the main metabolite of DDT, is also persistent and capable of
recycling in aquatic systems.

Data as of 1972

     Persistence of pesticides in aquatic environments was recognized in
the early phases of environmental concern over DDT.  Residues in fish
have been monitored since 1965 in the Great Lakes  (Reinert, 1970).  The
National Estuarine Monitoring Program, established in 1965, was also
concerned over the persistent chlorinated hydrocarbons, especially DDT,
existing in our nation's estuaries.  Numerous other incidents had clearly
established that long-term residues of DDT and similar compounds could
cycle through the aquatic environment.  Model ecosystem studies reported
by Metcalf (1972) clearly demonstrated the potential for DDT and its
lipid soluble metabolites to penetrate into every component of an aquatic
environment.

     Because of the low water solubility of DDT (0.0012 ppm) and the
frequent contamination of aquatic areas from local applications due to
erosion and runoff associated with heavy rainfalls, excess DDT tends to
be taken up on sediments, living organisms, and other particulate matter.
Due to the highly variable nature of bottom sediments and more immediate
concerns over residues in fish and drinking water  (filtered water),
most efforts aimed at defining problems in aquatic environments gave
secondary emphasis to sediment analyses.  However, a striking example of
long-term persistence of DDT was given by Dimond et al (1972), where
residues of DDT in stream bottom muds, plants, insects, mussels, and
fish existed for a period up to 10 years following single applications
of DDT.  In animal samples, 60-85% was present as DDE whereas mud
samples contained 35%, 45%, and 20% DDT, DDE, and TDE, respectively.
                                     -115-

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Data since 1972

     Vind, Muraoka, and Mathews (1973) deposited a number of chlorinated
hydrocarbons, including DDT, on diatomaceous earth and cultured them with
marine microorganisms in seawater.   No appreciable degradation occurred
after one year.  Degradation of p,p'-DDT in situ by estuarine sediments
(Severn estuary) proceeded much more slowly than companion studies con-
ducted under hydrogen in the laboratory (Albone et al, 1972).  This is
consistent with findings of substantial residues in these sediments
resulting from agricultural runoff from the watershed serving this
estuary.

     Harvey  (1974) concludes that the half-life of DDT in ocean water
is only 10 days.  However, his information source (Wilson, personal
communication, 1975) has conducted more extensive tests where, during
short exposure periods, solubilized DDT in seawater is found to be
transferred to suspended material but not necessarily lost or extensively
degraded.  Rice and Sikka (1973) found that various organisms are able to
remove dissolved DDT and DDE from seawater.

     Patil, Matsumura, and Boush (1972) found, in laboratory incubation ex-
periments using filtered sea water, that no significant degradation took
place.  On the other hand, particulate materials in the presence of sea
water caused further degradation to both polar and nonpolar metabolites.

Conclusion

     Persistence of DDT in aquatic ecosystems has been well documented
and long-term studies support the conclusion that contaminated waters
and sediments will purge themselves of DDT only after a long hiatus of DDT
usage.  In those contaminated areas, a gradual conversion of DDT to DDE and
TDE can be expected.  Residue levels of fish taken from the Great Lakes
indicate that either there is a gradual loss of DDT and its metabolites
from these areas or that the DDT laden sediments are being overlaid with
fresh sedimentary deposits containing lower levels of DDT.  Similar
residue findings are noted with oysters taken from various coastal areas
where, in general, residues have declined in recent years.  There are
few direct observations of residue declines in aquatic sediments over
extended periods of time, so conclusions with regard to persistency have
largely been based on indirect measurements of residues in aquatic
organisms.  The fate of DDT in the open ocean is not at all clear and
the relative roles of sedimentation of residues into the deep abyss
versus other forms of degradation are not well defined.  The relatively
high levels of DDT associated with coastal environments compared with
the open ocean are closely associated with the increased biomass and
particulate matter load existing over the continental shelf.  The rate
of diffusion of coastal residues into the deeper oceans is currently
unknown.  Data clearly show, however, that coastal area contamination
with DDT can be expected for an extended period.
                                     -116-

-------
                       HUMAN EXPOSURE TO DDT  RESIDUES


           Administrator's Finding:  The accumulation in the food
           chain and crop residues results in human exposure.


     Aside from the effects of DDT on certain forms of wildlife and its
persistence in various environmental components, the greatest concern
over DDT has been its routine occurrence in staple human foods, especially
meat and milk.  High per capita US consumption of these commodities leads
to relatively high residues in human tissues.  Human exposure to DDT has
been a constant occurrence since its early use on various food and feed
crops.  Efforts in the last decade have led to significant reductions of
average DDT levels in all commodities including meat and dairy products.
However, low-level residues of DDT and its metabolites are still commonly
found in these commodities.  Since DDT levels in meat and dairy products
are dependent on levels in feed and forage fed to domestic ruminants, the
limiting factor in a future residue decline in humans is directly associa-
ted with these items.

Data as of 1972

     FDA data (Duggan and Corneliussen, 1972) indicate that DDT and its
metabolites are the most commonly found pesticide in market basket
samples.  The average daily intake of total DDT residues'per day in
1970 was calculated to average 0.0004 rag/kg of body weight, down from
0.0009 in 1965.

     DDT and DDE residues are routinely found in dairy products and meats.
Average levels in total diet samples were 0.047 ppm and 0.233 ppm respec-
tively for these two commodities (Corneliussen, 1972).  There is little
doubt that food ingestion represents the primary route of human exposure
in the United States (Tr:1987).  Exposure by way of drinking water, in-
halation, and dermal exposure, while not quantifiable, are not believed
to be highly significant.

Data since 1972

     The Food and Drug Administration (Corneliussen, personal .communica-
tion, 1973) evaluated pesticides in FY 1973 samples of food and compared them
with composite results for FY 1964-1969.  Their report stated that "there has
been a distinct decline in relative occurrence of DDT-related residues in all
major commodity classes except that DDE (degradation product of DDT) remained
constant in eggs and showed a slight relative increase in fluid whole milk.
This phenomenon is likely a result of the environmental burden of DDT, since
usage has been drastically limited.  Continued occurrence of the DDT
degradation products in foods of animal origin (particularly fish) is
                                    -117-

-------
reasonably expected."  Comparative analyses of baby foods (infant and junior)
for FY 1973 versus FY 1964-1969 showed a decline in positive DDT findings but
little change in DDE interceptions.  These data are:

                               % Samples Positive

                            FY 1973     FY 1964-1969

                DDE           13.8          12.7

                DDT            4.8           9.3

     Total diet residue studies involving analysis of ready-to-eat foods in 12
food class categories taken from 30 markets in 28 different cities have been
conducted by the Food and Drug Administration since 1965.  Major sources of
DDT food contamination lie in two specific categories:  dairy products and
meat, fish and poultry products.  Data for Fiscal Years 1966 through 1971 are
shown in Table IIIC.l and Figures IIIC.1-6 (Pesticide Monitoring Journal;
1(2)2-12, 1967; 1(4)11-20, 1968; 2(4)140-147, 1969: 4(3)89-105, 1970: 8(2)110-
124, 1974).  These data show that DDT and its metabolites have been dropping
gradually since 1965.  Figures IIIC.1-6 represent statistically computed best
fit plots for the raw data.

     The residue declines are undoubtedly due to numerous factors, the most
likely being increased public awareness and caution in pesticide usage, state
restrictions prior to .the 1972 Federal cancellations, and gradual phaseout of
DDT in preference to less persistent materials.

     Dietary intake values based on prorated food quantities of the various
food commodity classes (based on typical diet of a 19 year-old boy) have also
been summarized in Table IIIC.2.

     Although a gap exists in the data for FY 1971 and FY 1972, a rapid decline
in all members of the DDT family is evident, especially for DDT and TDE.  From
FY 1969 to FY 1973, respective declines of 86%, 89%, and 64% took place for DDT,
TDE, and DDE.

     A significant decline of DDT residues in poultry between 1968 and 1971 was
reported by Spaulding (1972).  Data tables for these studies follow (Stadelman,
1973):

                   DDT Residues in Poultry (ppm Fat Basis)
                           Total Samples Analyzed

                N.D.    0.01-0.1  0.1-0.5  0.5-3.0  3.0-5.0
1968
1971
1
138
406
412
1781
1062
\
465
192
13
0
                                   -118-

-------
Table IIIC.l
                               Total Diet Studies




                                  FY 1966-1971
Parts Per Billion (Fat Basis)

Dairy Products Meat, Fish and Poultry
FY DDT DDE TDK DDT DDE
1966 40 75 15 299 253
1967 53 54 19 195 172
1968 30 63 19 103 116
1969 23 48 10 101 100
1970 17 16 6 52 71
1971 trace 36 — .36 60
Sources
Pesticide Monitoring Journal 1(2):2-12, 1967.
Pesticide Monitoring Journal 1(4):11-20, 1968.
Pesticide Monitoring Journal 2(4) :140-147, 1969.
Pesticide Monitoring Journal 4 (3): 89-105, 1970.
Pesticide Monitoring Journal 8(2) : 110-124, 1974.
TDE
139
110
62
43
29
11


                                   -119-

-------
Table IIIC.2
                  Estimated Dietary Intake (micrograms/day).§/
FY
1965
1966
1967
1968
1969
1970
1971k/
197Zk/
1973£/
DDT
31
41
26
19
16
15
—
—
1.88
DDE
18
28
17
15
11
10
—
—
4.98
TDE
13
18
13
11
5
4
—
—
0.72
Sources

aj  Duggan, R.E., and P.E. Corneliussen.  Dietary intake of pesticide chemicals
    in the United States  (III) June 1968-April 1970, 1972.
b_/  Data for 1971-1972 not available.
cj  Corneliussen, P.E., Personal communication, Food and Drug Administration, 1975.

NOTE:  Less precise values were reported for the period 1965-1970  in the  first
       printing of the report.
                                      -120-

-------
                        Fig. IIIC.l
i
M
r-o
t->
I
300




270




240



210




180




150




120




90




60




30




0
                                                         DDT -*  FEAT / FISH / POULTRY
                                               FISCAL   YEAR
                                       vO
                                       vO
                                                       vO
                                                      co
                                                      \o
                                                                                     Ol
                                Source:  TPesticide  Monitoring Journal (See Table IIIC.l)

-------
                           Fig.  IIIC.2
to
NJ
I
                  300
                                                 IDE -^ ftAT  / FISH / POULTRY
                                                         FISCAL  YEAR
                         vO
                                        vo
                                        vo
oo
\o
Oi
                                                                                    CTi
                                                                                                                   ON
                                  Source:  Pesticide Monitoring Journal  (See Table IIIC.l),

-------
                          Fig. IIIC.3
ho
CO
I
300



270



240



210



180



150



120




90



60



30



0
                        CO
                         m
                         v£>
                       vO
                       vO
                       a\
                                                      DCE -» HAT / FISH / POULTRY
                                                                FISCAL  YEAR
                                                        vO
oo
so
cr>
                                                                                      vO
                                                                                      o\
                                  Source:  Pesticide Monitoring Journal (See Table IIIC.l),

-------
                         Fig.  IIIC.4
N>
-P-
I
100


90


80


70


60


50


40


30


20


10
                      GO
                      CQ
                      £4.
                      D_
                                                           DAIRY  PRODUCTS
                                                             FISCAL  YEAR
                        vo
                        ov
                                      vO
                                                                   oo
                                                                   vo
                                                                                 vO
                                                                                O
                                                                                i—
                                 Source:  Pesticide Monitoring Journal (See Table IIIC.l),

-------
                          Fig.  IIIC.5
NJ

Ul

I
100





90





80





70





60





50





40





30





20





10
                      GO


                      52
                      PQ
                       e
                       Q-
                                                  DDT-> DAIRY  PRODUCTS
                                                             FISCAL  YEAR


                                                                    00
                                                                                   ON

                                                                                   VO
                                                                                                                (Ti
                                Source:  Pesticide Monitoring  Journal (See Table IIIC.l)

-------
                       Fig.  IIIC.6
NJ
ON
I
100




90



80



70



60



50



40



30



20



10



0
                    C/5



                    OQ
                     e
                     O_
                                    vO
                                    VO
                                    ON
                                                   DDE-»DAIPY  PRODUCTS
                                                             FISCAL  YEAR
                                                                 00
                                                                 ON
                                                                 VO
                                                                 ON
O
r«.
ON
                                                                                                              ON
                              Source:   Pesticide  Monitoring Journal (See Table IIIC.l),

-------
     Similar declines were not noted between 1967 and 1973 for livestock
except for the frequencies of high-residue samples greater than 1.5 ppm.
These data along with a general discussion of the APHIS (Animal and Plant
Health Inspection Service, USDA) residue monitoring program are given by
Mussman (1975) and summarized below:


                  DDT Residues in Livestock (ppm Fat Basis)

                                  Percent of Samples

                            N.D.   0.01-1.5 •  1.5-3.0   3.0

                    1967    23.3    72.8        2.2     1.5

                    1973    26.1    72.7        0.6     0.6

     A review of similar data from USDA, APHIS for calendar years 1972-1974
(Conrey, 1975) does not reveal additional trends for poultry or any other
meat product.  However, it must be remembered that many residue problems are
identified and dealt with in various manners prior to a product's entering
into interstate trade channels.  A summary of 1972-1974 data is given in
Table IIIC.3.

     The USDA, APHIS conducted a special monitoring program exposing domestic
ruminants to 1974 Tussock Moth spray residues and monitoring for DDT residues.
The animals were grazing in and around the immediate understory of treated
forests.  However, sincere efforts were made not to treat open pasture land
within the forest complex.  A significant number of animals developed illegal
residues and were quarantined to allow residue decline to occur.  Young
calves were released from quarantine on April 1, 1975 whereas older cows hav-
ing a greater body pool of adipose tissue were not released until June 1,
1975, or later.  Data available to date involve objective phase analyses of
358 samples entering interstate commerce.  Only two of these samples were
found to contain levels of DDT above the current tolerance.  The total number
of animals being held back for later slaughter is unknown (Spaulding, 1975).

     Withdrawal of DDT use in Arizona agriculture in 1968 resulted in a drop
in total DDT residue in green alfalfa from an average of 404 ppb in 1967 to
45 ppb in 1970.  Residues in beef fat during the same period dropped from
0.97 to 0.49 ppm (Ware et al, 1971).  Ware et al (1974) in a recent update
of this work found still lower levels corresponding to about 30 ppb of DDT
residues in alfalfa.  Statistical analysis of data for the sampling dates
between 1969 and 1972 showed that in three of four areas sampled, levels of
total DDT in green alfalfa have stabilized at about 0.03 ppm.

     Data on the decline of fish residues from samples taken in the Great
Lakes have been reported elsewhere in this document.  In summary, precipitous
                                  -127-

-------
Table IIIC.3
                    DDT Residues in Domestic Animals From Nationwide Meat and
                                   Poultry Inspection Programs
Species
Cattle
1972
1973
1974
Calves
1972
1973
1974
Horses
1973
1974
Swine
1972
1973
1974
Turkeys
1972
1973
1974
Chickens
1972
1973
1974
Lambs
1972
1974
No. Samples
202
710
1010

11
84
282
44
266
129
232
329

206
517
734
357
531
1034
130
99
Violations
0
0
1

0
0
1
1
0
0
0
a

0
0
i
0
0
0
0
1
Warnings
0
0
0

0
1
0
0
0
0
Q
0

0
0
0
0
0
0
0
0
None
Detected CO
59 (29)
132 (18)
165 (16)

5 (45)
3 (3)
8 (2)
20 (45)
53 (19)
64 (49)
118 (50)
84 (25)

39 U8)
58 (ID
75 ao)
50 (14)
89 (16)
66 (6)
42 (32)
24 (24)
ppm Total DDT (Fat)
0.01-0.3*(%)
135 (66)
464 (65)
755 (74)

6 (54)
73 (86)
245 (86)
18 (40)
176 (66)
58 (44)
101 (43)
229 (69)

155 (75)
374 (72)
610 (83)
291 (81)
393 (74)
925 (89)
83 (63)
58 (58)
0.31-1.0**(%)
8 (3)
95 (13)
74 (7)

0
4 (4)
23 (8)
3 (6)
25 (9)
6 (4)
8 (25)
15 (4)

10 (4)
70 (13)
46 (6)
14 (.3)
46 (8)
38 (3)
4 '(3)
7 (7)
1.0 (%)
0
19 (2)
16 (1)

0
4 (4)
6 (2)
3 (6)
12 (4)
1 (0.7)
5 (0.2)
1 (0.3)

2 (0.4)
15 (2)
3 (0.5)
2 (0.5)
3 (0.5)
5 (0.4)
1 (0.7)
10 (10)
 *.01-0.5 (1972)
**0.51-1.0 (1972)

Source:  Conrey, personal communication, 1975.
                                                     -128-

-------
declines were noted with average residues in coho salmon (Oncovhynohus
kisutch) declining from 11.8 ppm in 1968 to 4.48 ppm in 1973 (Reinert,
1975).  An evaluation of fish residue data in ocean fish from a recent
NOAA survey (Stout, 1975) for fish off the Pacific Coast showed a res-
idue trend which generally declined with the northward progression of
sampling from California to Oregon.  In general, the residues were well
within the current action limit except for samples taken off the coast
of Southern California.

     Butler (1973) described the results of a national program for mon-
itoring estuarine molluscs in 15 coastal states for the period 1965-1972.
"For most estuaries monitored, detectable DDT residues have declined in
both number and magnitude in several species of estuarine molluscs in
recent years.  DDT pollution in many estuaries as judged by the magnitude
of the residue in molluscs, peaked in 1958 and has been declining markedly
since 1970."

     The North Carolina Agricultural Experiment Station (1974) and Sheets
(1973) found significant reductions in DDT and TDK levels in flue-cured
tobacco between 1968 and 1972.  These decreases are shown in Tables IIIC.4
and IIIC.5.  In 1970, a decrease in use of DDT for tobacco occurred and
since 1970, a certification that DDT and TDE would not be used has been
necessary for tobacco producers to obtain price support.  When reviewing
these data, it should be remembered that a 2-year period normally occurs
between time of tobacco planting and final sale of cured product at auc-
tion.

     Domanski, Haire, and Sheets (1975) proposed that the low levels of
DDT found in recent samples (1972) of auction market tobacco resulted pri-
marily from existing environmental contamination rather than direct appli-
cation.  Recent experiments by the North Carolina Agricultural Experiment
Station (1974) confirmed that tobacco produced with currently recommended
cultural procedures will in general have residue levels similar to the
1972 survey of US auction market tobacco.

     Residue levels found in the lower stalk portion correlated linearly
with those in the soil and were in agreement with recent radiochemical
DDT-uptake studies conducted by Rosa and Cheng (1974).  Drift of airborne
soil containing DDT was considered to be a possible contaminant source,
especially for upper tobacco leaves.

     Domanski and Guthrie (1974) reporting on residues of DDT in cigars
found little difference in the residue levels between the years 1969, 1971,
and 1972.  However, Sheets (1974) found a decrease from 15.6 ppm in 1971 to
10.5 ppm in 1973.

     Due to the variable time lag between harvest and marketing of finished
tobacco products, it may take 5 years or more for the decline in DDT and
TDE to manifest itself fully in such products.
                                   -129-

-------
Table IIIC.4
        Frequency Distribution of DDT and TDE in Flue-Cured Tobacco
                                US Market
Concentration
Range (ppm)
0.0-0.099
0.1-0.49
0.5-0.99
1.0-2.99
3.0-9.99
> 10.0
1968
0
0
0
0
1.2
98.8
Samples within Range
%
1970
0
11.6
27.7
31.3
15.2
14.3
1972
0.9
63.9
15.7
12.0
7.4
0
Source:  North Carolina Agricultural Experiment Station,  1974.
                                  -130-

-------
Table IIIC.5
  Average DDT and TDE Residues in Flue-Cured Tobacco from the Auction Market
                               US, All Belts
Year
1968
1970
1972
1973*
• • jit-
Average Cone .
(ppm)
53.0
5.9
0.85
0.21
*Additional information from limited survey.

Source:  Sheets,  1973.
                                    -131-

-------
Conclusion

     Between 1965 and 1970, levels of DDT and DDE in the two commodity
groups, dairy and meat, fish and poultry, gradually decreased.   Then,
between 1970 and 1973 a precipitous drop occurred in residues of DDT
and TDE with respective decreases of 86% and 89%.  DDE on the other
hand decreased only 27%.  In FY 1973, these two commodity groups repre-
sented more than 95% of the total body burden of ingested total DDT
residue with dairy products- contributing about 30% of this amount.

     Based on domestic ruminant monitoring data since 1972, no signifi-
cant change has occurred in the residue profile through 1974.  If cur-
rent levels of DDT exposure to domestic ruminants are caused by inges-
tion of food and feed produced from soil having past, but no current
exposure, to DDT, diminution of these levels cannot be expected to occur
in the near future.

     DDT residues in agricultural commodities other than dairy products
and meat, fish, and poultry do not currently pose a significant problem
with regard to direct human intake.
                                  -132-

-------
                         HUMAN STORAGE AND DDT RESIDUES
          Administrator's Finding:  Human beings store DDT.
     DDT and its metabolites, DDE and TDE, are highly soluble  in fatty sub-
stances.  Thus, when humans are exposed to residues of DDT in food, a cer-
tain portion will be retained and stored in the body fat.  The major source
of this DDT is dairy and meat products ingested as part of the total diet.
The source of this DDT in food is our nation's agricultural soils.  Small
quantities are taken up by plant materials.  Thus, the simple food chain
(soil ->• plant -> domestic ruminant ->• human) accounts for most of DDT found
in human tissues.

Data as of 1972

     Adipose tissue data from the National Human Monitoring Programs (Yobs,
1971) yielded mean levels of total DDT, including metabolites, in the gen-
eral population of 6.26 ppm in 1968 and 5.97 ppm in 1970.  Significant dif-
ferences were noted between black and white populations (TR:1984).  Blood
serum levels of DDT varied significantly with the socioeconomic background
of the subject and "lowest values are found in the more affluent groups,
and higher values in poor" (TR:2022).

     Analysis of DDT in the human food chain using a system modeling approach
was done by O'Neill and Burke (1972) for the DDT Advisory Committee.  This
approach revealed that a reduction of DDT levels in human fat to 25% of that
existing at the time of cancellation of all DDT uses would take approximately
28 years.

Data since 1972

     A comparison of 1970 thru 1972 National Human Monitoring data has been
prepared by Kutz, Yobs, and Strassman (1974) and Kutz (1975)  and is shown below.
The geometric mean of DDT in human adipose tissue declined from 7.95 ppm in
1971 to 5.89 ppm in 1973, which may signal a downward trend.  Since 1970, the
percent of DDT residues found as DDE increased slightly (from 77.15% to 81.19%)
Detailed analyses of FY 1970 data were described by Kutz et al (1974).
                                    -133-

-------
1,412
99.3%
7 . 87 ppm
77.15%
1,616
99.75%
7.95 ppm
79.71%
1,916
99.95%
6 . 88 ppm
80.33%
1,092
100.00%
5.89 ppm
81.19%
                  National Summary of Total DDT Equivalent
                      Residues in Human Adipose Tissue

                        (total US population basis)

                            FY 1970     FY 1971     FY 1972     FY 1973

Sample size

Frequency

Geometric mean

Percent DDT found as DDE

Total DDT equivalent = (o,p'-DDT + p,p'-DDT)

                       + 1.114 (o,p'-DDD + p,p'-DDD +

                       p,p'-DDE + o,p'-DDE)
     As part of an epidemiological study, Griffith (1975) monitored serum
levels of p,p'-DDT, o,p'-DDT, p,p'-DDE and o,p'-DDE in a cohort of 382 ex-
posed human subjects during 1971, 1972, and 1973.  The data (Figure IIIC.7)
clearly show that p,p'-DDT serum residue levels have decreased over the 3-
year period 1971-1973 suggesting diminished exposure to DDT.

     Residues of p,p'-DDE, on the other hand, do not show such a pronounced
downward trend (Figure IIIC.8).  It has been suggested by a number of in-
vestigators that serum p,p'-DDT levels reflect recent exposure to DDT, while
p,p'-DDE levels seem to correlate well with long-term exposure and the stor-
age capacity of the human body (Keil et al, 1972; Edmundson, 1970: Morgan,
1971 and Selby, 1968).

Conclusion

     DDT residues in human adipose tissue have tended to decline in recent
years (1971 to 1973), while the percent of DDT stored as DDE has moved up
only slightly.
                                 -134--

-------
Ul
I
_, . __..-_ — ijJ. J.lSJUilM..L.VSJU\SV7 J-V^fVJU tJ-JLUJL/ J.UhJ i JML/UIVtt,
gt iiu"' X Serum Residues of p,p'-DDT
1971-1973
13.0

12.0 ._
_
11.0 _
10.0 _

9.0-
o_
vS 8.0 _
UJ -
5 7.0 -
e f\
v//
£~ £ f\
g 6.0 —
UJ
oo
|: 5.0 ..
"o.
cC 4.0 _
3.0 -
2.0._
1971 Exposed - 382
Exposed Control - 129





































1972
Exposed






Control
























1973
Exposed




Control























Control














                       Source:  EPA, Office of Pesticide Programs, Human Effects and Monitoring Branch

                                 Feb 1975.

-------
         Fig. IIIC.8
£
Q.
Q
oo
 Q-
 (X
50.0_


45.0


40.0_


35.0,


30.0-


25.0


20.0


15.0


10.0_


 5.0_
                       EPID^tEOLOGIC STUDIES PROGRAM
                        X Serum Residues of p,p'-DDE
                                 1971-1973
                                Exposed - 382
                                Control - 129
                              1971
                                                       1972
                      Exposed
Exposed
                                   Control
                                                                                1973
                                                                        Exposed
                                                            Control
                                                                                   Control
                Source:  EPA, Office of Pesticide Programs, Human Effects and Monitoring Branch,
                           Feb 1975.

-------
                                 REFERENCES
Addison, R.F., M.E. Zinck, and R.G. Ackman.  Residues of organochlorine
  pesticides and polychlorinated biphenyls in some commercially produced
  Canadian marine oils.  J. Fish. Res. Board Can. 29:349-355, 1972.

Ahr, W.M.  Long-lived pollutants in sediments from the Laguna Atascosa
  National Wildlife Refuge, Texas.  Geol. Soc. Am. Bull. 84(8):2511-2515,
  1973.

Albone, E.S., G. Eglinton, N.C. Evans, J.M. Hunter, and M.M.  Rheod.   Fate
  of DDT in Severn estuary sediments.  Environ. Sci. Technol. 6(10):914-
  919, 1972a.

Albone, E.S., G. Eglinton, N.C. Evans, and M.M. Rheod.  Formation of bis
  (p-chlorophenyl)-acetonitrile (p,p'-DDCN) from p,p'-DDT in anaerobic
  sewage sludge.  Nature  240(5381):420-421, 1972.

Bandy, L.W.  The bioaccumulation and translocation of ring-labelled  chlo-
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Beitz, H., and E. Heinisch.  Contamination of meadows, pastures,
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Beyermann, K., and W. Eckrich.  Gas chromatographic determination of insec-
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Bjerk, J.E.  Residues of DDT and PCB in Norwegian sprat (Clupea sprattus)
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Bjerk, J.E.  Residues of DDT in cod from Norwegian fjords.  Bull. Environ.
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Bradley, J.R., T.J. Sheets, and M.D. Jackson.  DDT and toxaphene movement
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Butler, P.A.  Residues in fish, wildlife and estuaries.  Pestic. Monit. J.
  6(4):238-362, 1973.
                                   -137-

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Carey, A.  Personal communication, 1975.

Carr, R.L., C.E. Finstenwolder, and M.J. Schibi.  Chemical residues in
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Chisholm, D.,  and A.W. Machphee.  Persistence and effects of some
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Claeys, R.R.,  R.S. Caldwell, and N. Cutshall.  Chlorinated pesticides
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Cliath, M.M.,  and W.F. Spencer.  Dissipation of pesticides from soil by
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Collyard, K.J., R.E. Johnsen, and C. Lin.  Influence of soil amendments
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Conrey, A.  Personal communication, Animal Plant Health Inspection Service,
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Corneliussen,  P.E.  Personal communication, Federal Drug Administration,
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Craig, P., H.  Johnson, and G. M. Woodwell.  DDT in British rain.  Science
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Domanski, J.J., and F.E. Guthrie.  Pesticide residues in 1972  cigars.  Bull.
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Domanski, J.J., P.L. Haire, and T.J. Sheets.  Residues on 1972 US Auction
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Duggan, R.E.,  and P.E. Corneliussen.  Dietary intake of pesticide chemicals
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                                    -138-

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EDF-16   Risebrough, R.S., R.J. Huggett, J.J.  Griffin,  and E.D.  Goldberg.
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EDF-20   Panel on Monitoring Persistent Pesticides in the Marine Environment.
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Edmundson, W.F., J.E. Davies, and M. Cranmer.   DDT and  DDE in blood and DDA
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Edwards, V.G.  DDT in British rain.  Science 179(4077):956, 1973.

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Georgii, H.W.  DDT in the biosphere.  Hippokrates 44(1) ;98-100,  1973.

Giam, C.S., A. Hanks, R.L. Richardson, W. Sackett, and  M.K. Wong.  DDT, DDE
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Griffith, J.  Personal communication, Human Effects Monitoring Branch, Office
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Harris, C.R., and J.R.W. Miles.  Organochlorine insecticide residues in
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                                  -139-

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Jensen, S. , R. Gothe, and M.O. Kindstedt.   Bis-(p-chlorophenyl)-acetonitrile
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Keil, E.J., W. Weston, C. Loadholt,  S. Sandifer, and J. Colcolough.  DDT and
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Kerner, I., W. Klein, and F. Korte.   Photochemical reactions of l,l-dichloro-2,2-
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Klassen, H.E., and A. Kadoum.  Pesticide residues in natural fish populations
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Konstantinov, O.K., and N.N. Gorchakovskaya.  Level of DDT residues in the
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Kramer, R.E., and F.W. Plapp, Jr.  DDT residues in fish from the Brazos River
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Ruhr, R., A. Davis, and E.F. Taschenberg.   DDT residues in a vineyard soil
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Kutz, F.W., A.R. Yobs, and S.C. Strassman.  A national survey for organo-
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Kutz, F.W., A.R. Yobs, W.G. Johnson, and G.B. Wiersma.  Pesticide residues
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Kutz, F.W.  Personal communication,  1975.

Kvalvag, J., and J. Stevenson.  Residues of DDT and its degradation products
  in cod liver from Norwegian fjords.  Bull. Environ. Contam. Toxicol. 8(2):
  120-121, 1972.
                                   -140-

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Law, L., and D.F. Goerlitz.  Selected chlorinated hydrocarbons in bottom
  material from streams tributary to San Francisco Bay.  Pestic.  Monit.  J.
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Leland, H., W.N. Bruce, and N. Shimp.  Chlorinated hydrocarbon insecticides
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Lenon, H., L. Curry, A. Miller, and D. Patulski.  Insecticide residues in
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Lloyd-Jones, C.P., D.P. Seba, and J.M. Prospero.  Pesticides in the lower
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MacGregor, J.S.  Changes in the amount and proportions of DDT and its
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Maugh, T.H.  DDT.  Unrecognized source of polychlorinated biphenyls.
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Metcalf, R.L.  DDT substitutes.  Grit. Rev. Environ. Control 3(l):25-59,
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Metcalf, R.L.  Model ecosystem for the evaluation of pesticide biodegrad-
  ability and ecological magnification.  Outlook Agric. 7:55-59,  1972.

Miller, L.L., R. Nakang, and G.D. Nordblom.  Sensitized photolysis of DDT
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Moilanen, K.W., and D.G. Crosley.  Paper presented at the 165th National
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Morgan, D., and C. Roan.  Absorption, storage and metabolic conversion of
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Mussman, H.C.  Drug and chemical residues in domestic animals.  Fed. Proc.
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North Carolina Agricultural Experiment Station.  An Annual Report of Ac-
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North Carolina Agricultural Experiment Station.  Fate of Pesticide Residues
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  State University, January 9, 1974.
                                    -141-

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Oertzen, J.  Marine pollution - A problem of marine biology.  Biol. Rundsch.
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O'Neill, R.V., and O.W. Burke.  A simple systems model for DDT and DDE move-
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Patil, K.C., F. Matsumura, and G.M. Boush.  Metabolic transformation of DDT,
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Pfaender, F.K., and M.  Alexander.  Extensive microbial degradation of DDT in
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Plimmer, J.R., and U.I. Klingebiel.  PCB formation.  Science 181(4104):
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Plimmer, J.R., U.I. Klingebiel, and B.E. Hummer.  Photooxidation of DDT and
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Poirrier, M.A., B.R. Bordelon, and J.L. Loseter.  1972.  Adsorption and
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Prospero, J.M., and D.B. Seba.  Additional measurements of pesticides in
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                                    -142-

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                                    -143-

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Yobs, A.R.  Presented at Public Hearings on DDT. Transcript.  Office of  the
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                                     -145-

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                                INTRODUCTION
          Administrator's Findings:  1) The use of DDT is not neces-
          sary for production of cotton, beans, peanuts, cabbage,
          cauliflower, brussels sprouts, tomatoes, fresh market corn,
          pimentos •, garlic, and commercial greenhouse plants but may
          be necessary to protect sweet potatoes in storage, sweet
          peppers against heavy corn borer infestations (in the Del-
          marva Peninsula only), and onions during an interim cancel-
          lation period.  2) Noncrop uses of DDT for moth proofing
          and to control bats and mice are proprietary uses for
          which DDT is not necessary.
     These are the Administrator's Ultimate Findings in Part V of his decision,
Benefits.  These ultimate findings on benefits were based on 12 Basic Findings
which generally relate to economic matters.  In view of these findings by the
Administrator and the more recent regulatory actions involving emergency re-
quests to use DDT against the tobacco budworm on cotton, the tussock moth and
the pea leaf weevil, the following crop use patterns were reviewed for this
report:

     1.  Cotton
                                f)  tomatoes
                                g)  garlic
                                h)  lettuce
                                i)  potatoes
                                j)  dry beans
k)  lima beans
1)  snap beans
m)  sweet potatoes
n)  sweet peppers
o)  onions
2.  Other crop uses

    a)  sweet corn
    b)  peanuts
    c)  cabbage
    d)  cauliflower
    e)  brussels sprouts

3.  Military uses

4.  Public Health use
     5.  Forest use

     Information available to the Administrator in 1972 was found in the testi-
monies of the DDT Hearing Record.  Current information since the cancellation
was located in a variety of sources.

     Commodity specialists in the disciplines of agronomy, entomology, and eco-
nomics were contacted in the USDA and the Land Grant Universities.  Data
sources, both public and private, were referred to and include USDA publica-
tions, Experiment Station and Extension bulletins, Tariff Commission Reports,
EPA-contracted research projects, and others.
                                    -147-

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                           DDT PRODUCTION AND USE
     In the early 1950's thirteen companies were involved in the manu-
facturing of DDT.  Among the last firms to cease producing DDT were:
Geigy Corporation (1966), Allied Chemical (1969), Olin Corporation
(1969), Diamond Shamrock Corporation (1970), and Lebanon Chemicals
(1971).

     Domestic production reached a maximum of about 188 million pounds
in 1963.  By the late 1960's DDT output had declined by about one-
third, e.g., 123 million pounds in 1969.  Then production declined
precipitously, to an estimated 60 million pounds per year in the
early 1970's (Table IIID.l).

     Domestic use peaked at near 79 million pounds in 1959, and de-
clined to about 18 million pounds in 1971 (22 million pounds in 1972).
More recent estimates of use are not available.

     Export lagged behind domestic consumption up to 1958, and the
maximum did not occur until 1963.  From 1958 onward, the quantity of
DDT exported continued to exceed domestic consumption.
                                    -148-

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Table IIID.l
           Domestic Production, Consumption, and Exports of DDT in
                  the United States, 1950-1972 (100% basis)
Year                Production        Domestic Consumption      Exports
                                          (1,000 Ibs)
1950
1951
1952
1953
1954
1955
1956
1957
1958
1959
1960
1961
1962
1963
1964
1965
1966
1967
1968
1969
1970
1971
1972
a/ EPA
67,320
97,875
115,717
72,802
90,712
110,550
137,747
129,730
131,862
156,150
160,007
175,657
162,633
187,782
135,749
140,785
141,349
103,411
139,401
123,103
59,316
63,134£/
57,427£/
estimates based on Pesticide Review
57,638
72,686
70,074
62,500
45,117
61,800
75,000
71,000
66,700
78,682
70,146
64,068
67,245
61,165
50,542
52,986
46,672
40,257
32,753
30,256
25,457
18,000*'
22,000£/
1973, pp. 10, 11,
7,898
NA
32,288
31,410
42,743
50,968
54,821
61,069
69,523
76,369
86,611
103,696
106,940
113,757
77,178
90,414
90,914
81,828
109,148
82,078
69,550
45,134
35,424
22, 23.
Source:  USDA, ASCS. Pesticide Review 1973 and earlier years.
                                    -149-

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                                   COTTON
     The major areas covered in this review are:  the availability of
alternative pest controls, chemical and nonchemical;  impact of the can-
cellation on cotton production costs (1971-1972 average compared to 1973-
1974 average) ; and impact of changes in cotton production costs on
acreage, production, and prices of cotton and other crops in the US, by
region, based on a representative year since cancellation.  This latter
analysis presents results in terms of the year 1975.  Throughout the
analysis, only cost impact is considered, as inadequate data were
available to systematically evaluate possible impact of alternatives upon
cotton yields throughout the areas where DDT was used.i'

     Before presenting results of the review, a brief summary of relevant
background information is presented on the cotton industry.
\J  Additional research is currently in progress in the Office of Pesticides,
EPA, in cooperation with cotton specialists in the states addressing yield as
well as cost impact in detail.  Basic data on the entomology and economics of
alternative cotton producing programs, including those with DDT, are now be-
ing received from the states but analysis will not be completed until well
into FY 1976.   Data are being obtained for 57 individual cotton growing regions,
which will be utilized in an analysis of impact of yield and cost effects of
the availability of DDT and other pest management options on the performance
of the cotton and other sectors of agriculture (e.g., acreage, production,
and price of cotton and other major agricultural crops).

     As part of the cotton pest management study, states were requested to
provide information on cotton yield differentials associated with alternative
control techniques, including the use of DDT.  As of July 1975, eight of the
14 states contacted have responded.  This data is therefore incomplete at this
time and the summary statements below provide tentative conclusions only.

     In the Southeast, the two states responding indicate that growers would
use DDT on cotton pests, principally for control of the tobacco budworm, boll-
worm, and the boll weevil, but yields would not change.  Three western states
expect very little DDT would be used if available.  One state indicated cotton
and alfalfa are frequently grown in adjacent fields and DDT would cause residue
problems in the alfalfa.  Yield improvements would not be expected except in
the case of bollworm control.  Three states in the Delta region have responded
and two provide specific numerical information on yield improvements if DDT
were available.  Estimates of yield increases range from 3% to 14%, depending
upon specific regional area.  One Delta state does not expect any change in
yields.

     The yield information is obtained from the professional judgement of ento-
mologists knowledgeable on the prevailing growing conditions in their respec-
tive regions and is based on actual field experience, experimental data, labor-
atory tests and other accumulated experience.
                                    -150-

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OVERVIEW OF THE COTTON ECONOMY
     Cotton is one of our most important agricultural crops.  It contributes
$3 to $4 billion to cash receipts of farmers and is grown commercially on
about 125,000 farms in the United States.1.' As many as one-fourth of these
farms have less than 25 acres of cotton.  The major cotton production regions
of the US are shown in Figure IIID.l.

     The cotton industry is one of the most intensive users of insecticides.
As of 1971, nearly one-half the total insecticides used in agriculture were
for protection of cotton.  About two-thirds of the cotton acreage in the US
is treated with insecticides.  DDT was a major insecticide used in the cotton
industry through 1972.  Additional background on the use of DDT and other in-
secticides, as well as other aspects of the cotton economy, are discussed be-
low (based on recent USDA evaluations, USDA, ERS, Cotton Situation, 1975 and
other sources as cited).

     The economic success of the cotton farmer is affected from year to year
much more heavily by a number of other factors than by changes in regulatory
policy on pesticides.  Factors such as weather, government acreage allotment
and price support programs, the market price of cotton, competition from
other crops, limited input supplies, and costs of other inputs often have a
major impact on cotton production costs and returns.  Average total costs of
producing an acre of harvested upland cotton in the US were estimated to be
$254.63 in 1974, of which insecticides accounted for only $9.64 or about 3.8%
(Table HID.2) (Starbird et al, 1975).I/ Since 1972, the total costs of pro-
ducing upland cotton have increased from $193.48 to $254.63 (by $61.15 or
about 32%).  According to these USDA estimates, increasing costs of insecti-
cides constituted a very minor part of the overall increase in cotton produc-
tion costs (from $7.74 to $9.64 per acre or by $1.90) (Table IIID.2).  This
is not to say that insecticide cost increases have been so nominal in all
areas or that insecticides are unimportant factors contributing to cotton
yields.

     Costs of growing cotton varied significantly among the US cotton produc-
ing regions.  In 1972, the latest year for which costs by region are available
from USDA, total costs per harvested acre varied from $95.49 to over $500 per
acre (Table HID. 3) (Starbird et al, 1972).  Insecticide costs per acre also
varied greatly.  The regions with heaviest insecticide costs as of 1972 were:
\J  There were estimates of as many as 150,000 farms with cotton allotments
for the year 1972 (USDA estimate, based on ASCS & ERS data sources).  How-
ever, as of 1974 the number of farms growing cotton on a commercial basis is
about 125,000 (based on market research reports available to EPA).
2_/  These preliminary USDA 1974 estimates of costs for insecticides are sub-
stantially lower than those presented later in this report, based on another
data source.  They are utilized here for purposes of indicating the importance
of insecticides in the overall cost of growing cotton, as estimated by USDA.

                                     -151-

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Ul
ro
I
               Figure  IIID.l
                                                    PRODUCTION   REGIONS  FOR  COTTON
                                                                                                                                              1
                                                                                                                                            SOUTHEAST
                      I SO. PIEDMONT
                      2 E. COASTAL PLAINS
                      3 SO. COASTAL PLAINS
                      4 LIMESTONE VALLEY- SAND MTN.
                      5 CLAY HILLS
                      6 BLACK BELT
                      7 BROWN LOAM
                     SOUTH CENTRAL -
                      1 MISSISSIPPI DELTA
                      2 N.E. ARKANSAS
                      3 BLACK PRAIRIE
SOUTH CENTRAL-

 4 COASTAL PRAIRIE
 5 LOWER RIO GRANDE VALLEY
 6 ROLLING PLAINS
 7 HIGH PLAINS
WEST-
 I SAN JOAOUIN VALLEY
 2 SO. CALIFORNIA AND S.W. ARIZONA
 3 CENTRAL ARIZONA
 4 HIGH SOUTHERN DESERT
 S UPPER RIO GRANDE. PECOS VALLEYS
 6 TRANS PECOS
           Source:    Starbird,  I.R.,  and B.L.  French.   Costs  of  Producing Upland  Cotton in the  United States,  1969.
                           1972.

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Table HID.2
           Production Costs per Acre of Upland Cotton Harvested,
                United States, Selected Years, 1964-1974
Average Cost per
Item
Labor
Power & Equipment
Materials
Seed
Fertilizer
Herbicides
Insecticides
Defoliants
Other Chemicals
Total Materials
Ginning, Bagging
& Ties
Custom Services
Irrigation
Interest on
Operating Capital
Total Direct Costs
Land
General Overhead
Total Cost per Acre
Harvested^./
1964
42.40
34.04

3.26
11.44
1.59
5.69
1.00
0.30
23.26
19.11

7.74
8.37

2.49
137.46
24.49
18.74

180.69
1966
27.83
37.28

3.56
12.67
3.72
6.42
1.00
0.25
27.62
19.82

8.90
9.19

2.29
132.94
24.44
13.99

171.38
1969
21.97
42.46

4.20
10.90
4.56
6.79
1.17
0.20
27.83
18.44

9.91
7.86

2.72
131.18
23.11
13.64

167.93
Acre Harvested
1972
23.33
43.50

4.40
10.96
6.18
7.74
1.48
0.52
31.28
23.54

11.28
11.12

2.79
146.83
34.15
12.49

193.48
1974^7
27.49
56.90

7.59
17.56
7.70
9.64
1.85
0.65
44.99
25.28

14.39
13.71

4.75
187.51
51.32
15.80

254.63
a/ Totals do not necessarily add because of rounding.
b/ Preliminary.

Sources

Starbird, I.R., et al.  Costs of Producing Upland Cotton arid Selected Crops
  on Cotton Farms in the United States, 1972, 1975.
Starbird, I.R.  Costs of Producing Upland Cotton iri the US — Procedures,
  Results, and Implications, 1974.
                                     -153-

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       Table HID.3
                              Average Total Production Costs and Insecticide Costs per
                                 Acre for Upland Cotton, US by Region, 1969 and 1972
I
M
Ul

I


1969


Insecticides
Regions
Southern Piedmont
Eastern Coastal Plain
Southern Coastal Plain
Limestone Valley-Sand Mountain
Clay Hills
Black Belt
Brown Loam
Mississippi Delta
Northeast Arkansas
Black Prairie
Coastal Prairie
Lower Rio Grande Valley
Rolling Plains
High Plains
San Jaoquin Valley
California & S. Arizona
Central Arizona
High Southern Desert
Upper Rio Grande-Pecos Valleys
Trans Pecos
United States
Total
Cost
(dollars)
179.61
214.17
202.60
165.49
184.23
176.92
178.57
185.98
165,33
76.84
109.57
183.90
89.21
126.00
313.65
414.94
389.32
330.64
252.02
333.92
167.93
Cost
(dollars)
11.51
18.22
16.19
8.06
6.74
12.40
4.78
10.92
2.41
2.40
3.27
11.10
1.26
0.53
10.92
35.99
21.81
3.01
3.38
14.39
6.79
Percent of
Total
(percent)
6.41
8.51
7.99
4.87
3.66
7.01
2.68
5.87
1.46
3.12
2.98
6.04
1.41
0.42
' 3.48
8.67
5.60
0.91
1.34
4.31
4.04
Total
Cost
(dollars)
NA
230.57
226.40
218.46
189.70
NA
196.21
210.11
179.33
95.49
160.15
199.19
103.77
150.94
371.95
487.73
503.13
NA
332.98
NA
193.48
1972

Insecticides
Cost
(dollars)
NA
24.41
31.96
15.86
8.51
NA
3.21
10.31
3.39
3.68
11.43
17.58
0.61
0.72
9.55
38.32
31.12
NA
2.42
NA
7.74
Percent of
Total
(percent)
NA
10.59
14.12
7.26
4.49
NA
1.64
4.91
1.89
3.85
7.14
8.83
0.59
0.48
2.57
7.86
•6.19
NA
0.73
NA
4.00
       Sources


       Starbird,  I.R.  and  B.C. French.  Costs of Growing Cotton in the United States. 1969. 1972.
       Starbird,  I.R.  et al.  Costs of Producing Cotton and Selected Crops on Cotton Farms in
         the United  States. 1972. 1975.

-------
Southern Piedmont, the Eastern Coastal Plain, Coastal Prairie, Lower Rio
Grande Valley, and Southern California/Southwest Arizona.  In these regions
the costs of insecticides ranged up to 14% of total production costs com-
pared with a national average of 4.0% in 1972;  Later in this analysis ad-
ditional cost data are presented for insecticides by chemical for purposes
of estimating the cost impact of the DDT Decision on the average during
1973 and 1974 in comparison with the 1971-1972 average.

     Competition from man-made fibers and declining demand, due to the un-
favorable general economic conditions in the US and world markets during the
last year have had significant impact on cotton prices (Figure HID.2).
Cotton prices received by farmers have declined sharply from the high of
near $0.60 per pound which occurred about a year ago.  The high market
prices for cotton during the 1972-1973 and early 1973-1974 seasons generated
very large plantings in 1974 (nearly 14 million acres compared with an
average of 12.95 million acres for 1970-1974).

     Although bad weather battered cotton producers all season long in 1974,
particularly in the Southeastern and Delta areas, thus reducing yields, the
1974 crop totaled 11.7 million bales.  In the face of declining demand, the
crop precipitated dramatic price decreases.  For example, the February price
received by farmers in 1975 was only $0.32 per pound compared with $0.52 per
pound in February 1974.

     Improvement in the national market situation in cotton depends upon
recovery of the economy and reduction in production in 1975, to
adjust to needs in the domestic and export markets.  The latter is expected
to happen as prospective planting in 1975 is 9.5 million acres, down 22%
from 1974, to the lowest level in many years.

     The cotton commodity market in which one can contract for delivery at
specified prices has been a disconcerting factor for the cotton farmer during
the last 2 years.  In 1974, 20% of the cotton crop was contracted compared
with 75% in 1973 and only 15% in 1972.  In 1973, farmers received attractive
prices for cotton.  Cotton was contracted at prices acceptable to farmers,
and the $0.15 price support was in effect.  However, cotton prices continued
to increase throughout the 1973 season, and holders of the contracts were
the beneficiaries, not necessarily the farmers.  Farmers' anticipation of
windfall gains in 1974 appear to have resulted in only 20% of the crop being
sold under contract at future prices.  However, since cash prices in 1974
were declining and farmers had not protected themselves by contracting at
higher prices, 80% of the crop was on the open market at current lower cash
prices.

     The Federal Government's cotton program is a very significant factor
affecting the cotton producer.  The Agricultural Act of 1973 represented an
important change in US agricultural policy.  This Act reflects a trend away
from government controls and guarantees to a more open market-oriented
philosophy.  Under free-market agricultural policies, farm markets tend to
become more unstable.  Annual prices can fluctuate, subjecting farmers to
"shocks" in income.
                                   -155-

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Figure HID.2
                     U.S.  COTTON  PRICES
    <: PER LB.'


    80


    60


    40


    20

     Spot market SLM 1-1/16"
Spot market SLM 1" /,
                         Price received by farmers
        1969/70  70/71    71/72    72/73   73/74   74/75
                       YEAR BEGINNING AUGUST 1
                            + /Vf T WEIGHT, MID-MONTH.
  USDA
                                                      MEG. ERS 8648 -74 (11)
                              -156-

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     The Agricultural Act of 1973 first went into effect in the 1974 growing
season, including new cotton allotment provisions.  One important feature
was the target price concept to replace the $0.15/lb lint price payment.
Farmers would no longer automatically receive a price supplement.  Instead,
a target farm price floor was set for their crop.  As long as the market
price of cotton equals or exceeds the target price, no payment is made.
Farmers receive per pound payment when cotton prices at the farm level fall
below the target price, which for cotton was set at $0.38/lb lint.  The farm
price of cotton exceeded this level, and no payments were made to farmers
for the 1974 crop.

     The disaster provision of the law gives some income protection in the
event of crop loss due to a natural catastrophe.  The provision becomes ef-
fective if over one-third of the cotton crop grown on allotment acreage is
lost.  If, for example, a farmer has 100 acres of cotton allotment and the
normal yield per acre is 500 Ibs of lint, the farmer's normal yield is
50,000 Ibs of cotton.U  If one-half of the crop is lost, the farmer quali-
fies for disaster payments on 25,000 Ibs of cotton.  He receives a payment
of one-third the current target price multiplied by the pounds of cotton
lost if the loss is equal to or greater than one-third the normal yield.

     In some circumstances the farmer can suffer a disaster to his crop yet
not qualify for the disaster payments in the program.  This can happen as
follows.  Consider the same farm as above with the 100-acre allotment.  Now
assume the farmer chooses to grow 200 acres of cotton, so that 100 acres
under the allotment while the other 100 acres is not.  Expected yield in
this case is 100,000 Ibs of lint.  If 50,000 Ibs of cotton are lost due to
a disaster and the farmer produces only 50,000 Ibs at harvest, he is not
eligible for disaster payments.  His disaster payment is based on 50,000 Ibs
of his normal yield.  The cotton allotment applicable in this case assumes the
farmer has received his normal yield and therefore does not qualify for disaster
payments.

     There are no restrictions on the number of acres of cotton planted.  How-
ever, the risk to the farmer increases if he plants on nonallotment acres.  In
1974, for every 100 acres of allotment cotton in the US, there were about 27
acres of nonallotment cotton grown.  A combination of bad weather and insect
damage in some areas such as the Southeast and the Delta appear to have resulted
in yield reductions.  However, as a result of growing a large amount of the
crop on nonallotment acres, many farmers experiencing damage either did not
qualify for disaster payments or received less than the full benefits of these
payments.
JL/  Although the allotment is stated in acres, the provisions of the cotton
allotment program are based on normal yield.  Normal yield is derived from
a moving average of yields on each farm from previous years.
                                   -157-

-------
TRENDS IN COTTON ACREAGE. YIELDS, AND PRODUCTION IN THE US AND IN MAJOR
PRODUCING REGIONS
     Economic performance of the cotton industry since the DDT cancellation
must be viewed within the context of trends during earlier years as indi-
cated in Figure HID.3 and Tables HID.4,  5, and 6.  These data indicate
that cotton acreage, yield, and production vary greatly from year to year,
that there are long-term trends in the cotton industry, and that results
in 1973-1974 are not grossly out of line with past performance of the in-
dustry.  The high degree of annual variability in the cotton market is
typical of agricultural markets.

     The cotton industry has been able to maintain its production to meet
domestic and export needs since the DDT cancellation.  Although production
has declined slightly at the national level, it has been more than adequate
to meet market needs, as prices declined very significantly in 1974.  The
record high prices for cotton in 1973 are not attributable to the DDT
Decision.

     The two regions of the United States in which DDT was used as of 1972
are the Delta and Southeast .A'  DDT was used much more extensively in the
Southeast Region (Va., N.C., S.C., Ga. , Fla. , and Ala.) than the Delta
Region (Mo., Ark., Tenn., Miss., La., 111., and Ky.).  In the Southeast, it
was used on about half the acreage compared with less than one-fourth of.
the acreage in the Delta.  These insecticide use patterns will be discussed
in more detail later in this report.

     Cotton yields in Southeast Region in 1973 and 1974 are equal to or
greater than yields during years immediately prior to the decision and are
above the long-term average for the region (Figure HID.3 and Table HID.4).
In the Delta Region, cotton yields increased slightly in 1973 over 1972  and
were above long-term average yield.  However, the Delta cotton yield declined
from 555 Ibs  in 1973 to 406 Ibs in 1974, the lowest yield.in the last 14
years.  Most of this decline is credited to floods and adverse weather condi-
tions as discussed in USDA's analysis of the situation presented in its  recent
Cotton Situation reports (January and April, 1975).  Changes in pesticide
policy are not cited as a significant factor in yield reduction in USDA's
1974 cotton situations.  Overall production in the Delta area did decline
significantly in 1973 and again in 1974 as a result of reduced yield and
acreage harvested.  In the Southeast, production has been maintained in  1973
and 1974 at levels comparable to 1972 and prior years.
_!/  Regions are defined in Figure HID.3.  Note that these USDA regional
definitions differ from those for which production cost data were presented
in Figure IIID.l and Table HID.2.
                                    -158-

-------
Figure HID.3
          COTTON:  ACREAGE,  YIELD, AND PRODUCTION
                                  UNITED STATES
                        X OF 193?.19 AV».
                         1957
                                 1963       1969
                                 YIAt MOINNINO AUOUSt I
                                                   1975
                  DELTA*
       1957  '60   '63   '66   '69   72
              TIAI MOINNINO AUOUH 1
                                  75
                                             SOUTHEAST*
                  WEST*
     X OF 1937 5» AV.
      uo
       1957   60   63    66   '69    72
              YIA« MOINNINO AUOUST 1
                                             SOUTHWEST*
                                         % OF IfSr-9* AV.
                                         uo
                                   1957   '60   '63   '66   '69   72   75
                                           TIAI MOINNtNO AUOUfl I
                             CS-269. JANUARY 1975
Note:
This chart,  based on USDA estimates as  of  January, 1975,  does
not reflect  more recent  estimates reported in Tables  HID.4, 5 and
6, which  are based on the Cotton Situation published  in April,
1975.
                                 -159-

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Table HID.4

           Cotton Yield Per Harvested Acre,  US  by Region,  1961-1974
                                         Region
Year
 West.
1963
1964
1965
1966
1967

1968
1969
1970
1971
1972

1973
1974

Average
  Yield
  1961-1974
1,034
1,035
1,047
  918
  828

1,047
  871
  798
  724
  937

  875
  983

  937
Southwest         Delta      Southeast
              (Ibs of lint)
   354
   338
   394
   375
   364

   404
   293
   306
   261
   399

   427
   280

   348
642
643
620
532
462

569
528
546
578
539

555
406

544
461
488
453
392
356

342
363
410
476
427

459
451

413
                           Total
1961
1962
959
1,356
343
339
489
510
338
363
438
457
517
517
527
480
447

516
434
438
438
507

520
443

477
West:  California, Arizona, New Mexico, and Nevada.
Southwest:  Texas and Oklahoma.
Delta:  Missouri, Arkansas, Tennessee, Mississippi,  Louisiana, Illinois,
  and Kentucky.
Southeast:  Virginia, North Carolina, South Carolina, Georgia, Florida,
  and Alabama.

Source:  USDA, ERS.  Cotton Situation. 1975.
                                     -160-

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Table IIID.5
                Cotton Production,  US by Region,  1961-1974
Year
West
Average
  Production
  1961-1974
2,491
                                          Region
Southwest       Delta
           (1,000 bales)
                          Southeast
4,036
                4,198
1,523
            Total
1961
1962
1963
1964
1965
1966
1967
1968
1969
1970
1971
1972
1973
1974
2,813
3,118
2,822
2,813
2,707
1,925
1,651
2,482
2,104
1,796
1,780
2,593
2,550
3,716
5,145
5,026
4,744
4,403
5,030
3,393
2,958
3,786
3,138
3,402
2,791
4,609
5,126
2,947
4,485
4,710
5,407
5,468
5,051
3,077
2,179
3,612
3,691
3,819
4,468
5,139
3,990
3,672
1,840
1,973
2,321
2,461
2,150
1,162
655
1,046
1,057
1,175
1,438
1,363
1,308
1,367
14,283
14,827
15,294
15,145
14,938
9,557
7,443
10,926
9,990
10,192
10,477
13,704
12,974
11,702
12,247
West:  California, Arizona, New Mexico, and Nevada.
Southwest:  Texas and Oklahoma.
Delta:  Missouri, Arkansas, Tennessee, Mississippi, Louisiana, Illinois,
  and Kentucky.
Southeast:  Virginia, North Carolina, South Carolina, Georgia, Florida,
  and Alabama.

-§/ 480 Ib net weight bales.

Source:  USDA, ERS.   Cotton Situation  1975.
                                    -161-

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Table HID.6
           Cotton Acreage Harvested in the US by Region,  1961-1974
               	Region	

Year           West       Southwest        Delta       Southeast      Total
                                       (1,000 acres)
1961
1962
1963
1964
1965
1966
1967
1968
1969
1970
1971
1972
1973
1974
Average
Acreage
1961-1974
1,409
1,418
1,310
1,306
1,241
1,006
957
1,138
1,159
1,079
1,180
1,328
1,399
1,814
1,267


7,205
7,112
6,440
6,250
6,120
4,348
3,895
4,505
5,140
5,346
5,132
5,544
5,757
5,059
5,561


4,404
4,434
4,042
4,080
3,974
2,774
2,262
3,049
3,358
3,355
3,708
4,578
3,448
4,344
3,701


2,616
2,605
2,420
2,421
2,280
1,424
883
1,468
1,398
1,375
1,451
1,534
1,366
1,453
1,764


15,634
15,569
14,212
14,057
13,615
9,552
7,997
10,160
11,055
11,155
11,471
12,984
11,970
12,670
12,293


West:  California, Arizona, New Mexico, and Nevada.
Southwest:  Texas and Oklahoma.
Delta:  Missouri, Arkansas, Tennessee, Mississippi,  Louisiana,  Illinois,
  and Kentucky.
Southeast:  Virginia, North Carolina, South Carolina,  Georgia,  Florida,
  and Alabama.

Source:  USDA, ERS.  Cotton Situation. 1975.
                                    -162-

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     Trends in cotton yields since 1961 are presented by state in Tables
HID.7 and 8 for the Delta and Southeast regions.  These data indicate
a high degree of variability in cotton yields within the regions and from
year to year at the state level.  These data do not preclude the possibility
of significant yield impact from the DDT Decision.  However, yield reduc-
tions such as these have occurred at earlier times, due to other factors.

     The Administrator's decision on the emergency request for the use of
DDT against the tobacco budworm on cotton in Louisiana presents a review
of pest problems and the impact of available controls on yields in the
State of Louisiana, which is an important state in the Delta producing
area.  In that decision, the Administrator found that the State of Louisiana
had "presented no substantial evidence - new or old - to support the premise
that the tobacco budworm problem is new, that recognition of its occurrence
and seriousness is new, or that the DDT mixture is the only insecticide that
can be expected to prevent economically significant damage arising from a
possible tobacco budworm outbreak this year."  (EPA, 1975)

     An unfavorable economic situation was faced by cotton producers in 1974
as seen in the basic cost/price relationships for that year.  The 1974 US
average yield of 443 Ibs of lint per acre (Table HID.4) and the estimated
average production cost per acre of $254.63 (Table HID.2) give a cost per
pound of 57.5 cents.  This cost compares with a cotton lint price of 45.9
cents per pound from August to January 13 (1974-1975) and an allowance of
10.4 cents for the value of the seed (a total of 56.3 cents per pound), to
give an average net loss of 1.2 cents per pound (USDA, ERS, Cotton Situation
and Starbird et al, 1972).  This outcome has led to greatly reduced plantings
in 1975 and probably hit some areas much harder than others (e.g., as a
result of very low yields in some areas in 1974) .  Yields in the Southwest
and Delta Regions were down markedly in 1974, while they were up in the West
and in line with recent years in the Southeast (Table HID.4).
AVAILABILITY OF ALTERNATIVES TO DDT
         Administrator's Findings:  1) DDT is useful for the
         control of certain cotton insect pests.  2) Cotton
         pests are becoming resistant to DDT.  3) Methyl
         parathion and other organophosphate chemicals are ef-
         fective for the control of cotton pests.  4) DDT is
         lethal to many insects beneficial to agriculture.

Data as of 1972

     On December 30, 1970, the USDA submitted a list of essential uses of DDT
to the EPA, which was recorded by EPA as Hearing Admission Number 2.  The
USDA considered DDT essential to control the following pests:  budworm, boll
weevil, cotton bollworms, cotton fleahopper, fall armyworm, garden webworms,
Lygus bugs, mirids, thrips, and cutworms.
                                    -163-

-------
Table IIID.7
              Lint Yield Per Harvested Acre in the Delta Region,
                      by State (Major States), 1961-1974
Year   Arkansas     Louisiana   Mississippi     Missouri    Tennessee   Region

1961
1962
1963
1964
1965
1966
1967
1968
1969
1970
1971
1972
1973
1974

512
512
582
605
572
418
333
502
518
470
522
488
513
368

429
464
628
544
540
602
621
636
551
555
576
509
481
445
(Ibs)
493
512
709
732
. 678
653
567
660
534
658
613
599
651
459

469
582
630
564
559
408
314
495
533
431
614
520
501
356

493
494
621
640
611
475
295
432
505
483
597
543
472
298

489
510
642
643
610
532
462
569
528
546
578
539
555
406
Sources

USDA, ERS.  Statistics on Cotton and Related Data, 1920-1973, 1974.
USDA, ERS.  Cotton Situation, 1975.
                                    -164-

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Table HID.8
            Lint Yield Per Harvested Acre in the Southeast Region,
                      by State (Major States), 1961-1974
Year   Georgia
       South Carolina   North Carolina
Alabama    Region

1961
1962
1963
1964
1965
1966
1967
1968
1969
1970
1971
1972
1973
1974

354
369
453
467
467
398
408
322
351
373
466
395
499
480

337
373
405
496
486
442
449
352
342
349
412
435
473
456
(Ibs)
377
327
449
470
287
290
277
310
287
464
371
337
455
440

327
371
511
512
505
392
282
362
405
453
551
470
423
431

338
363
461
488
453
392
356
342
363
410
476
427
459
451
Sources

USDA, ERS.
USDA, ERS.
Statistics on Cotton and Related Data,  1920-1973,  1974.
Cotton Situation, 1975.
                                      -165-

-------
     Heavy dependence on DDT in cotton production was related to the control
of the boll weevil and the bollworm.  However, Dr. Brazzel of the USDA
testified that DDT used for boll weevil control also destroys beneficial
predators of bollworms (Tr:307, App. 1:159, 161).  Also, evidence presented
indicated that cotton insect pests are resistant to DDT and that methyl para-
thion was the most commonly used insecticide to control the boll weevil in
every state but Mississippi (Tr:6332-6334, App. 5:1940).

     Cotton entomologists participating in the DDT Hearings generally agreed
that a successful boll weevil "diapause" control program, which tends to re-
duce insecticide use, would contribute to the effective control of the boll-
worms.  This particular control program includes the destruction of cotton
plant refuse after harvest and the use of insecticides prior to the boll
weevil's diapause.  Since this practice delays the use of insecticides until
late in the growing season of the year, bollworm predator populations are
given some protection.

     Testimony at the 1972 Hearing presented DDT alternatives for the control
of cotton pest infestations.  Methyl parathion and carbaryl were two insecti-
cides available for bollworm control and the merits of the boll weevil dia-
pause program were stated.  In addition, the possibility of future implemen-
tation of sex traps, sterilized insects, and trap crops were mentioned (Tr:
314 p. 15, App. 1:166-167 and Tr:191, App. 1:102).

     Dr. Young of Mississippi State indicated that within 3 to 5 years the
bollworm will have established a very strong resistance to DDT, as well as
other insecticides (Tr:102, App. 1:13).  Dr. Newsome of Louisiana State
University contributed to this contention, since he believed that overuse of
insecticides by cotton producers would hasten the development of cotton pest
resistance mechanisms (Tr:102, App. 2:737).

     Historically more insecticides have been used for cotton than for any
other domestic agricultural crop.  Insecticides have contributed to cotton
production, but extensive use of insecticides has contributed to pest
management problems due to development of resistance in pests.

     Shortly after  World War II, chlorinated hydrocarbons were successfully
introduced as effective pest controls for cotton.  However, many target pests
proved to be very adaptive and developed a resistance to these pesticides
(Adkisson, 1973).

     The resistance problem was initially met with greater quantities of the
chlorinated hydrocarbons by increasing the number of applications or the
rate per acre.  Also, cotton producers began to use new chemicals (e.g.,
organophosphates or carbamates) or they combined different chemicals to
achieve either a broader spectrum of control or a higher probability of
target pest decimation (NAS, 1974).
                                   -166-

-------
     Both the increased quantity of insecticides as well as the use of dif-
ferent compounds have had a detrimental impact on populations of natural
predators.  Natural predator reduction contributed to larger infestations
of the increasingly resistant primary pests and enabled secondary problem
insects to achieve primary pest status (Adkisson, 1973).

     In certain cotton producing regions, the chemicals used for boll weevil
control enabled the bollworms to surpass the initial target pest in terms of
importance.  Also, the tobacco budworm has attained a high level of resis-
tance to chlorinated hydrocarbons, organophosphates, and carbamates, which
will hinder control in the future  (Adkisson, 1973).

     At the Annual Conference on Cotton Insect Research and Control in 1972,—
eight insect pests were declared resistant to DDT in one or more states
(Table HID.9).  The bollworm and tobacco budworm were each determined to be
resistant to DDT in several southeastern states, as of 1972 (Table HID.10).
DDT was recommended only for 3 of the 21 insects cited as cotton pests at the
1972 conference:  bollworms, budworms, and cutworms (Table HID.10).  Alter-
natives to DDT were recommended for each of these three pests.

Data since 1972

Chemical alternatives

     By 1975, the Annual Cotton Conference recommended several additional
alternatives to DDT for the bollworm and budworm (Table HID.11).  However,
only three chemicals were recommended for cutworms.  This conference also
cited numerous promising new future chemical controls for the bollworm, but
only three for the budworm, and none for cutworms (Table HID.11).

     A review of EPA registration data indicates several alternatives to DDT
for control of cotton insect pests for which DDT was considered essential by
the USDA (Table HID.12) (DDT Hearing Admission 2).  There may be other
alternative controls than those listed in Table HID.12, which held regis-
trations since 1972 or were recommended by the states.  Alternatives to DDT
are not equally efficacious or economically feasible in all areas due to
pest resistance and other factors.

     Under EPA's Substitute Chemical Program, a series of Minieconomic Re-
views have been conducted on the efficacy and cost effectiveness of various
chemicals for control of cotton insect pests.  These reviews contain sur-
veys of available literature and data on the capacity of substitute chem-
icals to control target pests and return a profit over costs when used by
the grower.
JY  The recommendations of the "Annual Conference" are based on the best
available current research data known by representatives of the various
cotton states and are generally followed in making recommendations to
growers on controls for cotton pests.
                                   -167-

-------
Table HID.9
             Cotton Insect Pests Stated to be Resistant to DDT,  1972
Pest
            States
Bollworm



Cabbage looper

Cotton leafperforator

Lygus bugs

Southern garden leafhopper

Tobacco budworm


Saltiaarsh caterpillar

Pink bollworm
Alabama, Arkansas, Arizona, California,
Georgia, Louisiana, Mississippi, Missouri,
Oklahoma, Tennessee, North Carolina, Texas

Arizona, Georgia, Tennessee, Texas

Arizona

Arizona, California

California

Alabama, Georgia, Louisiana, Mississippi,
North Carolina, Texas, Arizona

Arizona, California

Texas
Source:  USDA, ARS.  2,5th Annual Conference Report on Cotton Insect Research
           and Control, Memphis, Tennessee, January 11-12,  1972.
                                     -168-

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Table IIID.10
           Recommended Dosages of Technical Material in a Dust or Emulsion Spray for the Principal
                        Insecticides Used for the Control of Cotton InsectsS./ (1972)
Insecticide

aldicarb(Temik)b_/
azinphosmethyl£/
Bacillus
thuringiensis&J
carbaryl
carbopheno thion
DDTll/
demeton
t-- d icr o topho s ( Bidr in)
^o disulfoton6.'
endosulf an
endrin
ethion
EPN
malathionfL'
methyl parathion
Methyl Trithionl/
monocrotophos
(Azodrin)
parathion (ethyl)
phorateJL/
phosphamidon
Toxaphene
trichlorfon
Boll
weevil
Ib/acre
—
0.25-0.5

—
1.00-2.5
—
—
__
—
—
—
0.5
—
0.5
1.00-2.0
0.20-1.0
0.5

0.60-1.0
—
—
—
2.00-4.0
—
Bollworm Cabbage
or tobacco looper
budworm
Ib/acre Ib/acre
— —
—

4 to 8x109
1.00-2.5
—
1.00-3.0
	 —
— —
__ — —
1.0
0.30-0.6
— —
1.0

1.00-2.0 1.0
—

0.60-1.0 0.60-1.0
—
—
—
—
__ — —
Cotton Cotton
aphid leaf
perforator
Ib/acre Ib/acre
0.30-0.5
—

—
2.0
0.20-1.0
—
0.12-0.38
0.10-0.5
0.50-1.0
— —
— —
0.20-1.0
— —
0.30-1.0
0.25-0.5 1.0
0.20-0.5

0.3
0.10-0.5
0.50-1.5
0.12-0.5 —
—
1.00-1.5
Cotton
leafworm
Ib/acre
—
0.25-0.5

—
1.00-2.5
—
—
—
—
—
—
—
—
	
0.25-1.25
0.12-0.38
—

—
0.12-0.25
—
—
2.00-3.0
— —
Cutworms
Ib/acre
—
—

—
1.00-1.5
—
1.0
—
—
__
—
0.20-0.4
—
__
—
—
—

—
—
—
—
2.00-4.0
1.00-1.5
Fall
armyworm-
Ib/acre
—
—

—
1.00-2.0
—
—
—
—
—
—
—
—
	
__
0.25
—
—
—
—
—
—
—
0.50-1.0
   For information on recommended insecticides for the following insects see source report:   Beet armyworm, p. 46;
   darkling beetles,  p.  56;  field crickets,  p. 72; seed corn maggots,  p. 63; whitef ringed beetles, p. 69;
   wireworms, p.  69;  yellowstriped and western yellowstriped armyworms ,  p.  70.
   In-furrow granule  treatment at planting.
                                               (continued on next page)

-------
Table HID. 10 (continued)
Insecticide

aldicarkk/
azinphosmethyl
carbaryl
diazinon
dicrotophos
(Bidrin)
dimethoate
disulfoton£/
endosulf an
malathion
methyl parathion
Methyl Trithion
monocrotophos
naled
parathion
phorateS/
phosphamidon
Toxaphene
trichlorfon
Cotton
f leahopper
Ib/acre
0.60-1.0
0.10-0.25
0.50-1.5
—

0.10-0.4
0.10-0.4
—
—
0.70-1.0
0.25-0.5
0.5
0.25-0.5
—
0.25-0.5
—
0.50-1.0
1.00-4.0
0.25-1.0
Garden
webworm
Ib/acre
—
—
1.25-2.5
—

—
—
—
—
1.00-2.0
0.25-0.5
—
—
—
—
—
—
2.00-4.0
0.50-1.0
Grass-
hoppers l
Ib/acre
—
—
1.2
—

—
__
—
—
1.00-2.0
0.25-0.5
—
—
0.25-0.5
—
—
—
1.50-3.0
— .-.
Lygus bugs &
other mirids'
Ib/acre
0.60-1.0
0.10-0.25
0.70-2.0
—

0.10-0.4
0.10-0.5

—
0.70-1.0
0.25-0.5
—
0.25-0.5
—
0.5
—
0.50-1.0
1.60-4.0
0.25-1.5
Pink •'-' .
bollworm
Ib/acre
—
0.50-1.0
2.00-2.5
—

—
	
—
—
—
—
—
0.60-1.0
—
—
—
—
—
— —
Saltmarsh
cater- -
pillar
Ib/acre
—
—
2.0
1.0

—
	
—
—
—
1.0
—
—
—
—
—
—
—
1 . 00-1 . 5
Stink
bugs
Ib/acre
—
—
1.25-2.5
—

—
	 	
—
1.0
—
0.50-1.0
—
—
—
0.50-1.0
—
—
—
1.00-1.5
Thrips
Ib/acre
0.30-0.5
0.08-0.25
0.35-1.0
—

0.10-0.25
0.10-0.2
0.50-1.0
—
0.40-0.7
0.12-0.5
0.12-0.25
—
—
—
0.50-1.5
0.25-0.5
0.50-1.5
__

   Azinphosmethyl and malathion may be applied ultra-low volume as technical material at 0.125-0.25 and at
   0.5-1.2 Ibs/acre, respectively.
   International units (1 to 2 quarts) per acre.
!~J In-furrow granule at planting.  Seed treatment for cotton aphid and thrips control at 0.25 to 0.5  Ib/cwt seed.
L/ Research indicates that higher dosages of Methyl Trithion than those registered are required in some areas.
iL' In-furrow granule treatment at planting.  Seed treatment at 0.25 to 1.5 Ibs/cwt seed.
h/ Pending the final decision by the Administrator of EPA recommendations for the use of DDT for the  control  of
   certain insects on cotton are included in this report.

Source:  USDA, ARS.  25th Annual Conference Report on Cotton Insect Research and Control, Memphis, Tennessee,
           January 11-12, 1972.

-------
Table HID. 11
         Recommended and Promising Controls for Bollwonns, Budworms,
             and Cutworms Advocated by the 1972 and 1975 Annual
              Conferences on Cotton Insect Research and Control
Pest
1972 Recommended
   Controls
1975 Recommended
   Controls
 Future Promising
Controls in the Field
Bollworm
carbaryl
endrin
EPN
methyl parathion
Azodrin
 (monocrotophos)
DDT
Budworm
carbaryl
endrin
EPN
methyl parathion
Azodrin
 (monocrotophos)
DDT
Cutworm
carbaryl
endrin
Toxaphene
trichlorfon
DDT
carbaryl
endosulfan
endrin
EPN
methyl
 parathion
Azodrin
 (monocrotophos)
Toxaphene
Chevron Ortho
 9006 (Monitor)
chlordimeform
me thorny 1
carbaryl
endosulfan
endrin
EPN
methyl parathion

Azodrin
 (monocrotophos)
Toxaphene
Chevron Ortho 9006
 (Monitor)
chlordimeform
methomyl

carbaryl
Toxaphene
trichlorfon
 Orthene (acephate)
 Bay NTN 9306
 carbofuran
 Cela S-2957
 Lorsban (chorpyrifos)

 Ciba-Geigy CGA
  18809
 FMC 33297
 Hoechst HOE 2960

 Leptophor
 Zectran (mexacarbate)
 NPV
 San I 52, 159
 Stauffer Nr2596

 Bay NTN 9306
 FMC 33297
 NPV
Sources

USDA, ARS.  25th Annual Conference Report on Cotton Insect Research and Control,
 Memphis, Tennessee, January 11-12, 1972.
USDA, ARS.  28th Annual Conference Report on Cotton Insect Research and Control,
 New Orleans, Louisiana, January 6-8, 1975.
                                    -171-

-------
Table HID. 12
                          Alternatives to DDT for Control
                           of Cotton Insect Pests, 1974
      Pest
                                            Alternative
Boll Weevil
Cotton Bollworms
 (Heliothis zea
 and Heliothis
 virescens)
Cotton Fleahopper
Fall Armyworm


Garden Webworm




Lygus Bugs
Thrips
Cutworm
aldicarb
azinphosmethyl  (Guthion)
carbaryl
dicrotophos  (Bidrin)
endosulfan
endrin
EPN

azinophosmethyl  (Guthion
carbaryl
chlordimeform hydrochloride
dicrotophos  (Bidrin)
endosulfan
endrin
EPN
methidathion

aldicarb
azinphosmethyl  (Guthion)
carbaryl
carbophenothion
dicrotophos  (Bidrin)
dimethoate
EPN

carbaryl
endrin

azinphosmethyl  (Guthion)
carbaryl
endrin
malathion

aldicarb
azinphosmethyl  (Guthion)
carbaryl
dicrotophos  (Bibrin)
dimethoate
endrin
malathion
methyl parathion

aldicarb
azinphosmethyl  (Guthion)
carbaryl
demeton
dicrotophos  (Bidrin)
dimethoate
disulfoton
endosulfan
endrin
EPN

carbaryl
endrin
methyl parathion
malathion
methidathion
methyl parathion
monocrotophos  (Azodrin)
parathion
Strobane
Toxaphene

methomyl
methyl parathion
monocrotophos  (Azodrin)
naled
parathion
Strobane
Toxaphene
malathion
naled
parathion
phosphamidon
Strobane
Toxaphene
trichlorfan

malathion
methyl parathion

methyl parathion
parathion
Strobane
Toxaphene

monocrotophos (Azodrin)
naled
oxydemetonmethyl
parathion
phosphamidon
Strobane
Toxaphene
trichlorfan

malathion
methyl parathion
Monitor
monocrotophos (Azodrin)
parathion
phorate
phosphamidon
Strobane
Toxaphene
Strobane
Toxaphene
trichlorfan
Source:  EPA, Summary of Possible Alternative Registered Pesticides for DDT
           Insecticides, 1974.
                                        -172-

-------
     Information on efficacy and cost effectiveness is exerpted from several
reviews of alternatives to DDT in control of cotton pests and presented in
Appendix IIID.l of this report (parathion, methyl parathion, aldicarb, and
malathion).  Although current (1974) efficacy and cost effectiveness data
are limited, there are indications that these chemicals can serve effectively
to control the cotton pests once controlled by DDT combinations.  Whether an
alternative is effective in a given state or area depends greatly on how long
the chemical has been used and at what intensity.  Additional reviews of DDT
alternatives are in progress under the Substitute Chemical Program.

Improved use of chemical and nonchemical alternative controls

     Substantial economic and environmental benefits can be obtained by use
of the least hazardous pesticides, and by their use only in line with economic
thresholds of pest infestation, i.e., when the level of infestation actually
justifies use.  There has been a tendency to use insecticides on a regular
schedule as part of a cotton growing program designed to insure against insect
pest damage, with little or no regard for whether an infestation exists.  In-
creasingly during recent years interested Federal Agencies, such as USDA and
EPA, the states, and industry have promoted so-called integrated pest management
programs, which are usually devoted to improved use of both chemical and non-
chemical controls of cotton pests.

     Integrated pest management (IPM) is a concept which will probably become
more prevalent as a control of cotton pest infestations.  It appears to be
slowly gaining acceptance in many different regions of the country, even
though many of the basic concepts are from 50 to 70 years old.  Publicly run
IPM programs have been encouraged in at least three states for 10 years or
longer.  These states are Alabama, Arkansas, and Texas.

     The objective of the concept is to improve pest control systems. . An IPM
program normally has three goals:

     1.  Diagnosis of the pest problem (by scouting, also referred
         to as "field checking"; pest trapping; and/or other
         methods).

     2.  Determination if and when intervention (pest suppression)
         is required (mostly based on damage thresholds).

     3.  Suppression of the pest(s) by the most appropriate tool(s)
         available.

     IPM programs vary from state to state, but most are oriented toward im-
proved insect control by delayed chemical application.  The delay of insec-
ticide applications facilitates population growth of natural predator insects,
which helps to control the pests.  A number of programs have made progress in
the use of the most appropriate tool(s) available, e.g., biological or cul-
tural controls, as well as in improved pest diagnosis and suppression.
                                     -173-

-------
     In states with publicly run IPM, program participants apply insecti-
cides only on a recognized need basis, rather than treating according to
a designated time schedule.  This approach is not as sophisticated as some
integrated pest management programs, but it has generally contributed
to a 30 to 40% reduction in the number of insecticide applications.

     Specifically, in the Texas High Plains reproductive-diapause boll
weevil control effort, a comparison of expected insecticide use with and
without an IPM program indicated an 82% decline in the treatment level
over a 10-year period.  For that region, it meant a reduction of 8,240,000
Ibs of chemicals such as malathion, Toxaphene, methyl parathion, azin-
phosmethyl, and Bidrin.  This involved a $12 million decrease in production
costs, while 76,000 bales of cotton were added to the total yield.  Also,
no adverse effects on wildlife (especially beneficial insects), domestic
animals, or human beings have been detected (Lacewell and Casey, 1974).

     In another program conducted in a previously high insecticidal use
area, strong positive results were demonstrated by an IPM program at Pecos
Station, Texas.  During 1968-1970, insecticidal application was initiated
based on accurate assessment of insect populations in the field.  System
support was provided by good crop management, including a diversified
cropping system which supported beneficial insect populations naturally.
The experiment demonstrated that Pecos area cotton producers could reduce
their treatment costs by over 90%; saving over $60/acre (Pate et al, 1972).

     Initiation of IPM programs for cotton production requires intensive
grower education programs.  These education programs center around work-
shops for pest scouting.  In Arkansas a small industry of consultants
specializes in private scouting.

     In recent years, the US Department of Agriculture has assumed a much
stronger role through federally funded IPM programs.  In 1974, 14 states
were involved in cotton scouting programs.  Initially implemented as 3-
year projects, funding from USDA was formula distributed in each state
through the Cooperative Extension Service.  In addition to required proof
of economic feasibility to the growers, these projects had to provide in-
sect control comparable or better than customary practices.

     Grower participation has increased significantly since the 1972 init-
iation of the 3-year programs.  In 1972, only 549,000 acres were involved
in the programs compared to 868,000 acres projected for 1974 (6% of the
plantings).

     Less than 20,000 acres were in each of the federally sponsored pro-
grams in New Mexico, Missouri, and Oklahoma; but in many states over 20%
of the cotton acreage was committed to IPM programs.  These states included
Arkansas with 250,000 acres; Alabama with 154,000 acres; South Carolina
with 115,000 acres; and Arizona with over 50,000 acres (Good, 1974).  Ad-
ditional acreages  (often sizable) in these states were scouted by private
consultants.
                                    -174-

-------
     In the future, as confidence increases with the use of these con-
trols, more fully integrated pest management programs can be expected.
As these programs progress by upgrading field checking capabilities,
expanding data bases of actual field histories, and experimenting with
artificially introduced predators and parasites, more sophisticated
biological and cultural controls can be expected.  However, it has been
stated that IPM systems are not being actively promoted by Federal regu-
latory agencies despite their potential for the future (RvR Consultants,
1974).

     Presently, a bacterial spore formulation of Bacillus thuringiensis
is registered for use on cotton, but the level of control is not as con-
sistent as existing chemical insecticides.  This particular pathogen has
potential, since strains 15 to 20 times more effective than earlier
varieties have been developed.  However, additional research is needed
to improve upon the pathogen's insecticidal properties (USDA, ASCS, 1973).

     A class of microorganisms that is often mentioned for cotton pest con-
trol is the nuclear polyhedral viruses (NPV).  Viral diseases have been
stated to be highly effective against the cabbage looper, since pest des-
truction occurs before yield-reducing damage results (USDA, ERS, 1970).
Also, there is an experimental permit to use Heliothis virus to control
bollworms (USDA, ASCS, 1973).

     However, one study indicated that the following characteristics of
pathogenic controls merit increased attention before widespread acceptance
can occur (NAS, 1974)!/:

     1.  Longer shelf life              4.  More reliable and consistent
                                              control of the target pest
     2.  Greater persistence
                                        5.  Lower cost
     3.  Ease of application
                                        6.  Capability of meeting EPA
                                              registration standards
JL/  A study of the commercial potential of new generation pesticides, includ-
ing cotton insecticides, has been funded under EPA's Substitute Chemicals
Program which will give added data on the potential for biological and other
novel controls.  The study is to be completed by Fall 1975.
                                   -175-

-------
     Insects that are either exotic or indigenous to cotton producing areas
can be used for pest control purposes (NAS, 1974).  Some scientists have
advocated searching Central America and Mexico to find exotic predators.
It has also been suggested to mass rear natural cotton predators for re-
lease in areas of heavy infestation.  However, large-scale rearing of pre-
dators has not yet been tried, and exotic predator importation has not
been successful.

     Some of the indigenous insects found in different producing regions
considered helpful to control cotton pests include lady beetles, nabids,
parasitic wasps, minute pirate bugs, and the larvae of green lacewing
(Ledbetter, 1972).

     In 1972 one specific biological control program released sterilized
pink bollworm moths in the San Joaquin Valley of California (USDA, ASCS,
1973).  About 282 million moths were reared in Phoenix, Arizona, and over
99 million were sterilized for release, to prevent the establishment of
the pink bollworm in California.  Surveillance with a large number of
attractant-baited traps indicated that the project was successful.

     Another biological control is the use of cotton plant varieties that
have characteristics incompatible to pests (NAS, 1974).  For instance,
crops that mature for harvest in late August or early September, rather
than October or November, reduce the opportunity for tobacco budworms to
inflict heavy damage.  There is also a frego-bract variety of cotton that
is resistant to the boll weevil and a nectariless variety that is moderately
resistant to Lygus bugs and fleahoppers and slightly resistant to the boll-
worm complex (Shuster and Maxwell, 1974 and Jenkins and Parrot, 1971).

     Trap crops are one cultural technique that can reduce damage related
to infestations.  A small portion of the cotton field can be planted early
to attract overwintering boll weevils.  The trap crop can then be treated
with an insecticide, shredded, and plowed under the soil (NAS, 1974).

     Alfalfa can be used as a trap crop specific to Lygus bugs, since this
insect prefers alfalfa to cotton as a food source.  Alfalfa can be planted
in areas of heavy infestations and treated with relatively small amounts
of insecticides for control (Presley, 1972).

     There are other cultural pest control practices that merit brief atten-
tion.  Cotton producers have used desiccants and defoliants to facilitate
rapid harvest and to force a shedding of fruiting forms that are food
sources for certain pests.  Plant stalks can also be destroyed and plowed
under, since the stalks may harbor overwintering pests.  Diversified crop-
ping may be used to increase populations of beneficial insects.  Also, the
use of mechanical strippers, rather than spindle pickers, will leave fewer
harmful larvae in the fields after harvest (NAS, 1974).
                                    -176-

-------
Conclusion

     DDT substitute chemicals are available for cotton pest control.  The
chemical substitutes are generally effective, but pest resistance problems
are encountered in some areas.

     In addition, IPM programs are substitutes for DDT use in cotton pro-
duction.  These programs can  combine chemical, biological, and cultural
controls and may achieve results comparable on better than conventional
cotton pest control practices.  However, most IPM programs are still in
the initial stages of development and implementation.
INSECTICIDE USE PATTERNS

Data as of 1972

     At the time of the DDT Hearings and the decision in 1972, limited cur-
rent data were available on insecticide use patterns.  There were estimates
that up to 38% of the cotton acreage was treated with DDT  (Tr:6171-6172),
which accounted for as much as 85% of domestic DDT use (soybeans, 5%;
peanuts, 9%; and other uses, 1%)  (Order of Administrator, p.2).  The 1964
and 1966 USDA surveys were the most recent data.  Since that time, USDA has
conducted a survey for the year 1971 (published in 1974) and private market
research data are now available and will be discussed herein.

USDA data;  1964, 1966, and 1971 surveys

     Historically more insecticides are used in cotton production than any
other domestic agricultural crop.  From three insecticide use surveys con-
ducted by the ERS of the USDA for 1964, 1966, and 1971, cotton was estimated
to account for 55.6%, 47.2%, and  47.6% respectively, of all agricultural
crop insecticides (USDA, ERS, 1968; USDA, ERS, 1970; USDA, ERS, 1974).   For
these 3 years, DDT accounted for  31.2%, 29.6%, and 17.9% of the total cotton
insecticides and represented 74.1%, 73.0%, and 94.0% of the total DDT used
on crops.

     A profile of quantities of the various insecticides used in cotton  pro-
duction prior to the cancellation of DDT is provided in Table HID.13 and
provides a basis to study past trends.  While Toxaphene, exhibited stability
of consumption, use of DDT declined from over 23 million pounds in 1964  to
near 13 million in 1971.  Conversely, organophosphate use about doubled.

     The USDA pesticide use surveys indicate a similar pattern on the basis
of cotton acreage treated with various insecticides  (Table HID.14).  Quite
clearly DDT use was on the decline  (and the use of organophosphates on the
increase) prior to the 1972 cancellation order.
                                    -177-

-------
Table HID. 13
              Quantities of Selected Types of Insecticides Used on Cotton,
                          United States, 1964, 1966, and 1971
Type of Insecticide Product

Inorganic Insecticides
Botanicals and Biologicals
Synthetic Organic Insecticides
Organo chlorines
Lindane
Strobane
TDE (DDD)
DDT
Methoxyclor
Endrin
Heptachlor
Dieldrin
Aldrin
Chlordane
Endosulfan
Toxaphene
Others
Total
Organophosphorous
Disulfoton
Bidrin
Methyl Parathion
Parathion
Malathion
Demeton
Diazinon
Trichlorfon
Azinophosmethyl
Phorate
Ethion
Other
Total
Carbamates
Bux
Carbaryl
Carbofuran
Methomyl
Others
Total
Other Synthetic Organ! cs
Total Synthetic Organics
Total Insecticides (Not Including
Petroleum)
Petroleum
Total Insecticides
Sources
USDA, ERS. Quantities of Pesticides
USDA, ERS. Quantities of Pesticides
1964

2,518
NA


540
NA
1 191
23,588
NA
1,865
—
—
17
NA
NA
26,915
2,660
55,778

565
NA
8,760
1,636
1,811
47
—
NA
250
10
NA
2,177
15,196

NA
4,510
NA
NA
NA
4,510
14
72,978

78,016
6
78,022

Used by Farmers
Used by Farmers
1966
(1,000 Ibs)
—«
2


163
2,016
167
19,213
6
510
—
11
123
3
61
27,345
85
49,703

300
1,857
7,279
2,181
559
NA
—
963
200
—
73
212
13,624

NA
1,571
NA
NA
—
1,571
—
64,898

64,900
468
65,368

in 1964, 1968.
in 1966, 1970.
1971

69
—


—
216
—
13,158
—
1,068
—
65
—
—
—
28,112
—
42,619

225
778
22,988
2,560
670
NA
—
144
288
100
6
1,617
29,376

—
1,214
—
40
37
1,291
2
73,288

73,357
8
73,365



USDA, ERS. Farmers' Use of Pesticides in 1971 - Quantities, 1974.
                                           -178-

-------
Table IIID.14
         Acres of Cotton Treated with Selected Types of Insecticides
                     United States, 1964, 1966, and 1971
Type of Insecticide Product
Inorganic Insecticides
Botanicals and Biologicals
Synthetic Organic Insecticides
Organochlorines
Lindane
Strobane
TDE (DDD)
DDT
Methoxychlor
Endrin
Heptachlor
Dieldrin
Aldrin
Chlordane
Endosulfan
Toxaphene
Others

Organophosphorus
Disulfoton
Bid r in
Methyl Parathion
Parathion
Malathion
Demeton
Diazinon
Trichlorfon
Azinophosmethyl
Phorate
Ethion
Others
Carbamates
Bux
Carbaryl
Carbofuran
Methomyl
Others
Other Synthetic Organics
Petroleum
1964
(1
57
NA


636
NA
61
6,901
NA
1,194
negligible
—
16
NA
NA
5,016
428


619
NA
5,420
751
213
322
—
NA
641
35
NA
2,236

NA
1,002
NA
NA
NA
102
NA
1966
,000 acres)
_M
8


298
225
33
4,767
6
403
—
36
161
6
56
3,881
285


473
1,416
3,577
860
245
NA
—
512
222
NA
26
534

NA
415
NA
NA
—
—
71
1971
i.. .it...
23
—


—
18
—
2,383
—
262
—
174
—
—
i i
3,275

i '.?'

553
1,797 .„, ,
6,384 ,
682
273
— '•<
—
191
. 119
182
30
1,216

—
244 ' <
—
84
66
24
11
Sources

USDA, ERS. Quantities of Pesticides Used by Farmers in 1964, 1968.
USDA, ERS. Quantities of Pesticides Used by Farmers in 1966, 1970.
USDA, ERS. Farmers' Use of Pesticides in 1971 — Quantities. 1974.

                                   -179-

-------
     Therefore, it would appear that DDT and other chlorinated hydrocarbons
were diminishing in importance as factors of production in cotton at the
national level.  Conceivably, if EPA had not issued the cancellation order,
factors such as development of DDT-resistant cotton pests and effective
chemical and nonchemical substitutes would have contributed to further de-
cline in the chemical's importance.

     The USDA surveys did not provide use pattern data by region for indi-
vidual chemical/crop combinations such as DDT on cotton.

Data since 1972

     The above USDA data on cotton insecticide use at the national level
are complemented with market research data which show more recent national
trends and use patterns of DDT and other insecticides by regions of the
United States.  These data are utilized to obtain a picture of shifts after
the cancellation in the number of farms and acres with treatment of DDT,
treatment with other insecticides and with no treatment.  In this analysis,
data are presented for the 2 years prior to cancellation (1971-1972 average)
and for 2 years since (1973-1974 average).  Table HID.15 contains a summary
of use pattern data for these 2 periods.

     Review of these data indicates:
                                       /
     1.  DDT treatments were used on about 17% of US cotton
         farms in 1971-1972 (18,744 out of a total.of.110,724
         cotton farms in the US).  An additional 32,066 farms
         (29% of the total) treated with other insecticides,
         while slightly more than half of US cotton farms used
         no insecticide treatment on cotton (59,914 farms or
         54% of US total).

     2.  DDT treatments averaged 11.7 million acre applications out of
         a total of 47.0 million acre applications with cotton insecti-
         cides (25% of the US total).  I/ This resulted in 51.8% of US
         cotton acreage being treated one or more times per year during
         the 1971-1972 period with the overall average number of applica-
         tions being 7.3.
I/  An acre application is the use of a chemical or chemical combination on
one acre one time.  The number of acre applications exceeds the number of
acres treated if there are multiple  treatments during the year.  For example,
a farmer treating five times on 100 acres of cotton would have 500 acre ap-
plications even though his total treated acreage is only 100 acres.
                                     -180-

-------
Table HID. 15
            DDT Cotton Insecticide Use Patterns in US, by Region, 1971-1972 and 1973-1974 Averages
South East South
Atlantic Central
1971-1972
Number of farms
DDT treatments
Other treatments
No treatments
Total farms
Number of acre applications
(in thousands)
DDT treatments
Other treatments but no DDT
Total acre applications
Total acres treated - any
chemical!1/ (in thousands)
Acres treated/farm
Number of applications/acre
1973-1974

Number of farms
DDT treatments
Other treatments
No treatments
Total farms
Number of acre applications
(in thousands)
DDT treatments
Other treatments
Total acre applications
Total acres treated - any
chemical?*' (in thousands)
Acres treated/farm
Number of applications/acre
No.

9,516
3,764
3,706
16,986


5,217
4,216
9,438

917
69
10



—
11,544
2,304
13,848


—
11,032
11,032

820
71
13
(%) No. (%)

(56) 8
(22) 14
(22) 18
(100) 42


(55) 6
(45) 20
(100) 27

(93.1) 3
.1 —
.27 —



	
(83) 29
(17) 16
(100) 46


—
(100) 30
(100) 30

.5 (92.9) 3
.1 —
.43 —
SJ Percent of total cotton acreage in region treated
Source: EPA computations based
Pesticide Programs,

,576
,904
,815
,296


,319
,834
,133

,144
133.
8.



	
,302
,789
,090


—
,355
,355

,550
121.
8.

(20)
(35)
(45)
(100)


(23)
(77)
(100)

(74.8)
9 —
62 --



	
(64)
(36)
(100)


—
(100)
(100)

(82.7)
2 —
55 —
West South All Other
Central Regions
No.


10
32
43



5
5

1






16
34
51



7
7

1


one or more times

	
,578
,846
,424


—
,394
,394

,486.
140.
3.



	
,662
,454
,116


—
,482
,482

,810
96.
4.
(any
on Special Pesticide Market Research Survey
1975





(%) No. (%)

	 -
(24) 3,
(76) 4,
(100) 8,


—
(100) 5,
(100) 5,

5 (25.4)
5 —
6 —



	
(33) 6,
(67) 4,
(100) 11,


—
(100) 2,
(100) 2,

(29) 1,
2 —
13 —
insecticide)
Information


_
472
547
019


_
046
046

954
274
5



,_
776
622
400


—
261
261

281
189
1
.
for


	
(43)
(57)
(100)


	
(100)
(100)

(58.7)
.8 —
.29 --



__
(59)
(41)
(100)


—
(100)
(100)

(67.4)
—
.76 —

Total US
No.

18,744
32,066
59,914
110,724


11,738
35,268
47,006

6,501
127.
7.



__
64,284
58,170
122,454


—
51,140
51,140

7,463
116.
6.

(%)

(17)
(29)
(54)
(100)


(25)
(75)
(100)

(51.8)
9 —
3. —
1
\

_ —
(52)
(48)
(100)


—
(100)
(100)

(55.9)
1 —
79 —

EPA, Office of



                                                      -181-

-------
     3.  DD1 was used only in the South Atlantic and East South
         Central Regions (regional definitions provided on
         Figure HID.4) .

     4.  The South Atlantic Region was more dependent on DDT,
         as more than half of its cotton farms used it compared
         with less than one-fourth of the farms in the East South
         Central Region.  More than 90% of cotton was treated
         with an insecticide in the South Atlantic Region com-
         pared with only 75% in the East South Central.  The
         number of applications per year was also greater in the
         South Atlantic (10.3 compared with 8.6).

     5.  Acreage treated per farm is considerably smaller in the
         South Atlantic than in the East South Central Region
         (69.1 acres compared with 133.9 acres in 1971-1972).

     6.  In 1973-1974, total cotton acreage and the number of
         farms declined in the South Atlantic Region while in-
         creases occurred in the East South Central Region

     7.  The percentage of acreage treated one or more times re-
         mained near 93% in the South Atlantic Region in the
         pre- and postcancellation periods while it increased
         quite significantly in the East South Central Region
         (from 74.8% to 82.7%).

     8.  The number of applications per year increased between
         the pre- and postcancellation periods in the South
         Atlantic Region (from 10.3 to 13.4 treatments per year)
         while remaining essentially constant in the- East South
         Central Region at near 8.6 treatments per year.

     9.  The percentage of farms treating with one or more in-
         secticide treatments increased between the pre- and
         postcancellation periods in both regions (from 78% to
         83% in the South Atlantic and from 55% to 64% in the
         East South Central Region).

Conclusion

     DDT was widely used as a cotton insecticide through 1972, although its
importance was on the decline.  By 1971-1972 it was used on about one-sixth
of US cotton farms, and it equalled about one-fourth of total cotton in-
secticide acre applications.
                                     -182-

-------
           Figure IIID.4
oo
U)
                                           SPECIAL PESTICIDE MARKET SURVEY:   COTTON REGIONS
                                             """	1	1—J\
                                                        • NORTH DAKOTA    :      *««*•.
                                                                        I MINNESOTA  '
                                                                        \
                                                                         \
                                                                         )        f WISCONSIN
                                                                         ']
                                                                          i
                        \!               !        "U      I-	, OKLAHOMA
                        \               i                ITEXAS  T
                         >              /               I        !
                        ^               '                I        k_
                        '.              ;                I             '•*—•
                            '..        /                I        ^f
                                 —I.:—c        J        ^r
         1 - North Atlantic States
         2 - South Atlantic States
         3 - East North Central States
         4 — East South Central States
         5 - West North Central States
         6 - Western States
         7 - West South Central States
V

-------
INSECT CONTROL COSTS
          Administrator's Finding:  By using methyl parathion
          or other means of pest control3 cotton producers
          can generally produce satisfactory yields at accep-
          table cost.
Data as of 1972

     The DDT Hearing Record includes testimony by Dr. Ridgeway from Texas
(Tr:2495) who referred to an unspecified study which estimated that the
replacement of DDT with organophosphates would increase cotton production
costs by $15 million (presumably per year).  Ridgeway was not concerned
as much by the $15 million production cost impact as by possible economic
side effects on industry and regional economies that could be associated
with cancellation.

     Ridgeway contended that increased use of organophosphates after DDT's
cancellation would accelerate the development of resistance mechanisms of
cotton pests, which would increase the chance of not having adequate con-
trols for cotton pests at some future time.  Inadequate controls for cotton
pests could force cotton production out of certain geographic regions,
which would have economic impact on other segments of the local economy
interrelated with cotton production.

     Cooke of the USDA testified that use of Toxaphene and methyl parathion
as substitutes for DDT would increase the number of insecticide applica-
tions, thus increasing cotton production costs.  Also, Cooke submitted a
USDA study (USDA, ERS, October 1970) which estimated that annual cotton in-
secticide and application costs would double (i.e., increase by about
$54.5 million over those associated with present average insecticide prac-
tices) if DDT were cancelled (Tr:2472-2578).

     The above estimate was limited to the Southeast, Appalachia, Delta
States, and Southern Plains Regions.   It was based on 1969 data and the
two DDT substitutes Toxaphene and methyl parathion.  Cooke indicated
that the cost per treated acre in the regions would have increased $9.95
(or $5.24 for all cotton acres).  Expressed in terms of 1970 data, the in-
creased cost per pound of lint was 1.2 cents, which was estimated to be
about a 5% increase in the cost of production.

     Cooke also indicated that the relative increase in insecticide costs
would be higher for low insecticide users relative to the high users (Tr:
2578).  The insecticide cost per pound of lint produced by the high use
farmers was estimated to increase from 4.38 cents to 5.09 cents.  For the
low use farmers the same cost item was estimated to change from 2.52 cents
to 4.67 cents.
                                   -184-

-------
     The above estimates of impact on the costs of cotton production ($15
million to $54 million per year) are much greater than those indicated by
Dr. Headley, an economist from the University of Missouri who testified
at the DDT Hearings.  Dr. Headley testified that the cancellation of DDT
would not have a significant (or adverse) effect upon the cotton economy
(Tr:6180-6184), as he believed that pest control costs and the cotton
market price would not be influenced by the unavailability of the chemical.
This contention was based on the premise that only half of the cotton farms
used any insecticide and further that only 38% used DDT.  Also, Headley in-
dicated that DDT use was concentrated in the Southeast, Delta States, and
eastern half of the Southern Plains with larger farms probably using more
DDT than small farms.

Data since 1972

Total expenditures, national level

     Expenditures for insecticides to protect cotton have increased sharply
since the cancellation.  Nationally, annual average insecticide expendi-
tures for cotton increased from $64.6 million in 1971-1972 to $102.9 million
in 1973-1974, while the average number of acre applications per year in-
creased only slightly (from 47.0 to 51.1 million) (Table HID.16).  Costs
per acre application on the average increased from $1.38 in 1971-1972 to
$2.01 in 1973-1974.  Total insecticide costs per treated acre increased from
$10.07 (7.3 applications x $1.38) to $13.65 (6.79 applications x $2.01).

     The largest single shift from the use of DDT combinations obviously was
to the use of Toxaphene/methyl parathion combinatipns, as total acre appli-
cations of this combination increased from 2.4 million to 10.4 million.
Substantial increases are noted in several other individually named chemi-
cals such as temik, galecron, guthion, and fundal plus endrin/parathion
combinations and other miscellaneous combinations.  These data at the
national level are provided as general background for the review of changes
in expenditures for cotton insecticides in the two regions in which DDT was
used prior to the cancellation.

Total expenditures, regional level

     Cotton insecticide expenditures are presented for the pre- and post-
cancellation periods for the South Atlantic and East South Central Regions
of the US in Tables HID.17 and 18 including data for all insecticides
combined and individually for specific major pesticides including DDT com-
binations .  Average annual expenditures increased very sharply in both
regions in the postcancellation period compared to the precancellation
period.

     In the South Atlantic Region, average annual expenditures increased
from $14.2 million per year in 1971/72 to $26.6 million in 1973/74 and
from $1.51 to $2.41 per acre application.  Costs per acre application more
than doubled for ethyl and/or methyl parathion (from $1.89 to $4.35) and in-
creased rather sharply for other miscellaneous combinations $1.37 to $2.53).
                                    -185-

-------
     Table IIID.16
           Average Annual Expenditures and Use of Cotton Insecticides  in the US,  1971-1972 and 1973-1974
oo
CTi
Average Annual
Expenditures
Type of
(1,000 dollars)
Insecticide 1971-1972
Bidrin
Azodrin
Di-Syston
Toxaphene
Toxaphene/methyl
parathion
DDT/methyl parathion/
Toxaphene
Ethyl and/or methyl
parathion
Temik
Galecron
Guthion
Fundal
Endr in/par athion
Other miscellaneous
chemicals
Other miscellaneous
combinations^/
Unidentified
No answer
Total

-------
Table HID. 17
    Average Expenditures and Use of  Cotton Insecticides  in  South Atlantic  Region,  1971-1972  and  1973-1974
Average Annual
Expenditures
Type of
Insecticide
DDT /methyl parathion/
Toxaphene
DDT/methyl parathion
Toxaphene/methyl
parathion
Ethyl and/or methyl
parathion
Other miscellaneous
^1 chemicals
°° Other miscellaneous
1 combinations
Unidentified
No answer
Total users
Total nonusers
(1,000 dollars)
1971-1972

6,374
434

—

3,528

2,323

1,548
—
16
14,226
~—
Source: EPA computations based on
1973-1974

—
—

3,445

4,706

5,629

12,718
121
3
26,624
— —
Average Annual
Acre Applications
(1,000 acre appl.)
1971-1972

4,880
336

—

1,862

1,210

1,126
—
8
9,432
"
1973-1974

—
—

2,125

1,082

2,724

5,026
56
8
11,032
"
Special Pesticide Market Research
Average Cost per
Acre Application
Average Annual Number
Farms Using Insecticides
(dollars)
1971-1972

1.31
1.29

—

1.89

1.92

1.37
—
2.00
1.51

1973-1974

—
—

1.62

4.35

2.07

2.53
2.16
0.38
2.41

Survey Information for
1971-1972

8,677
840

—

3,116

8,508

4,150
—
453
13,280
3,706
EPA, Office of
1973-1974

—
—

3,224

2,804

13,711

7,654
688
320
11,544
2,304

           Pesticide Programs,  1975.

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Table HID. 18
     Average Expenditures  and Use  of  Insecticides  in the East  South Central Region,  1971-1972 and 1973-1974
Average Annual
Expenditures










i
M
00
CD
1






Type of
Insecticide
Bidrin
Toxaphene /me thy 1
parathion
DDT/Toxaphene/
methyl parathion
Ethyl and/or
parathion
Endr in/para thion
Other miscellaneous
chemicals
Other miscellaneous
comb ina t ions
Unidentified
No answer
Total users
Total nonusers
Source: EPA computations
(1,000
1971-1972
224

712

8,343

8,601
—

6,351

5,999
—
116
30,348
"
based on
dollars)
1973-1974
__

13,747

—

11,864
2,890

8,012

15,616
—
72
52,202
""
Average Annual
Acre Applications
(1,000 acre appl.)
1971-1972
260

517

6,319

10,442
—

4,726

4,825
—
34
27,133
__
Special Pesticide Market
1973-1974
___

6,843

—

9,915
1,092

5,110

7,346
—
34
30,354
""
Research
Average Cost per
Acre Application
Average Annual Number
Farms Using Insecticides
(dollars)
1971-1972
0.86

1.38

1.32

0.82
—

1.34

1.24
—
3.41
1.12
«_
1973-1974
_—

2.01

—

1.20
2.65

1.57

2.13
—
2.12
1.72
___
Survey Information for
1971-1972
1,020

1,330

8,576

9,102
—

8,753

5,648
—
223
23,481
18,815
EPA, Office of
1973-1974
__

8,618

—

10,363
2,640

17,806

7,714
—
720
29,302
16,789

           Pesticide Programs,  1975.

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Total insecticide costs per treated acre more than doubled between 1971-1972
and 1973-1974, i.e., from $15.51 (10.27 applications x $1.51) to $32.37  (13.43
applications x $2.41).  It is very difficult to determine which chemical com-
binations were used as alternatives to DDT combinations in the South Atlantic
Region.  Most of the increases in farms reporting insecticide use occurred in
unspecified chemicals or combinations of chemicals (Table HID.17).

     During 1971-1972 cotton insecticide costs in the South Atlantic Region
averaged $1,071 per farm for all farms using insecticides ($715 per farm for
DDT combinations).  Costs per farm more than doubled in 1973-1974 ($2,306 per
farm for all users) (average computed from Table HID.17).

     For the East South Central Region, average annual expenditures for cotton
insecticides increased from $30.3 million during the precancellation period to
$52.2 million after cancellation (Table HID.18).  Average costs per acre ap-
plication increased from $1.12 to $1.72 and insecticide costs per treated acre
increased from $9.65 to $14.71.  In this particular region, ethyl and/or methyl
parathion applications increased about 50% in contrast with a more than 100%
increase in the South Atlantic Region.—'

     During 1971-1972 cotton insecticide costs in the E- South Central Region
averaged $1,292 per farm per year for all farms using insecticides ($973 per
farm for use of DDT combinations).  These costs per farm increased by about
38% in 1973-1974 (from $1,292 to $1,781), considerably less than in the South
Atlantic Region.

Impact of cancellation on insecticide costs

     This part of the report is concerned with estimating the impact on the
costs to cotton farmers for insecticide materials and application costs in
the two regions where DDT was used prior to the cancellation, i.e., South
Atlantic and East South Central (Tables HID.17 and 18).

     The procedure to be used in estimating impact of the DDT cancellation on
cost is'as follows:

     1.  The number of acre applications with DDT in 1973-1974 is the
         actual number of acre applications in the region, with all
         chemicals, times the percentage of acre applications which
         contained DDT in 1971-1972;
_!/  Average costs per acre application were generally lower in the East South
Central Region than in the South Atlantic Region.  In the precancellation
period the average expenditures per acre application were $0.39  ($1.51 versus
$1.12) less in the East South Central Region and in the postcancellation
period costs were $0.69 less ($2.41 versus $1.72)  (Tables HID.17 and 18).  The
reduced number of acre applications of ethyl and/or methyl parathion together
with substantial increases in costs of these insecticides suggest a shortage
of such materials, particularly in the South Atlantic Region.
                               -189-

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      2.   The  cost  of DDT  combinations  in  1973-1974 is estimated
          as the  1971-1972 cost per acre application  for DDT  com-
          bination  plus  20%  to allow  for price  increases at  a
          rate of about  10%  per year;

      3.   The  cost  of DDT  alternatives  in  1973-1974 is the actual
          average cost per acre application  for all insecticides
          (some of  which are not  used as alternatives to DDT).!';

      4.   Compute impact of  DDT decision on  insecticide costs as
          number  of projected acre applications in 1973/74 with
          DDT  times difference between  DDT cost/acre  application
          and  other chemicals cost/acre application;

      5.   Add  $1.00 per  acre application for application costs
          assumed to be  attributable to DDT  cancellation, computed
          as the  total change in  acre applications between
          1971-1972 and  1973-1974, times the percent  of acre  appli-
          cations with DDT in 1971-1972.

      Alternative methods  could be used; however, this method is thought  to
give  reasonable  approximations of cost impact.  Impact on yield and changes
in  crops  grown which can affect  costs  and income (as well as acres grown
and production)  is not  considered in this particular cost analysis.

      South Atlantic Region

                                 2/
      In the South  Atlantic  Region—' , DDT  was used in two chemical combina-
tions:  1) DDT with methyl  parathion and  Toxaphene,  and 2) DDT with methyl
parathion.  These  two DDT combinations accounted for an average annual ex-
penditure of  $6.8  million in 1971-1972 ($1.31  per acre application).  This
cost  annually accounted for about 48%  of  the total cotton insecticide ex-
penditures for 1971-1972 in the  region which were $14.2 million ($1.51 per
acre  application).  Also, the insecticide treatments containing DDT ac-
counted for about  55% of the annual regional acre applications and 72% of
the cotton farms utilizing  insecticides during this  period,  which indicates
smaller cotton farmers  used DDT  more than larger acreage growers  (Table
HID.17).

      The  average annual number of acre applications  in 1971/72 was about
9.4 million and  13,280  cotton farms were  projected to utilize insecticides
(Table HID.17).
J7  It would be preferable to use the weighted average cost of insecticide
actually used as alternate to DDT.  However, this could not be done because
of data limitations, so the overall average was used.
21  South Atlantic Region includes Maryland, Delaware, Virginia, West
Virginia, North Carolina, South Carolina, Georgia, and Florida.
                                     -190-

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     Following the cancellation of DDT the average annual expenditure
for cotton insecticide in the  South Atlantic escalated to $26.6 million
(Table HID.17), $12.4 million more than the precancellation average.

     Since DDT mixed with other insecticides gave broad spectrum control
of many different cotton pests, it is probably reasonable to assume that
many alternative insecticides were used as substitutes after DDT's
cancellation.  If .the proportion of acre applications with DDT combina-
tions is assumed to be the same in 1973-1974 as in 1971-1972 (55%) , then
approximately 6,068,000 acre applications would have been DDT combina-
tions in the South Atlantic during 1973-1974 (55% of 11,032,000).

     In the  South Atlantic Region the average acre application cost
of insecticide materials was  $2.41 in 1973-1974.  By increasing the acre
application cost of DDT treatments by 20% to account for inflation, the
average annual acre application cost for DDT treatments in 1973-1974
would be about $0.84 more than non-DDT treatments ($2.41-($1.31 + 20%,
or $1.57) = $0.84).  Therefore, a rough estimate of the additional
insecticide cost associated with DDT substitutes in the postcancellation
period would be $0.84 times 6.1 million acre applications, which amounts
to about $5.1 million.

     If an aerial acre application costs  $1.00 and if 55% of the
increase in acre applications were due to the DDT cancellation (which
is only an assumption), an additional $880,000 can be added as an impact
of the cancellation (55% of the 1,600,000 added acre applications, i.e.,
11,032,000 compared with 9,432,000).

     Therefore, the total annual insecticide and  application costs associated
with the DDT cancellation in the South Atlantic Region would be
approximately $6.0 million.

     The increase in insecticide costs attributed to DDT cancellation
of $6.0 million would equal $630 per farm based on the average number of
farms using DDT in 1971-1972 (9,517 farms).!/  This is a significant cost
effect, as these farms had an average cost of $715 per year for DDT com-
binations in 1971-1972.  The $5.1 million increase in insecticide costs
equals 41% of the total increase in insecticide costs between 1971-1972 and
1973-1974 (i.e., from $14.2 million to $26.6 million, or $12.4  million).
The average insecticide cost per treated acre (all insecticides) in the
South Atlantic Region increased from $15.51 in 1971-1972 to $32.37 in 1973-
1974.  The DDT cancellation accounted for $5.56 to $6.25 of this increase
($16.86) depending on whether the $5.1 million increa.se is computed on
basis of 1971-1972 treated acreage (917,000) or 1973-1974 (820,500).
_!/  This may overstate the impact per farm since more farms than 9,517
may have used DDT in 1973-1974, as the number of acre applications increased
significantly between 1971-1972 and 1973-1974.
                                    -191-

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     East South Central Region

     In the East South Central Region—  , DDT combined with methyl para-
thion and Toxaphene accounted for over  27% of the annual cotton insecti-
cide expenditures, which averaged $8.3 million for 1971-1972.  DDT mixture
accounted for 23% of the acre applications and was used by 36% of the
cotton producers utilizing insecticides in the region (Table HID.18).

     Before DDT use was cancelled, the  average annual insecticide expen-
diture in the East South Central totaled about $30.3 million.  The aver-
age annual number of acre applications was 27.1 million, on about 23,500
cotton farms (Table HID. 18).

     For 1973-1974 the East South Central's average annual insecticide
expenditures climbed to $52.2 million (Table HID.17), which was about
$21.9 million more than the 1971-1972 average.  Also the average acre
applications increased to about 30.3 million, which was 3.2 million
higher, and the average number of farms utilizing insecticides increased
by about 5,800.

     By using the same estimation technique applied to the South Atlantic
Region, an approximate 7 million acre application of DDT combinations
would have been used annually in 1973 and 1974 if DDT had not been can-
celled (23% of 30.3 million).

     In the East South Central Region,  the average acre application cost
of insecticide materials was $1.72 in 1973 and 1974.  By increasing the
acre application cost of DDT treatments by 20% to account for inflation,
the average annual application cost would be about $0.14 more than a DDT
treatment.  Therefore, a rough estimate of the additional insecticide
cost associated with DDT substitutes in the postcancellation period would
be $0.14 times 7.0 million acre applications, which amounts to about $1.0
million.  The $1.0 million increase in  insecticide cost amounts to about
$0.30 per treated acre of cotton in the region, out of an increase from
$9.65 per acre in 1971-1972 to $14.71 per acre in 1973-1974.

     The change in the number of acre applications attributable to the
DDT cancellation was about 750,000 (23% of 30.3-27.1 million).  If an
aerial acre application costs $1.00, the increased cost of applying the
DDT substitutes would be $750,000 per year.

     Therefore, the total annual insecticide and application costs asso-
ciated with the DDT cancellation in the East South Central Region would
be approximately $1.75 million.
_!/  East South Central Region includes Kentucky, Tennessee, Alabama, Mis-
sissippi, Arkansas, and Louisiana.
                                   -192-

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     The insecticide cost increases due to DDT cancellation (about $1.0
million) would be about $116 per farm, based on the 8,576 farms using
DDT in 1971-1972.  This compares with a cost per farm for DDT combinations
in 1971-1972 of $973.00.  This impact plus the application cost impact
brings the total cost impact to about $200 per farm.

Conclusion

     The analysis of cost impact for the two regions where DDT was used
in 1971-1972 results in a total cost of $7.75 million, of which $6.1
million was insecticide costs and $1.63 million was application costs.
Whether this increase in application costs (1.63 million) can be fairly
attributed to DDT cancellation is unknown, but it is consistent with the
hypothesis that DDT is more persistent than alternatives and therefore
they require more treatments.

     This analysis does not address the possibility of impact in 1973-1974
in areas where DDT was not used in 1971-1972 and does not take into account
the declining trend in DDT use which may have continued through 1973-1974
without the cancellation.

     The cost impact of $7.75 million per year on cotton production costs
due to the DDT decision is well within the range of estimates in the
record at 1972 Hearings (from Headley with no increase in costs to
Cooke with $54 million per year).  The $7.75 million cost impact is
significant in local regions where DDT was used.  It amounted to an average
of more than $600 per farm in the most significantly affected region, a
near doubling of per-farm insecticide costs.  The $7.75 million is a
nominal impact on the average consumer of cotton products, i.e., about
2.2 cents per capita per year.JV
INTRAREGIONAL AND INTERREGIONAL IMPACT ASSOCIATED WITH CANCELLATION OF DDT

     The previous analysis has considered the gross cost impact associated
with shifting from use of DDT in cotton pest control to alternative
insecticides.  It has been demonstrated that increased costs of alternative
controls are not distributed evenly across all cotton producing areas.
On an interregional basis, cotton producers in the Southeast were more
reliant on DDT than those in other areas.  In addition, a greater percentage
of 'cotton acreage is treated with insecticides in the Southeast than in
other regions (Appendix HID.2).

     The differential rates of economic impact stemming from cancellation
have been evaluated within an equilibrium framework through the use of a
national-interregional linear programming model of US agriculture which
was developed to assess the impact of pesticide policies.  A national model
was chosen for this analysis because of the high degree of substitution
between various land uses within a region and between regions for produc-
tion of a given crop when comparative advantage is altered by differential
changes in production techniques or input availability (Appendix HID.2).
I/  Based on 1973-1974 lint consumption of 17.3 Ibs/capita and US lint  pro-
duction of 5,922 million Ibs.

                                    -193-

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     The DDT cancellation on cotton was evaluated by solving the linear
programming model for equilibrium land use allocation when DDT is available
and, alternatively, when DDT is not available.  Both solutions are based
on the year 1975, which simulates a typical year in the period 1973-1977.
The results of these two solutions are reported in Appendix HID.2 and
can be summarized in acreage shifts, costs of production, and economic
returns to land  (a proxy for profit).

     The cancellation of DDT caused a slight reduction in total cotton
acreage in the US as evaluated within the framework of the linear
programming model (from 10.972 million acres to 10.952 million acres).
The reduction in acres was distributed as follows:  Atlanta, -3,924 acres
(-0.42%); Memphis, -8,915 acres (-0.37%); New Orleans, -24,056 acres
(-7.21%); Louisville, -625 acres (-34.05%); San Francisco, +17,590 acres
(2.24%) (see map in Appendix HID.2 for regions).  The relatively minor
shifts in acreage demonstrate that the change in production costs associated
with cancellation is not large enough to generate significant changes in
comparative advantage among regions, and therefore does not affect cropping
patterns for cotton or alternative crops.

     Aggregate costs of cotton production were affected both by a change in
production costs per acre in some regions and by the slight changes in acres
planted between regions.  In the Atlanta region, aggregate production costs
increased by $2.1 million (1.4%); in Memphis, the increase was $1.8 million
(0.5%); in New Orleans, where cotton acreage decreased the largest, total
production costs declined by $3.0 million (-6.45%); in San Francisco, the
increased plantings led to increased production costs of $4.3 million (2.2%).
Total US production costs increased by $5.2 million (0.4%) as a result of
the cancellation.

     Returns to land, which serve as a proxy measure for impact on the
profitability of cotton production, were affected slightly.  In the Atlanta
region, these returns decreased by 0.37% (from $45.35 million to $45.19
million); in Memphis, the decline accounted for a 1.93% reduction in the
precancellation returns of $63.53 million; and in New Orleans the $100,000
reduction in returns accounted for 0.93%.  San Francisco encountered an in-
crease in returns to land of 0.26% (from $33.41 million to $33.50 million).

Conclusion

     The analysis which was carried out through comparative analysis of linear
programming solutions indicates that production cost increases due to the DDT
cancellation on cotton are of insufficient magnitude to cause sizable shifts
in economic parameters at the regional or national levels, e.g., acreage, pro-
duction, total costs and returns to land.  A more detailed discussion of the
results of the linear programming analysis is presented in Appendix HID.2.
                                    -194-

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                                 REFERENCES
Adkisson, P.L.  The Principles, Strategies, and Tactics of Pest Control
  in Cotton.  College Station, Texas, Texas A&M University, January 1973.
  [draft]

Arthur D. Little, Inc.  Azodrin - Initial Scientific and Minieconomic
  Review.  Cambridge, Massachusetts, Arthur D. Little, Inc., October
  1974.  [draft]

Eichers, T., R. Jenkins, and A. Fox.  DDT Used in Farm Production.   Wash-
  ington, D.C., US Department of Agriculture, ERS, July 1971.  [AER 158]

Good, J.M.   Extension emphasis and results from cotton pest management
  projects.  Presented at 1974 Beltwide Cotton Production-Mechanization
  Conference, Dallas, Texas, 1974.

Jenkins, J.N., and W.L. Parrot.  Effectiveness of frego bract as a boll
  weevil resistance character in cotton.  Crop Sci. 11:159, 1971.

Lacewell, R.D., and J.E. Casey.  Evaluation of integrated pest manage-
  ment programs for cotton in Texas.  In:  Evaluation of Integrated Pest
  Management Programs for Cotton in the United States.  Washington, D.C. ,
  Environmental Protection Agency and Council on Environmental Quality^,...
  1974.  [D-16-18]

Ledbetter,  R.J. et al.  Guide for Cotton Insect Management in Alabama.
  Auburn, Alabama, Auburn University, 1972.  [Circular E-ll]

National Academy of Sciences.  Cotton;  An Assessment of Current and
  Future Pest Management.  Washington, D.C., National Academy of Sciences,
  September 1974.  [draft]

Pate, F.T., J.J. Hefner, and C.W. Neeb.  A Management Program to Reduce
  Cost of Cotton Insect Control in the Pecos Area.  College Station,
  Texas, Texas A&M University, Agricultural Experiment Station, February
  1972.

Presley, R.J.  Insect control in cotton in the USA.  In:  Cotton.  Basel,
  Switzerland, Ciba-Geigy, Ltd., 1972.  [Technical Monograph 3]

RvR Consultants.  Evaluation of Integrated Pest Management Programs for
  Cotton in the United States.  Shawnee-Mission, Kansas, RvR Consultants,
  September 1974.  [draft]
                                   -195-

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Shuster, M.F., and F.G. Maxwell.  The impact of nectariless  cotton on plant
  bugs, bollworms, and beneficial insects.   In:  Proceedings of the 1974
  Beltwide Cotton Research Conference, Dallas, Texas, 1974.

Special Pesticide Market Research Survey Information for EPA, Office of
  Pesticide Programs.  St Louis, Missouri,  Doane Agricultural Service, Inc.,
  1975.

Starbird, I.R.  Costs of producing upland cotton in the US - Procedures,
  results, and implications.  Presented at  1974 Beltwide Cotton Production-
  Mechanization Conference, Dallas, Texas,  January 10, 1974.

Starbird, I.R., and B.L. French.  Costs of  Producing Upland Cotton in the
  United States, 1969.  Washington, D.C., US Department of Agriculture,
  ERS, 1972.  [draft]

Starbird, I.R., B.L. French, and J.A. Evans.   Costs of Producing Upland
  Cotton and Selected Crops on Cotton Farms in the United States, 1972.
  Washington, D.C., US Department of Agriculture, ERS, 1975.  [draft]

Tr   Public Hearings on DDT, Transcript, Office of the Hearing Clerk,
  Environmental Protection Agency, Washington, D.C., 1971-1972.

US Department of Agriculture, Agricultural  Research Service.  25th Annual Con-
  ference Report on Cotton Insect Research arid Control, Memphis, Tennessee,
  January 11-12, 1972.

US Department of Agriculture, Agricultural  Research Service.  28th Annual Con-
  ference Report on Cotton Insect Research arid Control, New Orleans, Louisiana,
  January 6-8, 1975.

US Department of Agriculture, Agricultural  Stabilization and Conservation
  Service.  Pesticide Review 1972.  Washington, D.C., US Department of Agri-
  culture, June 1973.

US Department of Agriculture, Agricultural  Stabilization and Conservation Ser-
  vice.  Pesticide Review 1973.  Washington, D.C., US Department of Agricul-
  tural, 1974.

US Department of Agriculture, Economic Research Service.  Cotton Situation.
  Washington, D.C., US Department of Agriculture, January and April 1975.

US Department of Agriculture, Economic Research Service, Economic Effect of
  Restricting the Use of DDT on Cotton.  Washington, D.C., US Department of
  Agriculture, October 13, 1970.

US Department of Agriculture, Economic Research Service.  Economic Research on
  Pesticides for Policy Decision-Making, Proceedings, Washington, D.C., April
  27-29, 1970.

US Department of Agriculture, Economic Research Service.  Fanners' Use of Pes-
  ticides in 1971 — Quantities.  Washington, D.C., US Department of Agricul-
  ture, July 1974.  [AER 252]
                                    -196-

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US Department of Agriculture, Economic Research Service.   Quantities of
  Pesticides Used by Farmers in 1964.  Washington, D.C.,  US Department
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US Department of Agriculture, Economic Research Service.   Quantities of
  Pesticides Used by Farmers in 1966.  Washington, D.C.,  US Department
  of Agriculture, April 1970.  [AER 179]

US Department of Agriculture, Economic Research Service.   Statistics on
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  Agriculture, 1974.  [Statistical Bulletin 535]

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US Environmental Protection Agency.  Opinion of the Administrator.   Wash-
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US Environmental Protection Agency, Office of Pesticide Programs.   Initial
  Scientific and Minieconomic Review - Methyl Parathion.   Washington, D.C.,
  Environmental Protection Agency, October 1974.

US Environmental Protection Agency, Office of Pesticide Programs.   Summary
  of Possible Alternative Registered Pesticides for DDT Insecticides.
  Washington, D.C., Environmental Protection Agency, 1974.  [draft]
                                    -197-

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                     ECONOMICS OF THE MINOR USES OF DDT
     The minor uses of DDT present special problems for economic analysis,
not only of data but also of simple identification of the uses.  At the
Public Hearings on DDT in 1971, no party was able to identify all uses
for which DDT was registered.  The cancellation orders simply cancelled
all registrations of products containing DDT and TDE (EPA, OPP, January
1971; EPA, OPP, March 1971).  The Department of Agriculture submitted a
list of uses it deemed essential (EPA Hearing, Admission 1), but this
list was never taken to be a comprehensive statement of all registered
uses.  It was finally agreed by all parties that the only uses of DDT
at issue in the hearing and on which evidence would be taken were those
contested by the registrants.  These uses, designated in the Hearing
Record as Admission 11 (Table HID.19), are the only uses on which the
Administrator needed to make a determination of risks and benefits.  All
other uses of DDT were finally cancelled prior to the hearing because
all parties failed to appeal the original cancellation notice.  This
analysis is confined to those contested uses of DDT.

     Generally, the hearings produced very little economic data concern-
ing minor uses.  Most of the economic information presented concerned
cotton, by far the largest use of DDT.  Since the presentation of the
economic benefits of DDT was taken to be the responsibility of the
registrants and others opposing cancellation, neither EPA nor EDF prepared
analyses of economic benefits and costs.  Most of the information in this
analysis has been prepared since the final cancellation decision and deals
with observed economic effects in the 2 years since cancellation.
CONTESTED NONESSENTIAL CROP USES
            Administrator's Finding:  DDT is useful for controlling
            insects that attack the following: beans (dry, lima, snap),
            sweet potatoes, peanuts, cabbage, cauliflower, brussels
            sprouts, tomatoes, fresh market corn, sweet, peppers and
            pimentos, onions, garlic, and commercial greenhouse plants.
            The use of DDT is not necessary for the production of these
            crops.

     Crops which do not require use of DDT because adequate substitute
chemicals are available at reasonable costs are listed in Table HID.20.
The Administrator found that the registered alternative insecticides were
sufficiently effective to allow the maintenance of crop yields without
burdening farmers with increased insecticide costs.
                                   -198-

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 Table HID. 19
                  Cancelled Uses of DDT subjected to Objection
           by Group Petitioners and Other Uses Deemed Essential by USDA
 Use Pattern                                    Notes and Limitations
 1.  Fresh Market Corn
       Armywonn
       Corn Earworm
       European corn borer
       Cutworm

 2.  Peanuts
       Whitefringed beetle                     Soil application
       Cutworm

 3.  Cabbage, Cauliflower, Brussels Sprouts
       Cutworm

 4.  Tomatoes
       Cutworm

 5.  Lettuce
       Corn earworm
       Cutworm                                 Fall lettuce only (Northeast)

 6.  Potatoes
       Flea beetles
       White grubs
       Wireworms

 7.  Sweet potatoes
       Cucumber beetle
       Flea beetle
       Sweet potato weevil

 8.  Commercial Greenhouses and Nurseries      Necessary for State-Federal
                                               quarantine and generally safer
                                               to humans than alternatives
 9.  Beans (dry, lima, snap)
       Armyworms
       Corn earworms
       Loopers

10.  Public Health Pests
       Bats
       Rodents

11.  Agriculture, Health and Quarantine
     Treatments in Emergencies as Recom-
     mended by and under Direction of
     State-Federal Officials

12.  Peppers and Pimentos
       European corn borer

13.  Fabric Treatment                          Military only

14.  Onions/Garlic
       Cutworm
 Source:  Public Hearings on DDT, Admission 11, 1972.
                                      -199-

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Table HID.20


    Crop/Pest Combinations for Which DDT Use Was Found Not to be Necessary


Crops                                  Pests


Sweet corn                             Armyworm, Corn earworm, European
                                         corn borer, Cutworm

Peanuts                                White-fringed beetle, Cutworm

Cabbage                                Cutworm

Cauliflower                            Cutworm

Brussels sprouts                       Cutworm

Tomatoes                               Cutworm

Garlic                                 Cutworm

Lettuce                                Corn earworm, Cutworm

Potatoes                               Flea beetle, White grub, Wireworm

Dry beans                              Armyworms, Corn earworm, Loopers

Lima beans                             Armyworms, Corn earworm, Loopers

Snap beans                             Armyworms, Corn earworm, Loopers


Source:  Ruckelshaus, W.D.  Opinion of the administrator.  Public Hearings
           on DDT, Admission 11, 1972.
                                    -200-

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Data as of 1972

     During the Consolidated DDT Hearings limited evidence was presented
on the benefits or lack of benefits of DDT use for crops listed as
essential.  On the benefits side was the contention that these uses of
DDT were essential, and the testimony of USDA entomologists that DDT was
needed for control of the specified pests on the indicated crops.

     On the other hand, Respondents pointed out that Group Petitioners
never quantitatively defined "essential" and, in fact, the hearing
examiner refused to allow any testimony or cross-examination challenging
the "essential use" contention.  (The hearing examiner was under the
mistaken impression that by allowing the USDA list of essential uses to
be designated as an Admission, the Respondents in fact agreed that these
uses were essential.  However, Respondents merely agreed the USDA con-
sidered them essential.)

     No accurate data were presented on either current DDT use or trends
in DDT use on the affected crops.  The 27 Group Petitioner registrants
did submit their total domestic sales for 1970 by region and crop and the
aggregated data were included in the hearing record (Table HID.21; EPA
Hearing Admission 6, 1972).  The data, however, only break down the crop
usage into cotton, soybeans, peanuts, and others.  The state sales break-
downs are for the total DDT sales only, and not on a crop-by-crop basis.
The data gave no indication of DDT use for any of the individual contested
uses, except peanuts.

     The hearings produced no data on the efficacy or yield effects of DDT
compared to the registered alternatives, beyond the personal observations
and beliefs of entomologists.  There was no analysis made by either side
of yield, quality, or pest control cost impacts of switching from DDT to
the alternatives.  The limited information in hearing testimony has been
incorporated into the analysis of economic impacts since cancellation.

     The Administrator's finding that DDT was not necessary for production
of these minor use crops was based primarily on the fact that alternative
insecticides were registered for those contested uses (Ruckelshaus, 1972).
He also took into account the lack of any information presented about the
possible benefits of DDT use.

Data since 1972

     Since the 1972 cancellation of DDT there have been virtually no
economic data developed outside EPA on the contested minor uses of DDT.
It is possible, however, to obtain some idea of the economic impact since
the cancellation took effect.  This analysis will focus on estimates of
the extent of use of DDT prior to cancellation, on observed changes in
crop yields since cancellation, and on estimates of changes in insect
control costs brought about by loss of DDT.  To the extent possible,
these effects will be identified for each use under consideration.
                                   -201-

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Table HID.21
                    Summary of 1970 DDT Domestic Sales
Item
Total pounds of DDT soldi'
Types of DDT formulations sold
Emulsifiable sprays
Dust
Wettable powder
Granular
Use
Cotton
Soybeans
Peanuts
Other
States
Alabama
Arkansas
California
Delaware^.'
Florida
Georgia
Louisiana
Maryland
Mississippi
Missouri
North Carolina
New Jersey
New Mexico
New York
Oklahoma
Oregon
Pennsylvania
South Carolina
Tennessee
Texas
Virginia
Washington
DDT (100% BASIS)
11,966,196

10,318,915
1,506,186
127,350
13,736

10,277,258
603,053
937,901
158,853

1,139,256
1,193,175
2,500
21,400
74,888
1,600,556
2,712,347
133
3,731,876
11,895
426,810
2,352
6,948
2,612
865
200
33
1,016,286
207,104
97,422
13,282
1,000
£/  Number of DDT Formulators:  27.
b/  Information supplied by H.P. Cannon and Sons.
                                   -202-

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Extent of DDT use

     As previously stated the DDT Hearings produced no complete data on
the extent to which DDT was used by farmers for the minor uses at issue.
Associate USDA Entomologist Clarence H. Hoffman did state that the minor
uses were limited to specific, usually small, regions of the country
(Tr:1958).  Beyond this, however, there was no attempt to define the
areas encompassed by each of the minor uses in question.

     The US Department of Agriculture surveys of pesticide use provide
some indication of the extent to which DDT was utilized by farmers
(USDA, AER-252, 1974; USDA, AER-179, 1970; USDA, AER-131, 1968).  These
data are presented in Table HID.22.

     As the table indicates, DDT use on peanuts fell dramatically between
1966 and 1971.  As a proportion of the total acreage harvested, DDT (and
TDE) treated acres dropped from 35.2% to 1.5% of the peanut acreage.
DDT use on potatoes rose from 21.9% to 32.1% of the total acreage between
1964 and 1966, but by 1971 had fallen to 2.7% of the potato acreage.
Use of DDT on vegetables other than potatoes has declined steadily over
the period from 19.6% of the acreage to about 2.8% of the acreage in 1971.

     These published USDA data do not go into any more detail on the
individual crops within the category Other Vegetables, but all of the
contested minor crop uses should be included in this group.  As aggregated
as the data are, they do show that in the last few years prior to
cancellation, DDT was becoming a much less important insecticide for the
uses in question.  This trend is probably due to the development of
resistance in target pests and to the advent of more effective insecticides.

     Beyond these published use data, the Department of Agriculture has
a few more detailed accounts of DDT use on the crops within the Other
Vegetables group (USDA, unpublished, 1974).  The level of precision of the
USDA survey makes the accuracy of DDT use estimates for these individual
crops highly speculative.  These figures should not be construed as
official USDA estimates but merely serve as a guide to the relative
magnitude of DDT use on these crops.  They are, however, the only such
figures available.

     Table HID.23 presents these more detailed use data in terms of
acres treated.  Also presented are total acres harvested in 1971, and
the estimated percentage of the national acreage treated with DDT.  As
the table indicates, USDA picked up no use of DDT on five of the crops
listed.  This does not mean that DDT was not used on these crops, but it
does indicate that these uses were probably very small.  Another factor is
that the indicated use on these crops may include treatment for insects
other than those for which use was contested.  Thus, of the estimated
8.8% of the cabbage acres treated with DDT, some may have been treated for
insects besides cutworms, the only contested use on this crop.
                                   -203-

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Table HID.22
               DDT and TDK Use in the US, 1964, 1966, 1971
Crop
1964
1966
1971
Peanuts
Ibs
acres
% of US acres
Potatoes
Ibs
acres
% of US acres
Other Vegetables
Ibs
acres
% of US acres

NAi/
NAfL/
NA§_/

373
279
21.9

1892
641
19.6

2,265,000
500,000
35.2

633,000
470,000
32.1

1,428,000
406,000
11.9

62,000
22,000
1.5

77,000
38,000
2.7

407,000
88,000
2.8
a/  In 1964 peanuts were included in a category called Other Field Crops.

Sources

USDA, ERS.  Quantifies of Pesticides Used by Farmers in 1964, 1968.
USDA, ERS.  Quantities of Pesticides Used by Farmers in 1966, 1970.
USDA, ERS.  Farmers' Use of Pesticides in 1971 - Quantities, 1974.
USDA.  Agricultural Statistics 1973, 1973.
                                   -204-

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Table HID.23
                      DDT Use by Crop in the US, 1971
Crop
Sweet corn
Peanuts
Cabbage
Cauliflower
Tomatoes
Lettuce
Brussels sprouts
Potatoes
Snap beans
Dry beans
Lima beans
Garlic
Total
Acres Treated
with DDT!/
12,800
22,000
9,600
. —
61,900
—
—
38,000
700
—
—
—
145,000
Total Acres
Harvested
606,100
1,454,500
108,480
25,710
391,040
217,000
6,140
1,391,300
323,710
1,316,000
71,130
3,700
5,914,810
Percent Treated
with DDT
2.1
1.5
8.8
—
15.8
—
—
2.7
0.2
|
—
—
2.4
a/  Includes acres treated with TDE.

Sources

USDA, ERS.  Unpublished data from 1971 survey of farmers' use of pesticides,
  1974.
USDA, ERS.  Farmers' Use of Pesticides in 1971 - Quantities, 1974.
USDA.  Agricultural Statistics 1973, 1973.
                                   -205-

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     Some information on DDT use is available for individual states.  The
state of California publishes annual reports of pesticide use by crop in
the state (Cal. Dept. Food Agric. 1971, 1972, 1973, 1974).  These reports
are most accurate for those pesticides whose use is restricted by Califor-
nia and must be reported to county and state officials.  Since DDT is on
this restricted list, the use figures should be quite accurate.  The Cali-
fornia use data for the crops of interest here are presented in Table HID.24.
The figures show that in that state DDT use fell drastically between 1970 and
1971, and went to 0 by 1972.  This sudden decline in use is due to the re-
moval of DDT from state insect control recommendations and to the banning of
DDT use within California.  It appears, therefore, that the Administrator's
1972 decision to cancel DDT actually had no economic effect on California,
as DDT use on these crops had been eliminated before the decision was made.

     The state of Arizona also publishes data on the total quantities of
pesticides used within that state (University of Arizona, 1974).  Table
HID.25 presents the agricultural use figures for DDT from 1967 through 1973,
with the exception of 700 Ibs used in 1970,  DDT use was entirely eliminated
in Arizona by 1969.  Further, a conversation with an extension entomologist
in North Carolina revealed that that state had stopped recommending DDT several
years prior to the DDT Hearings and that there was virtually no DDT use at the
time of cancellation.  This information implies that neither Arizona nor North
Carolina should have been affected economically by the cancellation of the
contested drop uses of DDT.  These three states, California, Arizona, and
North Carolina, together account for some 16% of the national acreage of the
contested crops.

     For this review, an attempt has been made to estimate the number of acres
of the contested crops that would have received DDT treatments in 1973 had DDT
not been cancelled.  These estimates are based on the proportions generated
from the USDA data and various other information as described below.  The esti-
mates are presented in Table HID.26.

     The figure for lettuce in Table HID.26 represents the 1973 acreage for
fall lettuce in the Northeast since Admission 11, Public Hearings on DDT
specifically limited the contested use to this area and season.  For the other
crops the estimated acreage was calculated by subtracting from the 1973 national
harvested acreage of these crops, the acreage contained in the three states
(California, Arizona, and North Carolina) in which it was known that DDT would
not have been used.  The remaining acres were multiplied by the estimated per-
centage of the 1971 acreage treated (Table HID.23 with the assumption that
this proportion would also be treated in 1973.  For those crops for which the
USDA survey showed no DDT use, the average percentage treated for all the crops,
2.4%, was used.

     For the harvested crop acreages found in Vegetable-Fresh Market-1974
Annual Summary, only the acreages for the fresh market were presented.  It was,
therefore, necessary to estimate the additional acreage harvested for the
processing market.  After determining a ratio of fresh market acreage to
processing market acreage from 1972 data (USDA, 1972), the ratio was applied
                                    -206-

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Table HID.24






                      DDT Use in California, 1970-1973
Crop
Sweet corn
Peanuts
Cabbage
Cauliflower
Tomatoes
Lettuce
Brussels sprouts
Potatoes
Snap beans
Dry beans
Lima beans
Garlic
Other uses
Total
Source: California
Reports,
Acres
1970
74
0
4,570
9,680
106,882
416
182
0
0
16,088
1,699
0
504,308
643,899
Department
1970, 1971
1971
0
201
210
549
8,891
0
20
40
0
1,078
0
0
52,663
63,652
of Food and
, 1972, 1973.
1972
0
0
0
0
0
0
0
0
0
0
0
0
42,095
42,095
Agriculture. Pesticide

1973
0
0
0
0
0
0
0
0
0
0
0
0
544
544
Use

                                    -207-

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Table HID.25
               Agricultural Use of DDT in Arizona, 1967-1973
      Year                            Quantity Used
                                  (Ibs Tech. Material)
      1967                               2,519,900


      1968                                 528,000


      1969                                       0


      1970                                     700

      1971                                       0


      1972                                       0

      1973                                       0
Source:  University of Arizona.  Agricultural Use of Pesticides in Arizona,
           1974.
                                   -208-

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Table HID.26
                Estimated Acres Affected by DDT Cancellation
Crop
Sweet corn
Peanuts
Cabbage
Cauliflower
Brussels sprouts
Tomatoes
Lettuce
Potatoes
Snap beans
Dry beans
Lima beans
Garlic
Total
a/
Estimated Affected Acreage—
17,800
20,000
8,000
200
0
14,500
900
32,700 '
600
28,300
1,200
\
\
0
124,200
aj  For derivation see text.

Sources

USDA.  Agricultural Statistics - 1973, 1973.
USDA, SRS.  Crop Production - 1973. 1974.
USDA, SRS.  Vegetables - Fresh Market - 1974 Annual Summary, 1974,
                                    -209-

-------
to 1973 data (USDA, SRS, 1974) to estimate harvested acreage for the proces-
sing market.  These acreage estimates were added to the appropriate fresh
market acreages to represent the 1973 total harvested acres.

     The estimated total acreage of these crops that would have been treated
is about 124,000 acres or about 2.4% of the national acreage of these crops.
There is no acreage indicated for brussels sprouts or garlic because both of
these crops are produced entirely in California.

     The acreage figures in Table HID.26 should not be taken as being in
any way as price estimates.  They are merely the best estimates based on the
extremely limited data available.  Furthermore, even these rough estimates
do not take into account the fact that some of the treatment in 1971 may
have been for insects not at issue in the hearings.  These estimates also do
not reflect the decline in DDT that would likely have continued even if it
had not been cancelled.

Yield changes .since DDT cancellation

     Considerable research has failed to uncover any studies which document
per acre yield changes due to the inability to use DDT on the contested crop
uses.  DDT has not been the standard insecticide treatment for purposes of
efficacy comparisons in these crops since the mid-1960's.  Data from this
time cannot be used today because of the rapid changes in insect resistance
conditions that have occurred.  About the best that can be done is to com-
pare reported average yields and production for these crops before cancel-
lation with those since the DDT cancellation.  While changes in yield and
production cannot be shown to be casually related to the loss of DDT, these
changes may help evaluate Hoffman's claim that "if growers are unable to
have the use of DDT, they will be unable to produce these crops (on USDA's
essential list)" (Tr:1891).

     Table HID.27 presents the comparisons of pre- and postcancellation
yields and production.  The precancellation figures are the averages of the
1968 through 1972 average national yields and production, whereas the post-
cancellation figures are the averages of 1973 and 1974 yields and production.
The comparisons for sweet corn are for fresh market only, and the figures for
lettuce are only for fall lettuce in the Northeast (i.e., New Jersey).  Brus-
sels sprouts and garlic do not appear in the comparisons because all of their
production was in California and changes in yields and production could not
be related to the DDT cancellation.  The postcancellation figures for peanuts,
potatoes, and dry beans are for 1973 only, and those for lima beans were not
available.

     As Table HID.27 shows, total production has increased in five of the
crops, and per acre yield has increased in 6 since the DDT cancellation took
effect.  Average yields of cauliflower declined 9.8 cwt  (about 10%) while
                                     -210-

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Table HID.27
                     Production and Yield of Contested Crops
                                  US 1968-1974
Production
Crop 1968-1972 1973-1974 Differ-
(million cwt) ence
Sweet corna./ 12.8
Peanuts]!/ 28.7
Cabbage 23.3
Cauliflower 2.6
Toinatoesi/ 18.8
Lettuce£/ 0.21
Potatoes^/ 309.5
Snap beans£/ 3.2
Dry beansk/ 17.5
13.3
34.5
24.4
2.9
19.7
0.16
297.4
3.0
16.8
+0.5
+5.8
+1.1
+0.3
+0.9
-0.05
-12.1
-0.2
-0.7
Yield

1968-1972 1973-1974 Differ-
(cwt/acre) ence
69.6 77.5
19.6 23.0
215.6 226.0
98.8 89.0
133.0 149.0
172.0 185.0
225.6 228.0
36.8 35.0
12.5 12.1
+7.9
+3.4
+10.4
-9.8
+16.0
+13.0
+2.4
-1.8
-0.4
—' Fresh market crop only.
b_/ 1973 yield and production only.
£/ Includes only Fall lettuce from the Northeast.
Sources
USDA. Agricultural Statistics
USDA, SRS. Crop Production -
USDA, SRS. Vegetables - Fresh

1973,

1973.
1973 Annual Summary,
Market
- 1974 Annual

1974.
Summary, 1974.


                                    -211-

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yields of snap beans and dry beans declined very slightly.  Production
declines in potatoes, snap beans and dry beans were nominal.  However,
the decline in fall lettuce equalled 28% of the 1968-1972 average.

     Again, there is no way to determine the degree to which any of the
yield or production .effects may have been caused by loss of DDT.  So
many factors such as temperature, rainfall, levels of insect and disease
infestation, and others influence crop yields and production that the
impact, if any, of DDT alone is impossible to separate.  Furthermore,
there is no way to determine whether DDT was even used in the areas in
which these declines took place.  About the most that can be said is that
farmers have continued to produce the contested crops despite loss of DDT.
Yield and production of most of the crops has actually increased since
cancellation, and there is no evidence that the declines which have oc-
curred are due to EPA's cancellation of DDT.

Changes in insecticide costs

     Another measure of the economic impact of the DDT cancellation is
through the changes in insecticide costs to farmers.  Farmers previously
using DDT had to switch to some alternative insecticide or other means
of pest control.  These alternative controls may cost more per pound, may
be applied at different rates per acre, and may require more applications
per year than DDT.

     Several difficulties arise in actually attempting to compute these
cost effects.  There are considerable differences across the country in
amounts and frequency with which DDT was applied.  Identifying the alter-
natives used in place of DDT is also difficult.  State insect control
recommendations provide a clue to the alternatives, but they are not
always indicative of what is actually used.  Even if per acre cost changes
can be estimated, there still exists the uncertainty as to the total number
of acres on which this cost change would occur.

     A rough estimation of these costs has been attempted and is shown in
Table HID.28.  The rate and frequency of DDT applications have been as-
sumed based on the testimony at the DDT hearings of entomologists Joseph
Capizzi, Dr. Stuart Race, and Dr. William Eden (Tr, 1972).  The alternative
insecticides and their rates of application have been based on surveys of
recent state insecticide recommendations for the crops and pests under
consideration.  It has been assumed that the alternatives would be applied
with the same frequency as DDT (Brogdon, personal communication, 1975).
The costs of alternatives are the average of the prices from two pesticide
dealers, one on the East Coast (Agrotec, Inc., 1973) and one in the Mid-
west (E-Z Flow Chemical Company, 1973).  The price of $1.27 per pound
active ingredient for DDT is the price paid by farmers in Washington and
Idaho for DDT in 1973 to control the pea leaf weevil under a temporary
emergency use permit.  This price is assumed to approximate the price that
would have been paid by most farmers in 1973.
                                    -212-

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   Table  HID.28
i
K3
                                 Estimated  Changes in  Insect  Control  Costs, US  1973  Basis£/
Pounds
of DDT
Per Acre
Crop Application
Sweet corn
Peanuts
Cabbage
Cauliflower
Tomatoes
Lettuce
Potatoes
Snap beans
Dry beans
Lima beans
1
10
1
1
1
1
6
1
1
1
DDT
DDT Cost
Applications Per
Per Season Acre
5
1
3
3
3
3
1
3
3
3
$ 6.35
12.70
3.81
3.81
3.81
3.81
7.62
3.81
3.81
3.81
Pounds of
Substitutes
Per Acre
Application
Carbaryl
Me thorny 1
none listed
Dylox
Toxaphene
Dylox
Toxaphene
Carbaryl
Toxaphene
Carbaryl
Phosdrin
Dyfonate
Diazinon
Carbaryl
Carbaryl
Carbaryl
Substitute
Substitute Cost
Applications Per
Per Season Acre
2
0.45
1
3
1
3
2
2
2
0.75
4
4
2
2
2
5
NA
3
3
3
3
1
3
3
3
$11.95
NA
6.90
6.90
5.94
11.22
12.92
8.04
8.04
8.04
Change in
Cost
Per
Acre
$+5 . 60
NA
+3.09
+3.09
+2.13
+7.41
+5.30
+4.23
+4.23
+4.23
Estimated
Total Change
in Cost
$+99,800
NA
+24,700
+ 618
+30,885
+ 6,700
+173,300
+ 2,500
+119,700
+ 5,100
+460,700
  .  a/    See text  for sources  and derivation.

-------
     The table indicates that based on the above assumptions, per acre
costs for insect control on the contested crops increased between $2.13
and $7.42 when DDT could no longer be used.  Multiplying these per acre
cost increases by the acreage estimates in Table HID.26 will give a
very rough estimate of the total increase in farmer pesticide expendi-
tures brought about by the loss of DDT.  The total increase in insecti-
cide costs are estimated to be about $460,700, at 1973 prices.  For the
individual crops the total estimated cost increases range from about
$600 for cauliflower to $173,300 for potatoes.  There is insufficient
data to attempt any discussion of the regional distribution of these
costs.

     It should again be emphasized that these dollar values cannot be
taken as precise estimates of impact.  They merely serve to demonstrate
the order of magnitude of the economic effects of the DDT cancellation
and not the actual values of these effects.  Accurate specification of
the economic impacts requires much more data than presently exist.

Conclusion

     1.  The consolidated DDT Hearings brought out limited
         information relating specifically to economic con-
         sequences of a DDT cancellation on minor use crops,
         i.e., limited estimation of production yield and
         price effects on these crops.

     2.  Based on estimates of DDT use, only about 2.4% of
         the national acreage of these crops would have been
         treated with DDT had it not been cancelled.

     3.  National average yields per acre have increased in
         six of the nine crops and total production has in-
         creased in five of the crops since the cancellation
         took effect.

     4.  It is estimated that insect control costs to farmers
         have risen somewhat due to DDT cancellation.  The
         estimated total cost increase for these contested
         uses is $400,000-$500,000.  It is possible that the
         cost impact in this range is more than offset by
         production increases in other crops, their neu-
         tralizing overall impact on the consumer.

     5.  Available information indicates that farmers have
         been able to continue producing the contested crops
         since DDT was cancelled.  There have been some
         slight-to-moderate declines in production, none
         directly attributable to loss of DDT.
                                    -214-

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SWEET POTATOES, SWEET PEPPERS, AND ONIONS
          Administrator's Finding:  Adequate substitute chemicals,
          namelyj methyl parathion and other organophosphates—
          for the most part—exist for...crops except:  sweet
          potatoes, heavy infestations of corn borer attacking
          sweet peppers grown on the Delmarva Peninsula,  and
          onions attacked by cutworms.
     The Administrator found that DDT may be the only useful treatment of
sweet potatoes in storage, and for control of European corn borers attacking
sweet peppers on the Delmarva Peninsula and cutworms attacking onions.
Final cancellation of this use was not ordered by the Administrator in
June 1972 because of questions about the supply of these crops, registration
of alternatives and so forth could be resolved during a transitional period.

Data as of 1972

     The Administrator based his finding that DDT may be necessary for these
three uses primarily on the fact that no party had demonstrated that any
alternative insecticides were registered.  While Toxaphene and diazinon were
registered for general cutworm control, it was not clear whether this in-
cluded registration for control of cutworms on onions (Ruckelshaus, 1972).

Sweet potatoes

     Testimony indicated that DDT was the only registered insecticide that
would satisfactorily protect stored sweet potatoes from attack by sweet
potato weevils.  Dr. Dale Newsom, an entomologist from LSU, testified that
Imidan is a satisfactory alternative (Tr:2397), but it was not regis-
tered at the time of the hearing.  No clear information on the quantities
of DDT use on sweet potatoes was reported.

Sweet peppers

     The hearings brought out that the European corn borer is an important
pest of sweet peppers on the Delmarva Peninsula that are grown almost
entirely under contract to H.P. Cannon and Sons, a vegetable processor.  In-
festations of corn borers higher than 10% rendered the peppers unsuitable
for canning and, therefore unsalable for the farmers.  Carbaryl was regis-
tered for corn borer control, but a Delaware entomologist testified  (Tr:
1623-1671) that will not work during heavy infestations.   He also
testified that Furadan (carbofuran) was a completely acceptable alternative,
but at the time of the Hearing it was not registered for this use.
                                     -215-

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Onions

     Little evidence was presented concerning cutworm control in onions.
An entomologist from Oregon testified (Tr:2775-2831) that DDT was
the best cutworm control for onions, but this use of DDT was not included
in the state insect control recommendations.  He testified that the results
of a USDA survey indicated that the only state with cutworm problems on
onions was California.

Data since 1972

Sweet potatoes

     The 1971 USDA pesticide survey data indicated some use of DDT on
stored sweet potatoes.  The survey reported that DDT was used on 127 mil-
lion pounds of sweet potatoes in 1971.  Since total production in that
year was 1.17 billion pounds (USDA, 1973), about 10.8% of the sweet
potato crop was treated.

     At the time of the hearings, there were no acceptable registered sub-
stitutes for DDT, but since the cancellation EPA has registered Imidan for
sweet potato weevil control.  Since Imidan has the same effectiveness as
DDT for this use (Tr:2397) the cancellation should have had no effect on
sweet potato production.  Sweet potato production in 1973 was down 5% from
the average level of the 5 previous years but this is less than the aver-
age annual variation in production within this period (USDA, 1973).

     No information is currently available on the differences, if any, in
the cost of sweet potato treatment between Imidan and DDT.  Any cost dif-
ferentials should, however, be small, since DDT was only applied at a rate
of 5 Ibs active per 1,000 bushels.

Onions

     Since hearing testimony brought out that cutworms were only a problem
on onions in California there should have been little, if any, impact from
the 1972 cancellation decision.  The California pesticide use report (1973),
indicates that only 50 acres of onions were treated with DDT in 1972.  This
represents only 0.2% of the onion acreage in that state.  The economic im-
pact of loss of DDT from this acreage would be clearly negligible.

Sweet peppers

     According to Dr. Paul Burbatia (personal communication, 1975), a wit-
ness at the DDT Hearings and probably the leading expert on this use, there
are about 4,000 acres of green peppers (also known as sweet peppers or bell
peppers) in the Southern New Jersey and Delmarva area.  DDT was used
                                    -216-

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throughout this area for control of the European corn borer.  The Uni-
versity of Delaware includes green peppers as one of the crops in its
Pilot Pest Management Program.  The reports for 1972 and 1973 (Graustein
et al, 1973 and 1974) are available and provide a contrast between pest
control costs before and after DDT was cancelled.

     In the 1972 pest control program,  European corn borers were controlled
with DDT.  12,127 pounds active ingredient of DDT were applied to 1,100
acres at a cost of $7,158.  The average DDT cost to farmers was, there-
fore, $6.51 per acre.

     In the 1973 program Furadan (carbofuran) was used for European corn
borer control.  Furadan is a systemic insecticide, usually formulated as
a 10% granular, and needs only be applied twice during a season, compared
with 3-5 times for DDT.  In this year, 4,165 Ibs (active ingredient)  of
Furadan were applied to 850 acres at a cost of approximately $21,658
(based on the 1973 price for Furadan 10G of $0.52/lb).   The average cost of
European corn borer control in 1973 was approximately $25.48 per acre.

     Cancellation of DDT and subsequent substitution of Furadan increased
costs of corn borer control by about $18.97 per acre for a season.  For
the approximately 4,000 acres involved in the contested green pepper use
the total increase in pest control costs were about $75,800.  Even this
figure probably overstates the cost impact had DDT not been cancelled.  It
is likely that the price of DDT would have risen along with other pesti-
cide costs, decreasing the difference between its price and that of Furadan.

     Dr. Burbatis indicated that Furadan can be used with no declines in
green pepper yield from the levels when DDT was used.  He did indicate,
however, that in the first year after cancellation, 1973, there was an
unexpectedly large infestation of armyworms which had apparently previously
been controlled with the DDT.  This infestation caused some loss in yields
in 1973, but farmers were ready for the armyworm population in 1974 and ex-
perienced no adverse effects on yields.

Conclusion

     1.  The Administrator's finding with respect to DDT use on
         stored sweet potatoes is probably no longer valid.
         Imidan, not registered at the time of the Hearings,
         has since been registered and is an acceptable alter-
         native to DDT.

     2.  The need for DDT to control cutworms on onions is re-
         stricted to California.  Since DDT was used on only a
         very small number of acres there the impact of cancel-
         lation has been negligible.
                                   -217-

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         Loss of DDT for use on green peppers has had little
         adverse impact on growers in the Delmarva area because
         Furadan has been registered for the European corn borer,
         The primary impact has been on insecticide costs which
         have increased about $76,000 over the whole region.
MILITARY USE OF DDT
          Administrator's Findings:  DDT is used for exter-
          minating bats and mloe by the military,  a)  Fumi-
          gation and nondhemiadl methods can guard against
          bat infestations,  b)  Warfarin is effective for
          exterminating house mice.

     The Administrator found that acceptable alternatives are available for
the military uses of DDT.  These include all military uses that are not for
the purpose of health quarantine.

Data as of 1972

     Very little information was generated at the DDT Hearings regarding the
use of DDT by the military.  The only quantitative data involved a statement
by Col. Fowler of the Armed Forces Pest Control Board to the effect that the
military used only about 800-900 Ibs for bat and mouse control (Ruckelshaus,
1972).  There were no data presented concerning the efficacy or costs of al-
ternative means of pest control.

Data since 1972

     In cooperation with OPP/EPA the Armed Forces Pest Control Board is in
the process of preparing a short statement on the military uses of DDT and,
to the extent possible, on the impact of the cancellation.  This statement
has not yet been completed.
PUBLIC HEALTH
          Administrator's Finding;  DDT is considered useful
          to have in reserve for public health purposes in disease
          vector control.

     The Administrator found that DDT is useful to have in reserve for public
health purposes in disease vector control.  The cancellation order exempted
public health and quarantine uses by official government agencies.
                                    -218-

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Data as of 1972

     The Hearings revealed that DDT was no longer the primary insecticide
for disease vector control in this country.  However, no quantitative
data on use were produced.  The main emphasis on DDT use in vector control
was the worldwide dependence on DDT as an inexpensive method of malaria
and typhus control.  The international use was not really relevant to the
hearings since domestic cancellation had no effect on DDT production for
the export market.

Data since 1972

     The cancellation of DDT had virtually no effect on the public health
uses since they were exempted from the order.  The cancellation may have
made DDT somewhat more difficult to obtain for public health agencies.

     According to Dr. Darsie of the Public Health Service,  Center  for Dis-
ease Control (personal communication, 1975), DDT is very seldom used in
this country for vector control.  It is used for lice control, but even
then in only a few states.  Most body lice are controlled with either a
lindane or a malathion preparation (Pratt and Littig, 1973).  No figures
could be obtained on the extent of current DDT use for public health
purposes.

Conclusion

     DDT is of minor importance for public health vector control in this
country.  Furthermore, if an emergency arises, DDT may still be used by
public health officials.
                                   -219-

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PEA LEAF WEEVIL

     The use of DDT against the pea leaf weevil was not considered at the
DDT hearings but subsequently was the subject of a special request for use,
which was granted for the 1973 and 1974 growing seasons.

     As a result of the work done under the limited use registration,
alternatives have been tested and registered, making it no longer necessary
to use DDT, as discussed in more detail below.

     Since 1970, an area of Northern Idaho and Eastern Washington which
produces 95 percent of America's dried peas has been subject to economically
critical infestations of the pea leaf weevil.  The only effective control
for this weevil had been DDT.  The growers commission involved (Washington
and Idaho Dry Pea and Lentil Commission) felt that the cancellation of this
use of DDT placed dried pea production in serious economic jeopardy.  As
permitted under FIFRA, through regulations promulgated in the Federal Register
on January 9, 1973, parties may petition for special use exemptions to a
cancellation or a denial of registration of a pesticide.

     With the support of the dry pea industry in the states of Idaho and
Washington, the Crop King Chemical Company petitioned the Administrator of
EPA on December 13, 1972, requesting permission for a registration to employ
DDT on dried pea acreage in the infested areas of their states.  Following an
EPA review of the matter, the Administrator determined that the use of DDT
was indeed critical for pea leaf weevil control because of the economic
importance of the industry and the absence of viable substitutes.  On
April 27, 1973, EPA granted the request by the Crop King Chemical Company for
a temporary registration of DDT for use against the pea leaf weevil.  The use
exemption was implemented and then officially expired August 1, 1973.

     With the support of the industry, Crop King Chemical Company again
petitioned the EPA for a DDT use exemption on January 25, 1974.  On
February 15, 1974, EPA convened a public hearing in Spokane, Washington to
review much of the petition.  On February 22, 1974, the application was
approved for 90 days' DDT use during the 1974 growing season.  The approval
was based on a determination that in absence of alternative controls, DDT
control of the pea leaf weevil was indeed economically critical.  The decision
was based on evidence presented by the growers indicating losses of 600 to 800
pounds per acre would be incurred in absence of pest control.  This is quite
large given average yields range from 1200 to 1600 pounds per acre.

     Whereas barley can be grown in place of dry peas, based on February, 1974
prices, the comparative value of barley was $101 per acre and for dry peas was
$380.  This represents a marginal difference of $279.  Moreover, from an
agricultural standpoint, it was revealed that dry peas have proved to be far more
effective than spring barley as a cover crop to prevent soil erosion, which is
a chronic problem in the rolling terrain of the region.  In addition, dry peas
provide nitrogen to the soil, thus reducing the fertilizer requirements of the
winter wheat crop; in contrast, spring barley is nitrogen depleting.  Finally,
it was revealed that this region not only supplied the majority of the U.S.
                                   -220-

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demand for dry peas during the previous two years, but it supplied 13 to
15 percent of world market.   Thus, with as much as 70 percent of the crop
going to export markets, there were obvious balance of payment considerations.

     The exemption was granted, provided that pea growers and the pesticide
industry (with assistance of EPA and university scientists)  would launch a
scouting program designed to monitor and reduce the amount of DDT released
into the environment.

     Operationally, the weevil scouting involved sifting soil and young pea
shoots from sample rows and counting weevils.  Aerial spraying of DDT was
limited to fields or parts of fields, where the weevil count per plant
exceeded a predetermined economically critical threshold.  By this procedure,
scouting records were available to determine which fields should be sprayed.
Only about 12 percent of some 89,000 acres surveyed were certified for
spraying.

     The scouting program provided protection at minimum spray costs to the
farmer and, at the same time, afforded an opportunity for further testing of
three chemicals — methoxychlor, Imidan, and malathion ULV — which had shown
some promise as alternatives to DDT.  Other possible alternatives to DDT were
tested in 1974 as well.  This was accomplished on a matching fund basis with
the Washington and Idaho Dry Pea and Lentil Commission, USDA, and EPA each
supplying partial funding.

     The program subsequently established that Imidan and methoxychlor are
viable substitutes for DDT.   They are now registered and are being employed
during the 1975 growing season.  Further match-funding research for DDT
alternatives is being conducted during the current fiscal year in order to
explore other chemical and biological control possibilities.
                                    -221-

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                               REFERENCES


Agrotec, Inc.  1973 Price List.   Salisbury,  Maryland, Agrotec,  Inc.,  1973.

Agrotec, Inc.  1974 Price List.   Salisbury,  Maryland, Agrotec,  Inc.,  1974.

Barry, R.M.  Personal communication,  University of  Georgia,  Coastal Plains
  Experiment Station, 1975.

Brogdon, J.  Personal communication,  University of  Florida,  1975.

Burbatis, P.P.  Personal communication,  University  of Delaware, 1975.

California Department of Food and Agriculture.   Pesticide  Use Report  1970.
  Sacramento, California, Department  of  Food and Agriculture, 1971.

California Department of Food and Agriculture.   Pesticide  Use Report  1971.
  Sacramento, California, Department  of  Food and Agriculture, 1972.

California Department of Food and Agriculture.   Pesticide  Use Report  1972.
  Sacramento, California, Department  of  Food and Agriculture, 1973.

California Department of Food and Agriculture.   Pesticide  Use Report  1973.
  Sacramento, California, Department  of  Food and Agriculture, 1974.

Darsie, R.F.  Personal communication, US Public Health  Service, Center  for Disease
  Control, 1975.

Deer, J.A.  Personal communication, Texas  A&M University,  1975.

Dibble, J.  Personal communication, University  of California, San  Joaquin
  Valley Agricultural Research Center, Parlier, California,  1975.

E-Z Flow Chemical Company.  1973 Price Book. Dayton, Ohio,  E-Z Flow  Chemical
  Company, 1973.

E-Z Flow Chemical Company.  1974 Price Book. Dayton, Ohio,  E-Z Flow  Chemical
  Company, 1974.

Graustein, M.R., et al.   Delaware Pepper Pest Management Pilot  Program  First
  Annual Report.  Newark, Delaware, University  of Delaware,  Cooperative Ex-
  tension Service, February  15,  1973.

Graustein, M.R., et al.   Delaware Pilot  Pest Management Annual  Report.   Newark,
  Delaware, University of Delaware, Cooperative Extension  Service, February 1,
  1974.

Hofmaster, R.  Personal  communication, Virginia Truck and  Ornamentals Research
  Station, 1975.

Insect Control Recommendations from California, Washington,  New Mexico,
  Louisiana, New York, New Jersey, New Hampshire, Connecticut,  Massachusetts,
  Delaware, Virginia, and Maryland.

                                   -222-

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Johnson, F.A.  Personal communication, University of Florida,  1975.

Lilly Co., The Charles H.  1974 Price Book.  Portland, Oregon, The Charles
  H. Lilly Co., 1974.

Miller, R.L.  Personal communication, Ohio State University, 1975.

Pratt, H.D., and K.S. Littig.  Lice of Public Health Importance and Their
  Control.  Atlanta, Georgia, US Department of Health, Education,  and Welfare,
  Center for Disease Control, 1973.

Race, S.R.  Personal communication, Rutgers University, 1975.

Ruckelshaus, W.D.  Coahoma Chemical Company et al, and Environmental Defense
  Fund, et al, vs. William D. Ruckelshaus, et al, Brief for Respondents,  in
  the US District Court of Appeals for the District of Columbia Circuit,  1972.

Ruckelshaus, W.D.  Opinion of the administrator and order, in re Stevens
  Industries, Inc., et al.  Presented at Public Hearings on DDT, Transcript,
  Environmental Protection Agency, Washington, D.C., June 2, 1972.

Scott, H.E.  Personal communication, North Carolina State University, 1975.

Sweeney, E.M.  Hearing examiner's recommended findings, conclusions, and
  orders.  Presented at Public Hearings on DDT, Transcript, Environmental
  Protection Agency, Washington, D.C., April 25, 1972.

Tr   Public Hearings on DDT, Transcrip^. Office of the Hearing Clerk, Environ-
  mental Protection Agency, Washington, D.C., 1971-1972.

US Department of Agriculture.  Agricultural Statistics 1969.  Washington, D.C.,
  US Government Printing Office, 1969.

US Department of Agriculture.  Agricultural Statistics 1972.  Washington, B.C.,
  US Government Printing Office, 1972.

US Department of Agriculture.  Agricultural Statistics 1973.  Washington, D.C.,
  US Government Printing.Office, 1973.

US Department of Agriculture, Economic Research Service.  Unpublished data -
  from 1971 survey of farmers' pesticide use, 1974.

US Department of Agriculture, Economic Research Service.  Farmers' Use of
  Pesticides in 1971 - Quantities.  Washington, D.C., US Department  of
  Agriculture, 1974.  [AER 252]

US Department of Agriculture, Economic Research Service.  Quantities of
  Pesticides Used by Farmers in 1964.  Washington, D.C., US Department of
  Agriculture, 1968.  [AER 131]

US Department of Agriculture, Economic Research Service.   Quantities of
  Pesticides Used by Farmers in 1966.  Washington, D.C.,  US Department  of
  Agriculture, 1970.  [AER 179]
                                 -223-

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US Department of Agriculture, Pesticide Regulation Division.   PR Notice 70-19.
  Washington, D.C., US Department of Agriculture,  August 18,  1970.

US Department of Agriculture, Statistical Reporting Service.   Crop  Production
  1973 Annual Survey.  Washington, D.C., US Department  of Agriculture,  1974.
  [CrPr 2-1 (74)]

US Department of Agriculture, Statistical Reporting Service.   Vegetables  -
  Fresh Market - 1974 Annual Summary.   Washington, D.C., US Department  of
  Agriculture, 1974.  [Vg2-2 (74)]

US Environmental Protection Agency.  Public Hearings on DDT,  Admission  1,
  Office of the Hearing Clerk, Environmental Protection Agency,  Washington,
  D.C., 1972.

US Environmental Protection Agency.  Public Hearings on DDT,  Admission  6,
  Office of the Hearing Clerk, Environmental Protection Agency,  Washington,
  D.C., 1972.

US Environmental Protection Agency.  Public Hearings on DDT,  Admission  7,
  Office of the Hearing Clerk, Environmental Protection Agency,  Washington,
  D.C., 1972.

US Environmental Protection Agency.  Public Hearings on DDT,  Admission  11,
  Office of the Hearing Clerk, Environmental Protection Agency,  Washington,
  D.C., 1972.

US Environmental Protection Agency, Office of Pesticide Programs.  PR Notice
  71-1.  Washington, D.C., Environmental Protection Agency, January 15, 1971.

US Environmental Protection Agency, Office of Pesticide Programs.  PR Notice
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University of Arizona, Department of Entomology.   Agricultural Use  of
  Pesticides in Arizona.  Tucson, Arizona, University of Arizona, July  31,
  1974.
                                   -224-

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                             FOREST USES OF DDT
HISTORY OF USE ON FOREST PESTS
     Among the many insect pests which prey upon North American forests, two
groups account for the overwhelming majority of tree losses:  defoliators,
and bark beetles.

     In the discussion which follows, major attention will be given to de-
foliating insects, since bark beetles, because of the location of their
attacks, are not amenable to control by mass spraying methods.  While the
discussion is intended to generalize about defoliators, it is recognized
that exceptions are common and most of these are noted for the three major
pests discussed.

Bark beetles

     Several species of bark beetles attack numerous forest tree species,
especially conifers.  Adult beetles typically penetrate the outer bark,
laying eggs in or near the soft inner bark which hatch into feeding larvae.
The larvae consume the inner bark while protected by the outer bark, often
girdling and killing the tree.  Several species of bark beetle attack
already weakened or dying trees and are considered secondary pests.  A few,
e.g., the southern pine and mountain pine beetles, may become primary
killers when epidemic populations develop.  DDT has never been an important
control agent for bark beetles.

Defoliators

     The overwhelming majority of forest tree defoliation results from the
attacks of insects in two orders:  Lepidoptera, mostly moths and a few but-
terflies; and Hymenoptera, principally sawflies.

     The larvae of defoliating moths and sawflies feed on the needles and
leaves of many important trees.  During the period 1945-1972, efforts to
control defoliating forest pests were mounted on nearly 30 million acres of
US forests.  On almost 95% of this area, control efforts were directed at
four defoliating moths:  the western budworm; gypsy moth; spruce budworm;
and Douglas fir tussock moth (Sartwell and Alligood, 1974).

     The population dynamics and feeding patterns of these moths make them
ideally suited to control by aerially applied insecticides.  The typical
pattern of population development is for the insect to maintain endemic low
levels of population for periods of several years, then for reasons yet un-
known, to develop epidemic numbers, usually in localized areas which may
persist for 3 years or longer.  During the epidemic population phase, the
                                    -225-

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larval stage feeds on the foliage of host trees in large numbers frequently
causing complete defoliation in a matter of weeks.  The emergence of the
larvae of most species is timed to coincide with the production of new foli-
age during the late spring and early summer.  New foliage is usually consumed
first.  In most cases, the larvae complete their growth at about the time
defoliation is complete.  They then change to the pupal stage for a period of
one or more weeks emerging in summer as adults, completing the life cycle by
reproducing and laying eggs.

     During the outbreak phase, epidemic attacks are usually quite localized.
However, migration for some distances is possible during both the early
larval and adult stages when insects may be carried long distances by pre-
valing air currents (adult female gypsy moths are flightless).  The gypsy moth
may also be distributed into new areas by the transport of egg masses on
recreation vehicles.  Adult moths seek out any convenient protected surface
and frequently attach their egg masses to camping vehicles during late June.
Thus, new localized outbreaks may occur many miles apart expanding in size
over succeeding years of population buildup.  Because large numbers of in-
sects are concentrated on relatively small areas aerial detection is quite
often possible.  Since the timing of egg hatching and larval feeding can be
predicted, foresters are able to anticipate the timing of control sufficiently
in advance to plan aerial spray control efforts.  Egg hatching may vary over
several weeks in a given attack area.  Since the purpose of control is to
reduce the amount of defoliation and prevent epidemic buildup, the applica-
tion of the insecticide must be carefully timed to achieve the highest pos-
sible mortality of feeding larvae.  The most severe defoliation (as opposed
to damage) occurs during the last 2-4 weeks of the 3-8 week larval stage.  It
is, thus, easy to understand why persistent pesticides, such as DDT, have
been favorite control tools.  Larvae from late hatching eggs can be controlled
even after the time of application.

Use of DDT prior to 1972

     DDT was relied on almost completely for control of defoliating insects from
 1945 to 1958 .  During those 14 years more than 20 million acres  were aerially
sprayed for the control of some 22 different defoliating pests.  Four of these
pests accounted for nearly 96% of the nearly 30 million acres to which insec-
ticides have been applied for the period 1945-1972 (Sartwell and Alligood, 1974).
Table HID.29 presents the acreage breakdown by chemical agent, showing DDT was
applied to more than 88% of the total.

     Table HID.30 presents the 34 forest insects requiring control efforts during
the period 1945-1972.   Three of these, the western and spruce budworms and the
Douglas fir tussock moth, attack various species of spruce, the true firs, and
Douglas fir.  The gypsy moth attacks a wide variety of trees, feeding most
heavily on oaks.  This moth was introduced at Medford, Mass, about 1869, by a
French naturalist who had intended to cross it with the silkworm.   During the
next 40 to 50 years, the moth spread gradually throughout most of New England
and by 1973 was causing extensive damage in these states as well as New York,
Pennsylvania, and New Jersey (US Forest Service and APHIS, USDA, 1974).
                                     -226-

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Table HID.29
       Materials Aerially Applied to Suppress Forest Insect Populations




                            US Total 1945-1972
Material
(1,
DDT
carbaryl
mexacarbate
malathion
fenitrothion
trichlorfon
Douglas fir tussock moth virus
GardonaiL/
lead arsenate
methoxychlor
phosphamidon
Bacillus thuringiensis
dimethoate
propoxur
Giant Basin tent caterpillar virus
Total
Area
000 acres)
25,713
2,187
550
380
222
51
16
14
9
7
7
5
2
1
1
29,165
Percent
of Total
88.1
7.5
1.9
1.3
0.8
0.2
—
—
—
—
—
—
—
—
—
100.0
       a/  Trademark, Shell International Chemical Co.




       Source:  Sartwell and Alligood, 1974
                                     -227-

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Table HID.30
               Forest Acreage Sprayed for Particular Pests
                           US Total 1945-1972
Insect

Western bud worm
Gypsy moth
Spruce budworm
Douglas fir tussock moth
Pine butterfly
Pitch-pine looper
Fall cankerworm
Jack-pine budworm
Western hemlock looper
Saratoga spittlebug
Great Basin tent caterpillar
Pine tussock moth
Elm spanworm
Blackheaded pine sawfly
Western blackheaded budworm
Redheaded pine sawfly
Saddled prominent
Lodgepole needle miner
New Mexico fir looper
Pine reproduction weevil
White fir needle miner
Grasshoppers
White fir sawfly
Arkansas sawfly
Eastern hemlock looper
Fall webworm
Forest tent caterpillar
Larch sawfly
Loblolly pine sawfly
Lodgepole pine sawfly
Southwestern pine tip moth
Utah cankerworms
Virginia pine sawfly
European pine sawfly
Total
Acreage
(1,000 acres) £/
12,816
12,324
2,113
724
255
239
132
123
104
102
54
41
24
18
16
14
14
13
10
6
5
4
3
2
1
1
1
1
1
1
1
1
1
—
29,165
Percent of
Total
43.9
42.3
7.2
2.5
0.8
0.8
0.5
0.4
0.3
0.3
0.2
0.1
b/
W
b/
b/
b/
b/
b/
b/
b/
b/
b/
b/
b/
b/
b/
b/
b/
b/
b/
b/
i/
—
100.0
a/  These figures may not represent actual acreage, as the same land may
    have been treated more than once in different years.
b/  Less than 500 acres or 0.05%.

Source:  Sartwell and Alligood, 1974.
                                 -228-

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     The most serious effect of defoliation, usually resulting from several
successive years of attack, is the outright killing of the host trees.
Less obvious but extensive damage also occurs from partial defoliation which
often results in top killing.  Damaged trees suffer reduced growth and
vigor making them subject to later mortality from other environmental
agents, especially bark beetles (Wickman et al, 1973).  In general, the
softwoods are less able to withstand repeated defoliation than hardwoods.
Two to 3 years of nearly complete defoliation usually results in the death
of conifers while hardwoods may withstand as many as 6 or 7 consecutive
years of heavy defoliation (US Forest and APHIS, USDA, 1974).

     The development of extensive control efforts since World War II was
made possible by  1) the availability of DDT, a persistent broad spectrum
insecticide, effective as both a contact and a stomach agent; and  2) the
use of aircraft for rapid detection of attacked areas and for rapid, broad
scale application of this inexpensive chemical.  (Gypsy moth detection re-
mains heavily dependent upon ground sampling techniques which include egg-
mass surveys and sex pheromone baited traps.)  Due to reliance upon aerial
detection lower levels of attack not resulting in visible defoliation may
go undetected during the first year.  This has meant that insects have been
able to build up to epidemic proportions before discovery and effect con-
siderable damage before control can be accomplished.  It has been observed
of many forest insect pests that periodic epidemic outbreaks often run their
course in a period of 3-5 years (sometimes longer) in the absence of controls.
The causes for the collapse of epidemic populations are not fully understood.
For example, studies of the Douglas fir tussock moths have identified a virus
disease of these insects which may be responsible, in combination with star-
vation, for the almost complete collapse of large populations in a single
year (US Forest Service, 1975).  Since past control efforts have usually
been mounted only when epidemic numbers are detected, it appears that mas-
sive spraying programs may have been delivered on the target pests during
the decline or collapse phase of the epidemics (Wickman et al, 1973)..  Con-
sequently, it has been very difficult to assign easily measured benefits to
these control programs.

     During the last 10 years, research has been intensified to improve
forest managers' techniques of pest control.  Several aspects of the control
problem have been attacked with limited success.  Earlier detection of incip-
ient epidemic outbreaks is now possible through the use of synthesized sex
attractants, recently developed for the gypsy moth.  They are used to monitor
insect population levels, helping to identify areas of potential build-up in
insect numbers.  In addition, experimental use permits have been issued the
US Department of Agriculture for the aerial application of a synthetic sex
pheromone attractive to the male gypsy moth.  Large acreage applications,
following earlier small plot trials, are being made to substantiate the find-
ing that the presence of the pheromone results in confusion of the male.
This confusion impairs the male's ability to locate a virgin female and re-
sults in reduced mating success.  Other problem areas being researched include
                                    -229-

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the development and wide scale production of disease causing agents specific
to target pests; identification and rearing of parasitic or predacious in-
sects which, if successful, can be introduced into target populations; and
development of chemical insecticides having short residual life and a mini-
mum of unwanted ecological effects.

Alternative controls

     During the period 1945-1958 aerial spraying efforts to control defo-
liating insects relied almost exclusively on DDT (Table HID.31), but
included two minor applications of lead arsenate (9,000 acres, 1945) and
malathion (4,000 acres, 1957).  Of the nearly 26 million acres of DDT appli-
cations which ended in 1967, 78% occurred prior to 1959 (Sartwell and Alli-
good, 1974).  In 1959, there began a major shift to carbaryl and other agents.
Use of carbaryl has risen gradually over the years as the use of DDT was
phased out by 1967.  The last major application of DDT was in 1974 for the
control of the Douglas fir tussock moth, under an emergency exemption granted
by EPA, March 5, 1974.  In the face of a large and apparently expanding epi-
demic of these insects and lacking any registered substitute control, the
US Forest Service, together with the States of Oregon and Washington and
private landowners applied DDT at the rate of 0.75 Ibs/acre to approximately
430,000 acres.  Experimental tests of lower application rates for DDT and
tests of other control agents were also conducted, as directed by EPA (EPA,
1974b).

     Four other chemicals have been used with varying success:  malathion
(extensively, 1963-1966); mexacarbate (Zectranl/), used in token amounts until
1972 when 500,000 acres were sprayed; fenitrothion (1968 and 1970) (Sartwell
and Alligood, 1974); and trichlorfon (US Forest Service, 1974 and 1975).

     The decline in DDT usage was coincident with increased reliance on
several more environmentally favorable control agents.  Table HID.32 shows
comparisons between DDT and the major alternatives.  Malathion was also used
on extensive acreage.

     In a final environmental statement for a proposed spruce budworm sup-
pression project, the US Forest Service summarized the findings of five
studies on the efficacy of malathion against the spruce budworm.  It was con-
cluded that "malathion can be used safely in the environment and that it will
have no significant effects on man or other animals when suitable aerial
spraying precautions are taken.  However, malathion has not demonstrated con-
sistently satisfactory control at the registered dosage."  Use of malathion
on forest pests has been minimal in recent years (US Forest Service, 1974).
Of the six alternatives (some of which are not currently registered for con-
trol of forest defoliators), four are chemical insecticides:  carbaryl,
mexacarbate, fenitrothion, and trichlorfon; and two are biological control
agents (Bacillus fhurlngiensis and Polyhedrosis viruses).  Bioethanomethrin
and resmethrin synthetic pyrethroids also have shown promise as controls for
I/  Tradename, Dow Chemical Co.
                                     -230-

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        Table IIID.31
i
N)
                                  Forest Area  (1,000 acres). Aerially Sprayed with Insecticides in the United States
Year
1945
1946
1947
1948
1949
1950
1951
1952
1953
1954
1955
1956
1957
1958
1959
1960
1961
1962
1963
1964
1965
1966
1967
1968
1969
1970
1971
1972
1973C/
1974£/
DDT
7
64
533
218
661
1,548
1,105
880
700
1,733
3,653
2,306
4,898
1,773
216
430
218
1,592
2,074
632
363
	
100
	
	
	
	
	
	
240
Carbaryl

	
	
	
	
	
	
	
	
	
	
	
	
	
86
11
29
31
130
97
234
275
203
201
95
233
390
172
47
91
Mexacar-
bate
___
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
	
5
3
7
16
	
19
500
504
469
Mala-
thion

	
	
	
	
	
	
	
	
	
	
	
4
	
3
1
5
	
	
	
	
	
	
10
	
212
	
	
22
11
Fenitro- Trichlor-
thion fon
___ __
	 	
	 	
	 	
	 	
	 	
	 	
	 	
	 	
	 	
	 	
	 	
	 	
	 	
	 —
	 	
	 	
	 	
	 	
	 	
	 	
	 	
	 	
10 39
6
212 3
	 	
	 3
125
77
DFTM Bacillus Otherk/
virus*./ thuringiensie
	 	 g
	 . 	 	
	 	 	
	 	 	
	 	 	
	 	 	
	 	 	
	 	 	
	 	 	
	 	 	
	 	 	
	 	 	
	 	 	
^ *
	 	 	
4 	 4
	 	 7
	 	 	
12 	 20
	 2 2
	 1 1
	 	 	 .
	 	 2.
^ 1
10
3
	 	 1
	 2 2 ,
	 — _ _ 2
15 4
Total
16
64
533
218
661
1,548
1,105
880
700
1,733
3,653
2,306
4,902
1,774
305
450
259
1,623
2,236
733
599
280
307
268
127
663
410
679
700
907
        Total    25,944
2,325
1,523
268
                                         222
                           253
                                            16
                                                        20
68
30,639
        a/  Douglas fir tussock moth virus.
        b/  Trichlorfon, Lead Arsenate, Methoxychlor, Phosphamidon, Dimethoate Propoxur, GBTC Virus, Gardona
            (Trade name, Shell International Chemical Co.).
        cj  These figures are for fiscal years 1973 and 1974.  The DDT application for the Douglas fir tussock
            moth extended into FY 75, covering a total of about 430,000 acres.
        Sources
        Sartwell and Alligood, 1974  (calendar years 1945-1972).
        US Forest Service, 1974 and 1975  (fiscal years 1973 and 1974).

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Table IIID.32
              Comparison of DDT and Alternative Controls on Major Forest Defoliating Insects

Registration
Spruce budworm
Gypsy moth
Tussock moth
Availability
Persistence
Chemical cost
($/A)
Total costfy
ro ($/A)
1^1
i
DDT
No
No
No
NAW
Several
years
$1.00
$3.00

Carbaryl
Yes
Yes
No
Limited
2 weeks
$1.50
$3.50

Mexacarbate
Yes
No
No
Unavailablec/
2 days
$1.68
$3.68

Bacillus
EPa/
Yes
No
Good
Several days
to 2 weeks
$9.00
$11.00

Polyhedrosis
Virus
No
No
EPa./
Limited
I/
Unknown^/

Fenitrothion
Yes
No
No
Limited
2 weeks
$1.10
$3.10

Trichlorfon
No
Yes
No
Good
1 week
$3.38
$5.38

a/ EP - An experimental permit has been granted by EPA.
b/ Montrose Chemical Co. produces DDT for export purposes.
cj Dow Chemical Co.  was the sole producer of mexacarbate (Zectran - registered trademark).  The product is no
   longer produced due to the limited market.
d/ Virus persistence and spread is dependent on biological  and environmental factors.
ej The virus is in the developmental stage.
f_/ Total cost includes the application cost  assumed to be $2/A.  This assumes maximum economies of scale in
   large area applications.  Smaller areas require higher per acre application costs.

Sources

Registration:   Registration Division, Office of Pesticide  Programs, EPA.
Availability:   Hofacker, 1975.
Persistence:    US Forest, 1972a, and Northeastern Regional Pesticide Coordinators, 1972.
Chemical Costs: The Charles H. Lilly Co., 1974.

-------
tussock moth but much further testing of formulations and application tech-
niques must be done (EPA, 1974a).

     The shift from DDT to alternatives can be characterized by a changeover
to non-persistent control agents.  DDT is very broad spectrum, affecting
many non-target insects and other organisms.  Carbaryl and fenitrothion are
also broad spectrum to a degree but their low persistence allows nontarget
species to recover to near normal levels in a short time (US Forest Serv-
vice, 1974).

Problems

     At present, no one alternative is registered for all three major forest
pests.  There are currently no registered products available for use against
the tussock moth, although an experimental use permit has been issued for
polyhedrosis virus.  Of the alternative controls, only mexacarbate is now
unavailable.  Dow Chemical Company was the only manufacturer and ceased pro-
duction in 1972 due to the limited and highly uncertain market for the com-
pound.  Carbaryl and fenitrothion are available in limited amounts due to
allocation programs following the shortages of many pesticide compounds in
the previous two years.  Other biological controls are essentially in the
developmental stage and it is doubtful that commercial quantities would be
available for widespread use if needed on short notice.

BENEFITS OF CONTROL

     The benefits of control are entirely due to preventing or reducing the
loss of living trees.  Primary losses result from reduction in commercial
wood supply, loss of valuable esthetic trees, and major changes in some
ecosystems.  Secondary losses result from disruption of normal harvesting
of timber and management of forests, as well as the consequent economic and
social losses occurring to the dependent communities.  These and other losses
are discussed further.

Timber losses

     The most obvious impact of epidemic defoliation is the killing of com-
mercially valuable trees.  Areas attacked may suffer losses varying from 5-
100%.  Individual areas may vary from a few to several hundred acres.  Sal-
vage of this killed timber is often feasible where sufficient quantities
per acre are harvested, providing the harvest occurs promptly after death.
Prompt salvage of all killed timber is almost never possible and recovery
may be limited to 50% or less.  There are several reasons for this.  Many
areas requiring salvage are inaccessible until roads are built to serve them.
The economics of harvesting is closely related to the amount of wood har-
vested per acre.  Harvesting of small volumes per acre where mortality is
light is uneconomical particularly where new roads must be built.  Where
large volumes are involved, but are scattered or patchy within a single
                                     -233-

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timbershed (area serving a processing center), the time required for major
salvage may exceed the durable life of the dead timber.  In northern timber
areas of the United States, where the most serious epidemics have occurred,
trees usable for sawtimber may remain salvageable for up to 3 years.  In
the south most dead trees have lost salvage value after 1 year.  Trees, in
the north, salvageable for pulping may last for 6 or 7 years for some
species.  In all cases, there is a gradual deterioration in value over time.
In many cases, the delayed mortality of trees initially weakened by partial
defoliation, further increases the amount of unrecovered loss.

     A less obvious, though possibly as serious a loss, may occur from the
reduction in growth rate in many young trees not killed.  Repeated defolia-
tion, even partial, reduces new wood formation during the attack year and
for several subsequent years.  Where repeated partial defoliation affects
wide areas of poorly stocked stands, the loss represents a sizable reduc-
tion in forest productivity and becomes serious where young, immature stands
are affected.

Disruption of harvesting and management

     As indicated, the costs of harvesting dead or injured trees is usually
considerably higher than normal harvesting costs.  Combined with this is the
continued deterioration in the value of the salvaged wood.  At some point
these combined losses exceed the value of the wood delivered for processing.
The pace of harvest is necessarily limited by the processing capacity within
hauling distance of the affected forest and/or the pace of road building.
Where processing plants run continuously on raw material from salvage oper-
ations, the quality of their product is necessarily lowered.  Marketing this
lower quality material may seriously affect the profit position of the mills.

     The saw and pulp mills may be required to run at an accelerated pace,
requiring additional labor for the period of salvage.  This may result in
overtime payments to regular workers, and possibly the importation of workers
for extra shifts.  A short-term stimulating effect on local employment and
business may follow; however, a long-term reduction of timber supply can
result in future curtailment of economic activity in these communities.

     Disruption in the management of a forest property results in both short-
and long-term effects.  An epidemic insect attack may require that all man-
agement personnel and equipment be involved in control efforts.  Other nor-
mally scheduled activities such as timber sale preparation, tree planting,
and fire suppression are temporarily suspended.  The consequent organization
of salvage activities further interferes with the conduct of normal manage-
ment functions.  Extensive areas of dead and dying timber also increase the
hazard of explosive, highly destructive wild fires.  The threat of catas-
trophic loss from wild fire may continue for several years requiring addi-
tional equipment, personnel, and preparation.  Layout and construction of
access roads to effect salvage of killed timber will require extra efforts
and personnel during the period of salvage.
                                     -234-

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     Long-term effects on systematic management of forests are more subtle.
Forests, fully organized to provide a sustained level of annual Harvests,
require a fairly-even distribution of areas in progressive stages of growth
from seedlings to mature trees.  Very few forests in the United States,
particularly in the West, have yet achieved this degree of organization.
Under an ideal forest organization, areas to be harvested in a given year
would consist of one or a few sizable blocks of timber which could be har-
vested with a minimum of new road building or maintenance.  Where insect
attacks result in widely scattered, small areas of liquidated forests re-
placed by new established stands, future management efforts, including
eventual harvests, are further complicated and correspondingly costly.  Aside
from these complications, the overall management of the forests may be dis-
rupted seriously only when these attacks result in an overbalance of young
stands in relation to juvenile and mature timber.  Many, if not most, of the
western forests, particularly public forests, have a serious overbalance of
mature timber.  Accelerated harvest and replacement of older stands on these
forests results in accelerated forest growth by replacing old, slowly growing
forests with young ones.  To the extent that this condition exists, the future
productivity of these forests may, in fact, be increased rather than decreased.
Thus, it is entirely possible that, provided localized timber losses are of
principally mature timber and are not too severe, the dependent mills and
local communities may suffer little if any long-term loss in stability.

Effects on other values

     The effects on wildlife from epidemic losses of 'timber are directly re-
lated to the patterning of timber kills.  Extensive areas of killed timber
which is later salvaged, will provide a new habitat of low vegetation attrac-
tive to grazing animals and the smaller herbivorous forms.  To the extent that
this habitat has been scarce, it may provide a very attractive food source for
several big game species.  These areas would likewise provide increased range
forage for livestock where this is an important forest use.

     Watershed values are particularly important in western mountainous
forests.  Much water useful to man is derived from forested watersheds.  This
yield of water is heavily dependent upon the accumulation of snowfall during
the winter months.  It is well established that clearing or partial clearing
of timber increases the accumulation of snowpack and consequent water yield
from-watersheds.  However, these increased water yields may be delivered
through snowmelt resulting in increased flooding and damage.  The effects of
clearing and increased snowpack on the dry season (summer and fall) water
yield is less clear.  Where watersheds have been cleared extensively, there
appears to be a reduction in dry weather yield of water.  Where clearing is
patchy and partial, it is possible that the total yield of usable water may
be increased without serious loss of dry season flows.

     The losses in esthetic values from defoliation, temporary or permanent,
is felt most heavily in developed recreation areas and homesites.  Loss of
shade and visual beauty during the summer months may reduce use and enjoy-
ment.  These effects have been particularly serious in eastern states.  .
                                   -235-

-------
attacked by the gypsy moth and occasionally by.the spruce budworm.  Fortun-
ately, recreation areas are generally accessible, frequently visited, and
as a consequence, usually receive early control efforts to reduce losses. .
In this connection, there- are additional effects from the attack of both tus-
sock moth and the gypsy moth. .Since these pests attack heavily during the
recreation season, their presence, is distasteful to visitors and the larvae  .
may cause allergic reactions in some people.  Workers on the earliest salvage
of tussock moth-killed timber are also hindered by this.nuisance.

Measurement of benefits                          ..  .    .

     Estimates of the expected benefits from control have, been made for a
number of recent control projects and are incorporated in the environmental
impact statements.  However, these estimates are very difficult to document
since little serious effort has been directed at evaluating the impacts of
past epidemic insect attacks.  As indicated, the nature of damage is highly
varied and the extent of damage may be serious in a given situation.

     Estimates of the timber damage prevented are uncertain for a number of
reasons.  The .effects of man's efforts to control epidemic insect populations
is complicated by his inability to predict the development or collapse of the
pest population.  As described, the stage of insect population development.or
possible spread has in many cases defied our best efforts at prediction.  The
widespread incidence of the virus disease of the Douglas fir tussock moth has
been associated with the onset of the decline phase of an outbreak.  However,
other factors not yet understood also seem to contribute to both the spread
and the .collapse of epidemic, populations.               .               ...

     Tree mortality as a result of defoliation is somewhat predictable within
wide confidence limits.  The possible recovery of trees from multiple years
of defoliation appears to be highly dependent upon the weather, patterns of
succeeding years.  When attack-free years, following the first, or second year
of defoliation are characterized by mild temperatures and ample moisture,
tree recovery may be the rule.  However, initial recovery may leave trees in
a condition of ^reduced vigor, making them susceptible to .attacks by secondary
pests especially bark beetles (Wickman et .al, 1973).  Thus, mortality over
several succeeding years may be higher than would be true in nonattacked
stands.         .           ,                                   .

     Reductions in growth of immature stands t:hrough partial defoliation may
be only temporary.  Where.this is combined with scattered mortality in dense
stands, the surviving trees may experience stimulated growth in succeeding
years equal to or exceeding the growth of nonattacked stands (Wickman and
Scharpf, 1972).  Thus, the prediction of growth loss becomes.highly complex
and dependent in part on future weather patterns.

     Evaluation of higher harvest cost losses due to salvage activity
together with the reduced value of products can be more easily estimated
once the extent of salvage has been determined.  Once again, the. orderly
                                   -236-

-------
progress of. .salvage activities, in part weather-dependent, must be assumed
in order to estimate the maximum amount of salvage from the total .recovery
program.  The impact on local communities providing the labor for proces-
sing plants can be estimated given.certain assumptions concerning the mar-
ket, salvaged material, and the extent and duration of the. salvage program.  ..
Since markets for wood products, especially lumper, fluctuate widely with
the prosperity of the housing and,construction market, the salability and
price of these products determine the level and stability of employment in
these processing plants.  To date only limited efforts have been made to
estimate these employment effects directly traceable to epidemic insect
attacks and consequent salvage operations (USFS and APHIS, 1974; EPA,  1974b).

     The effects, both short- and long-term on forest management have been
described.. No known effort has been made to quantify these effects (McCay
and White, 1973).

Measurement of other values

     Very little effort is directed to evaluation of insect epidemic attacks
on wildlife, watershed, or esthetic values.  The Forest Service, Regions II
and IV—' have attempted to evaluate the impact of past epidemics of defoli-
ating insects in the inter-mountain region on losses to recreation, wildlife,
and timber values.  The value of residential property losses has been esti-
mated based on number of trees, expected mortality,-lot size and value (McCay
and White, 1973).

     In order to provide additional information on the benefits of control of
the tussock and .gypsy moths, a study has been funded to evaluate benefits of
DDT and other controls of these two pests.  This study is conducted under an ,
EPA/USDA interagency agreement at a level of effort of $320,000, is now
underway and will be completed in 1977.  It is expected to significantly add
to the other research USDA/FS is doing in the area of costs and benefits of
control of forest insect pests.

FEDERAL POLICY ON USE OF PERSISTENT PESTICIDES

US Department of Agriculture                                             .

     In 1964, the Secretary of Agriculture issued a memorandum urging dis-
continuation of u^e of. persistent pesticides (USDA, 1964).  The expressed
concern for environmental effects was particularly directed at the wide-
spread use of DDT.

     Over the next 4 years, the Forest Service was actively testing a number
of substitute chemicals, while attempting to phase out the use of DDT.  In
_!/  Region II includes South Dakota, Nebraska, Kansas, Colorado, and part of
Wyoming.  Region IV includes Nevada, Utah, and parts of Wyoming and Idaho.
                                    -237-

-------
1969, the Secretary of Agriculture issued Memorandum number .1666, (USDA,
1969) directing that persistent pesticides will not be used except when
no alternatives are available.  It also directed that pest control actions
emphasize the use of integrated pest management strategies and, where
chemical pesticides were required, they should be nonpersistent formula-
tions.  The Cooperative State Research Service was directed to encourage
research on nonpersistent  pesticides and biological controls.

     In 1973, the Secretary of Agriculture issued a replacement memorandum
for the 1969 policy statement.  This memorandum repeated several policies
enunciated earlier and further emphasized the Department's dedication to
research into effective biological, cultural, and integrated pest control
materials and methods.  It also pledged the Department to cooperate with
other public and private organizations in the development and evaluation
of pest control materials and methods, assessment of benefits and potential
hazards in control operations, monitoring for pesticide residues, and dis-
semination of pesticide safety information.  Department users of pesticides
were strongly urged to heed label directions and exercise constant care in
pesticide application, storage, and disposal for the protection of people,
animals, and our total environment (USDA, 1973).

     The US Forest Service has been involved in most forest pest control
activities conducted by states or private owners.  The Forest Pest Control
Act of 1947  (16 USCA Sections 594 et seq.), administered by the Forest
Service, instituted a program of surveying pest hazards and provided fifty
percent cost sharing for control of insect pests on state and private own-
erships.  This program enabled private owners and the states to participate
in control activities at the reduced costs made possible by large scale
control operations.

US Department of the Interior

     Several of the Services and Bureaus of the Department of the Interior
are concerned with management of wild lands, management of water resources,
or both.  In 1964, Secretary Udall issued a policy memorandum discontinuing
use by.Department agencies of chlorinated hydrocarbon pesticides.  In 1970,
Secretary Hickel issued a more comprehensive policy statement.  Attached to
this statement is a list of prohibited chemicals and another list of re-
stricted control agents.  No agency of the Department was permitted to use
any pesticide on the prohibited list, including DDT (USDI, 19)70).

     Thus, by 1970, the two Federal departments which had major responsi-
bilities for land management and concern for water quality had discontinued
or severely restricted the use of persistent pesticides, including DDT.
This was two or more years prior to the EPA order cancelling most uses of
DDT.  Thus, these issues were not addressed by the cancellation order.
                                   -238-

-------
Conclusion

     DDT was widely used against defoliating forest insects through the
mid-1960's.  However, both USDA and USDI discontinued use of DDT and
other chlorinated hydrocarbon insecticides, as a matter of policy, by
the late 1960's because of concern for environmental effects.  There
are registered alternatives to DDT for the spruce budworm and the gypsy
moth, but none for the tussock moth.

     An experimental use permit has been issued by EPA for use of Poly-
hedrosis virus against the tussock moth.  EPA also authorized emergency
use of DDT against this pest in 1974.

     Benefits of control of forest insect pests by alternative means
have been evaluated to some extent but further evaluation is in process
via a study under a USDA/EPA interagency agreement.  This study is
scheduled to be completed by 1977 and will enhance our ability to
quantify these benefits.
                                  -239-

-------
                               REFERENCES
Hofacker, T.  Personal communication, US Forest Service,  February 21,  1975.

Lilly Co., The Charles H.  Personal communication,  The Charles H.  Lilly
  Company - Miller Products, Agricultural Chemicals,  Portland, Oregon,
  November 1974.

McCay, R.E., and W.B. White.  Economic Analysis of  the Gypsy Moth Problem in
  the Northeast, Applied to Commercial Forest Stands.  Upper Darby,
  Pennsylvania, US Forest Service, US Department of Agriculture,  1973.
  INE-275]

McCay, R.E., and W.B. White.  Economic Analysis of  the Gypsy Moth Problem in
  the Northeast, Applied to Residential Property.  Upper  Darby, Pennsylvania,
  Forest Experiment Station, 1973.  IdraftJ

Northeastern Regional Pesticide Coordinators.  Pesticide  Information Manual.
  1972.

Sartwell, C., and D. Alligood.  Aerial Insecticide  Application Against Forest
  Insects in the United States, 1921-1972.  1974.  [draft]

US Department of Agriculture.  USDA policy on pest  control.   Secretary's
  Memorandum, No. 1565, December 23, 1964.

US Department of Agriculture.  USDA policy on pesticides.  Secretary's
  Memorandum, No. 1666, October 23, 1969.

US Department of Agriculture.  USDA policy on pest  control.   Secretary's
  Memorandum, No. 1799, February 1, 1973.

US Department of the Interior.  Department of the Interior  Responsibilities
  and Policy on Pesticides.  Washington, D.C., US Department of the  Interior,
  Office of the Secretary, June 12, 1970.

US Environmental Protection Agency.  Use of DDT to  control  the Douglas fir
  moth - Order on request for an emergency exemption.  Fed.  Register 39(4),
  March 5, 1974b.

US Environmental Protection Agency, Hazardous Materials Control,  Acting Assistant
  Administrator.  DDT and the Tussock Moth.   Washington,  D.C., Environmental
  Protection Agency, 1974a.  [Memorandum dated February 19,  1974]

US Forest Service.  Douglas Fir Tussock Moth Research and Pilot Test Program,
  Season of 1974.  Interim Report.  Portland, Oregon, Pacific Northwest Forest
  and Range Experiment Station, 1975.

US Forest Service.  Final Environmental Statement:  Cooperative Spruce Budworm
  Suppression Project, Minnesota, 1974 Activities.  Northeastern  Area, State and
  Private Forestry.  Washington, D.C., US Department  of Agriculture, 1974a.
                                    -240-

-------
US Forest Service.  Pesticide Use Report — Fiscal  Year  1973.  Washington, D.C.,
  Forest Pest Control Division,  US Forest Service,  US  Department  of Agriculture,
  1974b.

US Forest Service.  Pesticide Use Report — Fiscal  Year  1974.  Washington, D.C.,
  Forest Pest Control Division,  US Forest Service,  US  Department  of Agriculture,
  1975.

US Forest Service and Animal and Plant Health Inspection Service.  Final
  Environmental Statement Cooperative Gypsy Moth Suppression and  Regulatory
  Program, 1974 Activities.  Washington, D.C., US Department of Agriculture,
  1974.

Wickman, B.E., and R.F. Scharpf.  Decay in White Fir Top — Killed by Douglas
  Fir Tussock Moth.  Portland, Oregon, Pacific Northwest Forest and Range
  Experiment Station, 1972.  tPNW-133]

Wickman, B., R.R. Mason, and C.G. Thompson.  Major  Outbreaks of the Douglas
  Fir Tussock Moth in Oregon and California.   Portland,  Oregon, US Forest
  Service, US Department of Agriculture, 1973.  [PNW-5]
                                     -241-

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  ENVIRONMENTAL  PROTECTION


                AGENCY
      (I. P. ft R. Dockets Noa. 63. etc.]

   CONSOLIDATED DDT  HEARINGS

      Opinion  and Order of  the
             Administrator
  Published herewith to my opinion and
order Issued June 14,  1972,  concerning
the registrations of products containing
the Insecticide  DDT.
  Done this 30th day of June 1972.
           WILLIAM D. RUCKILSHAUS,
                        Administrator.
      STKVXNB INDUSTRIES, INC., rr IL.
      OPINION or THE ADMINISTRATOR
  Before  the   Environmental   Protection
Agency: In re:  Stevens Industries, Inc., et
aL (Consolidated DDT Hearings), I.F. & R.
Docket No. 63 et al.
  This hearing represents the  culmination
of approximately 3  yean of Intensive  ad-
ministrative Inquiry Into the uses of DDT.
Part I seta  forth the background of these
proceedings and  Part II  contains a  discus-
sion of the evidence and law and my  factual
conclusions. I am persuaded for reasons set
forth  in Part III of this opinion that  the
long-range risks of continued use of DDT
for use on cotton and most other crops Is
unacceptable and outweighs any benefits.
Cancellation  for all  uses of DDT for  crop
production and nonhealth purposes Is here-
by reaffirmed and will become effective De-
cember  31, 1972. In accordance with  Part V
of this  opinion  and the accompanying or-
der, except that  certain uses, for green  pep-
pers,  onions, and sweet potatoes  In  storage
may  continue on terms and conditions set
forth  In Part V of this opinion and the ac-
companying order.
  I—A. Background.  DDT  Is the familiar
abbreviation for  the chemical  (l.l.l.trichlo-
rophenyl ethane), which was for many yea.3
the most  widely used chemical pesticide in
this  country. DDT's  Insectlcldal  properties
were originally discovered, apparently by ac-
cident, In 1939, and during World War  II It
                                                            I  A.
                                                         APPENDIX
was used  extensively for typhus  control.
Since 1945, DDT has  been used for general
control  of  mosquitoes, boll weevil  Infesta-
tion In  cotton-growing areas, and a variety
of other uses. Peak use of DDT occurred at
the end of the 1960's and present domestlo
use  of  DDT  In various  formulations  has
been estimated at  6,000 tons per year.1 Ac-
cording  to  Admission 7 of the record, ap-
proximately 86 percent or 10,277.258 pounds
of domestically used DDT Is applied to cot-
ton  crops.  The same admission Indicates
that 603,053 pounds and 937,901 pounds, or
approximately 5 percent  and  9 percent of
the total formulated by 27 of the petitioners
In these hearings  nre used respectively on
soybean and peanut crops. All other uses of
the 11,966,196 pounds amount to 158,833 of
the total, or  little over l percent.*
  Counsel  for the  Agency has called to our
attention publication  of the Department of
Agriculture. The Pesticide Review of  1971,
which estimates "a domestlo disappearance"
rate of  25,457.000 pounds for DDT In  1970.
See  p.  28.  The motion to Incorporate this
publication Is granted, as Is the motion by
registrants  to supplement the  record, see
Infra. I do not believe,  however, that the
Pesticide Review figure can be  accepted, on
Its face, without further explanation. Since
the result I reach today would. If anything,
only be reinforced  by the higher figure,  I
see no need to remand.
  For the above uses It appears that DDT Is
sold In four different  formulations:  Emulal-
flable sprays; dust; wettable powder; and
granular form.
  Public concern over the widespread use of
pesticides  was stirred by Rachel  Carson's
book, "Silent  Spring," and a natural out-
growth was the Investigation of this popular
and  widely sprayed chemical.  DDT, which
for many years had been used with apparent
safety,   was,  the  critics  alleged, a  highly
dangerous substance which killed beneficial
Insects, upset the natural ecological balance,
and collected In the food chain, thus posing
a  hazard to  man,  and other forms of ad-
vanced aquatic and avlan life.  In 1969, the
U.S.  Department of Agriculture commenced
a review of the health and environmental
hazards  attendant  to the use of DDT.
  Certain uses of DDT were canceled by the
Department of Agriculture In 1969  and In-
formal  review of remaining uses continued
through 1970.* In  early  1971,  this Agency
commenced formal administrative review of
DDT registrations by the cancellation  of all
registrations  for  DDT products  and  uses
pursuant to section 4(c)  of the Federal In-
secticide, Fungicide,  and Rodentlclde  Act
(FIFRA) 7  U.S.C.  section 135 (1972).'
  1 Admission 6  shows that domestic ship-
ments of DDT  by Its sole  manufacturer,
Montrose  Chemical  Co.,  totaled  8,827,900
pounds between January 1 and  August 1,
1971.  Total domestic  sales  In  1970  were
11,966,196, as stipulated In Admission No. 7.
The  Examiner found,  apparently based on
Admission 7, that domestic use In 1970  "was
just under 12 million pounds." Exam. Report
at 92.
  •Some discrepancy  In the figures exists
since  the figures given In breakdown of use
categories total. 11,977,065  pounds,  slightly
more  than the total sold by the 27 formula-
tors who supplied figures.
  •PR Notice  69-17.  Among the canceled
uses  were applications to trees for control
of Dutch Elm disease, tobacco, home  uses,
and aquatic uses. 34 F.R.  18827 (1969).
  •In Environmental Defense Fund v. Ruc-
kelshaus, 439 F.  2d 584 (D.C.  Clr.  1971), the
court of appeals held that cancellation  pro-
ceedings should  be  commenced  whenever a
registration  of  a pesticide raises a "sub-
stantial question of safety" which warrants
further study. On Jan. 15, 1971, all uses of
                                                                                                                         133«Gi)

                                                                                        B. Statement of the case. This hearing la
                                                                                      the final stage of formal administrative re-
                                                                                      view.' Thirty-one registrants have challenged
                                                                                      15 of the canceled uses of DDT and Its me-
                                                                                      tabolite. TDE.« These use* of DDT Include
                                                                                      applications to cotton fields  to  control  the
                                                                                      boll  weevil  and  bollworm  applications  to
                                                                                      various vegetable  crops, and a variety  of
                                                                                      lesser uses In public  programs. The case for
                                                                                      cancellation has been presented by counsel
                                                                                      for the Pesticides Office  of the  Environ-
                                                                                      mental Protection Agency and attorneys for
                                                                                      the Environmental Defense Fund  which Is
                                                                                      an  Intervenor. Other purtles  Include  Ell
                                                                                      Lilly & Co..  which held a DDT  registration
                                                                                      for "topocide." a  prescription drug,' R. P.
                                                                                      Cannon & Son. a user of  DDT,* and repre-
                                                                                      sentatives of the  chemical manufacturing
                                                                                      Industry and various wildlife groups."
                                                                                        The testimony  and exhibits cover In ex-
                                                                                      haustive fashion all aspects of DDT's chemi-
                                                                                      cal and lexicological properties. The evidence
                                                                                      of record, however, Is not so extensive con-
                                                                                      cerning the benefits from  using DDT, and
                                                                                      most of It has been.directed to the  major
                                                                                      use,  which Is on  cotton crops."
 DDT not canceled In  1969  were canceled.
 PR Notice 71-1. And on Mar. 18, 1971. notices
 of cancellation were Issued for all registered
 uses of TDE, a DDT metabolite. PR Notice
 71-5.
  •Under FIFRA  a registrant Is entitled to
 either a public hearing or a scientific advisory
committee or both to review his registration.
Pending completion of  that  review, a reg-
 istrant Is allowed to continue shipment of his
product.
  1 Unless specified, discussion of DDT In this
 opinion applies to TDE. DDT has three major
 breakdown products,  DDA, DDE,  and DDD;
 separate registrations exist for TDE (DDE).
  ' There has been some controversy over Ell
 Lilly's status because It failed to appeal can-
 cellation of Its registration within 30 days
 as required by section 4(c) of FIFRA. For the
 purposes of this case I believe they should
be accorded status as parties.
  •There has been some question as  to
whether or  not a  "user"  has standing to
appeal  a cancellation and thus  seek rein-
 statement of a canceled use even though no
registrant has stepped forward to appeal. The
 same reasoning  employed- by the court In
Environmental Defense Fund v. Ruckelshaus,
supra, and Environmental Defense  Fund v.
 Hardln. 428 F. 2d 1093 (D.C. Clr. 1970). which
accords standing to "public Interest" groups
gives "users" a right to appeal a cancella-
 tion.
  •The  groups  are:  National Agricultural
 Chemicals  Association;   National  Audubon
Society; The Sierra Club; and West Michigan
Environmental  Action Council.  As  already
noted, the Secretary of Agriculture,  In addi-
tion to being a party-registrant by virtue of
registrations  held by Its Plant Regulation
Division, has appeared as an Intervenor.
  "The following uses are Involved: For cot-
 ton; for military use on clothing; for peppers
 and pimentos; for fresh market corn; for pea-
nuts; for  cabbage, cauliflower, and brussel
 sprouts; for tomatoes; for lettuce; for pota-
 toes; for sweet potatoes hi storage (Southern
 States only); for use In commercial green-
 houses and  nurseries; for beans (dry, lima,
 cnap); for bat and rodent control; for emer-
 gency use for agriculture, health or quaran-
 tine purposes; and for onions and garlic; and
for lice control. There has been considerable
controversy as to  what uses  were  at Issue
during the hearing. Admission No. 3 sets
forth those uses which  the Department of
Agriculture considers essential. Many of those
uses have been canceled and  no appeal was
taken. The uses at Issue In this hearing are
only  those  noted In Admission 11.
                                    FEDERAL REGISTER, VOL 37,  NO. 131—FRIDAY, JULY 7,  1972
                                                            -243-

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l.'MTO
  The  Pesticides  Office and  Environmental
Defense Fund  (EDP),  In  presenting  their
case* against continued registration for DDT,
lean most heavily on evidence which, they
contend, establishes:  (1) That DDT and Its
nv.'tabolites  are  toxicants  whinn persist In
soil and the aquasphere; (2) thut once un-
leased, DDT Is an  uncontrollable chemical
which  can be  transported  by it/aching, cro-
;:on. runoff, and volatlllzntlon:  j;i) that DDT
Is not water soluble and collects In Tut tissue:
(1) that organisms tend to oillnct, and ci-u-
ceutrate DDT;  (6) that these qualities result
In accumulations of  DDT lu  wildlife and
humans: that once stored or consumed. DDT
can be toxic to bcth animals and humans,
rr. d  In the cas» of  fish and  wildlife Inhibit
;• prr.<-rauon o;  species; and (7) thut the
r"'iieli!S accruing from DDT  usage :ire m:u-
glnal, given the availability of alterj'.ntlve In-
•ectlcldes  and pest management  programs,
:"id  also tbe fact that crops produced with
JJDT are In ample supply. The testimony and
exhibits Include numerous reports of expert
scientists who have described  observed effects
cf DDT lu the environment and the labora-
tory.
  Group Petitioners and the U.S. Department
of Agriculture (USDA) seek to discredit the
Agency's case by  citing the record of safety
DDT baa compiled throughout the years, and
point to the negative  findings of epldemlo-
loglcal and  human feeding  studies carried
out over the years on Industrial workers and
volunteers exposed to concentrated levels of
DDT far In excess of that to which the aver-
age Individual Is exposed. Proponents of con-
tinued  registration have  also  Introduced
expert  testimony to the effect that DDT's
chronic toxlclty  to  man or animals has not
been  established by adequate proof. The
registrants nave  attacked the assumption
that laboratory data, as to effects of exag-
gerated doses of  DDT, can provide a mean-
ingful  basis for extrapolating effects on man
or  the environment.  In  tbe alternative,
Group Petitioners  contend  that whatever
barm to the environment might be attributed
to DDT, It  results from misuse and over-
dosing that occurred  In years past.  Lastly,
Group Petitioners and UBDA  have attempted
to prove that  DDT Is  effective and that its
use Is  more desirable than the organophos-
phates which  are  more acutely  toxic and
costly than DDT.
  On April 26, the Hearing Examiner Issued
an opinion  with  proposed findings, conclu-
sion*  and orders  recommending  that  all
"essential" uses of DDT be  retained and that
cancellation be  lifted."  The Examiner's re-
port which has findings, conclusions, and an
opinion, Is  attached below.  The Examiner
apparently  accepted  In  his  report the
Agency's  proof  that  DDT is  a hazard to
aquatic and terrestrial wildlife and substl-
t'.ues exist. He found,  as a "matter of fact,"
DDT can  have adverse effects  on beneficial
animals; that It  Is transferred through the
food  chain;  that DDT Is fat soluble. He
concluded, however, as  s  "matter of law,"
that DDT is neither a carcinogen nor terato-
gen, that the particular uses at Issue do not
adversely affect  wildlife, that DDT use has
rapidly declined. (Examiner's Rept. p. 93.)
  The Pesticides Office of this Agency and
Intervenor   Environmental   Defense   Fund
(EOF)  filed exceptions  to the Examiner's
report," challenging his application of the
burden of proof to this case, his findings  of
fact, conclusions of law, and numerous evi-
dentiary  rulings. Exception was also  taken
to  the  Examiner's application  of the so-
railed "risk  and  benefit" standard of FIFRA.
  On May 2, 1072, the Judicial  Officer pro-
pounded  by order, at my direction,  a  series
of qm*M lulls for  briefing and discussion  at
cvnl argument, and oral argument was held
»".  May 16.  That argument was transcribed
:,ud Is part of this record. Group Petitioners,
USDA,  EH Lilly,  and H. P. Cannon & Sons
have  also   responded  to  the  briefs  on
exceptions.
  II.—A. Applicable law. The basic FIFRA
scheme has  been outlined In court opinions
and Agency  decisions (see EDF v. EPA, D.O.
Clr. Slip. Op. 71-1365, ....... P.  3d	,
May 6, 1972  (opinion of Judge Leventhal);
Stearns Elec. Paste Co. v. EPA, 7th Clr. Slip
Op. No. 71-1112,	P. 2d	, May 11,
1972; Continental Chemlste Co. v. EPA, 7th
Cir. Slip Op. No. 71-1828,	P. 2d	,
May 11, 1973; EDF v. Ruckelshaus (opinion
of Judge Bazelon), supra; Statement of Rea-
sons Concerning the Registration of Products
Containing   DDT.   2,4,5-T,  and   Aldrtn/
Dleldrln, March  18. 1972; In re Hart-Karl
Llndane Pellets, et al, I.F.&R. No. 6 (1971)).
While there  Is no need to trace In detail once
again the statutory scheme, a brief  sum-
mary provides a useful prism for filtering toe
evidence.
  1. FIFRA. The  Federal Insecticide, Fungi-
cide, and Rodentlclde  Act,  7 UB.C.  section
136 (1972),  establishes a strict standard for
the registration of pesticides. Any "economic
poison"  which cannot be used without in-
Jury to  "man or  other  vertebrate animals,
vegetation, and useful  Invertebrate animals"
Is "mlsbranded," " and Is therefore  subject
to cancellation."
  " There Is some confusion as to what the
term "essential" means. By Admission No. 2
the parties stipulated that certain uses were
"essential" In the view of USDA. No stipula-
tion exists that these uses are. In fact, essen-
tial  In  that no  alternatives exist  or  that a
shortage of a crop would result without DDT.
  a Exceptions have  also been received  In
Docket  106, In Re Wallersteln. Stark Bros.
Nurseries held a registration for use of DDT
on  nursery plants. The Examiner recom-
mended  cancellation on the  grounds that
this was not an "essential" use according to
USDA.
  "Sees. 2(z)(2)  (c), (d), and (g), respec-
tively provide:
  "The term 'mtebranded' shall apply—
  (a) To any economic poison—
     •       •       •      • •     •
  (c) If the labeling accompanying It does
not contain directions for use  which are nec-
essary and If compiled with adequate for the
protection of the public;
  (d) If the label does not contain a warn-
ing or caution statement which may be nec-
essary and If complied  with adequate  to
prevent  Injury  to living man  and  other
vertebrate  animals, vegetation, and  useful
Invertebrate animals;
     *       •       •      «      •
  (g) If In the case of an Insecticide, nema-
•toclde, fungicide, or herbicide when used as
directed  or In accordance with commonly
recognized practice It shall be Injurious to
living man or other  vertebrate animals, or
vegetation, except. weeds, to which It IB  ap-
plied, or to the person  applying such eco-
nomic poison;
     •       •       •      •      •
  11 Sec. 4 permits the Administrator to can-
cel  a registration "If It  appears  that  'the
article and its labeling • • •'  do not comply
with (the Act)." Since the Act prohibits dis-
tribution of a "mlsbranded" pesticide, sec. 3
(a) (5),  the registration  for a "mlsbranded"
product may be canceled.
  While the language of the statute, taken
literally, requires only a finding of injury to
nontarget species, the inquiry cannot, how-
ever, end with a simplistic application of this
plain statutory language. Both judicial and
administrative precedent recognize that Con-
gress Intended the application of a balancing
test, that would measure the risks of using a
particular chemical against its benefits." If a
product Is "mlsbranded" within the meaning
of the Act, I.e.. If  It bears a label for use that
does not meet the criteria of section 2, It may
no longer be shipped In Interstate commerce
and stocks In hand In the original package
may be seized. 7 TJ.S.C. section 135(g) (1972).
  2. Risks  and benefits. It follows from the
statutory scheme and this Agency's decisions
that evidence of  each  alleged  risk  must be
reviewed  and a  conclusion reached as to
whether or not, and In what degree, such risk
Is Incident to the directed use of a particular
product. The task, however. Is complicated In
the case of a  "persistent"  pesticide by Its
possible chronic effects. The degree of persist-
ence, extent of overall usage and mobility all
bear on the amplitude or Indeed the exist-
ence of  the risk curve.1* I believe,  however, It
Is useful to Isolate the alleged risks and eval-
uate each  on  the assumption that they are
unaffected by overall levels of use, and defer
to Part  IV the discussion of the significance
of the relationship between risk and overall
use.
  III.—A. Analysis of evidence.—1. Risks—a.
Health effects and environmental properties.
There Is no dispute on this record that DDT
Is a  nonspecific  chemical  that  kills both
target and nontarget species in tbe Immedi-
ate area of application. Few chemicals, how-
ever, a,re so selective that they can  be used
without causing some Injury to "nontarget"
species.  We must therefore proceed to the
evidence bearing on other  "risks" and the
"benefits" from using DDT.
  I am convinced by a preponderance of the
evidence that, once dispersed, DDT Is an un-
controllable, durable chemical  that persists
In the aquatic and terrestrial environments.
Given Its Insolubility In water and  Its pro-
pensity to be  stored in tissues, It collects In
the food chain and Is passed  up to higher
forms of aquatic and terrestrial  lite. There
Is ample evidence to show that  under cer-
tain conditions DDT or  Its metabolites can
persist In soil for many years," that It will
volatilize  or move along with eroding soil.19
While the degree of transportability Is un-
known,  evidence  of record shows that  It is
  u See EDF v. EPA (opinion of Judge Leven-
thal), supra; EDF v. Ruckelshaus (opinion
of Judge Bazelon), supra, DDT Statement of
Reasons, supra; see also Statement of Rea-
sons Underlying Suspension and Cancellation
of Products Containing Mercury, 37 FJl. 6419
(Mar. 29,  1972).
  "Other factors bearing on risk may In-
clude the geographical location of applica-
tion, see, e.g., Statement of Reasons Underly-
ing  Registrations for Strychnine, 1080,  and
Sodium  Cyanide,   37  F.R.  5718  (1972),
although this may not be as significant where
the chemical Is highly volatile as Is the cone
with DDT. See also Statement of Reasons
Underlying the Cancellation of Mirex, Deter-
mination  and Order of the Administrator at
7 (37 F.R. 10987, June 1, 1972).
  "Method of  application  and type of soil
and  climate can affect persistence in soil and
likewise runoff  Into aquatic areas.
  u Registrants have made much of the fact
that aquatic contamination and the spread
of DDT have resulted from drift during aerial
application. While  the Examiner's report
dwells at some  length on  Improved methods
of application, it recognizes runoff as a signif-
icant source of aquatic contamination, even
with Improved aerial spraying techniques.
                                    FEDERAL REGISTER,  VOL.  37,  NO. 131—FRIDAY, JULY 7, 1972


                                                            -244-

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occasionally  found In  remote area* or In
ocean cpeclea. such a* whales, far from any
known area of application.
  Persistence  and blomagnlflcaUon tn the
food chain are. of themselves, • CMS* for
concern, given the unknown and  possibly
forever undeterminable long-range effects of
DDT In man, and the environment.1* Lab-
oratory testa have, however, produced tumort-
genlc effects on mice when DDT  was fed
to them at high levels." Most of the cancer
research experts who  testified at this hear-
ing Indicated that It was their opinion that
the tumorlgenlc  results of  testa thus far
conducted are an Indicator of carclnogenlty
and that DDT should be considered a poten-
tial carcinogen."
  Group Petitioners argue  that the testi-
mony Is In conflict and fasten on to the tes-
timony of the Surgeon General that of Drs.
Loomls  and Butler. The Surgeon General's
statement vns,  however, cautious  and, by
no means, carries the burden that the Group
Petitioners seek to place on It. In very gen-
eral terms the Surgeon General stated: "We
have no Information on which to Indict DDT
either as a tumorlgen or as a carcinogen for
man and on the basis now available, I can-
not conclude DDT represents an Imminent
health hazard." (Tr. 1360.)  This testimony,
however, does  not bear on  the long-term
effecta of DDT, nor did the Surgeon General
express a view on what uses,  apart from
health uses, would justify continued use of
DDT. Indeed, the  entire thrust  of the Sur-
geon General's testimony was only  that use
for Immediate  health  needs outweighs the
possible long-range effects of DDT on human
health.  Group  Petitioners' other witnesses,
Drs. Loomls and Butler, while men of stature
In their fields—toxicology  and. pathology—-
and knowledgeable about cancer treatment
and diagnosis, are not specialists In cancer
research as Is Dr. Safflottl. Indeed, Dr. Butler
disclaimed such expertise.
  Oroup Petitioners also take refuge under a
broad  canopy  of  data—human  feeding
studies  and   epldemlologlcal studies—and
  "It  Is particularly difficult to anticipate
the long-range effects of exposure to a low
dose of a chemical. It may take many years
before  adverse  effects would  take  place.
Diseases like cancer have an extended latency
period.  Ifutagenlc  effecta will be apparent
only In future generations. Lastly. It may be
impossible  to relate observed pathology In
man to a particular chemical because of the
Inability to Isolate control groups which are
not exposed In the same degree as the  rest
of the population.              '
  »Tumorlgenlc effects have been noted In
a  number  of laboratory  experiments. The
most  positive results  were developed by the
Blonetlcs Study and  the Lyons and Milan
tests. The  Blonetlcs Study of the National
Cancer  Institute fed  120 compounds to two
strains  of  mice. DDT was one  of  11 com-
pounds to  produce an elevated Incidence of
tumors. The Lyons  and Milan Studies of the
International  Agency  for  Research  of  the
World Health Organization Is a  multlgener-
atlonal study (still In progress) of 6,000 mice
of In- and  out-bred strains. Increased hepa-
tomas were noted  In  male and female mice
fed DDT  at  350  p.pjn. Matastasls  to  the
lungs or kidneys has been recorded In  five
Instances.
  "Witnesses testifying to the positive cor-
relation between tumorlgens and carcinogens
were Dr. Umberto Safflotti, Associate Scien-
tific Director for  Carclnogenesls,  Etiology
Area, National Cancer Institute; Dr. Marvin
Schneldermon,  Associate  Chief,  Biometry
Branch and Associated Director for Demog-
raphy, National Cancer Institute; Dr. Samuel
Epstein, Senior Research Associate in Pathol-
ogy, Children's Cancer Research Foundation,
Inc., Boston.
 support It with  ttie Increasingly familiar
 argument that exposure/ to any substance In
 sufficient quantities may cause cancer.
   None of tb*  feeding  studies carried  out
 with DDT have been designed adequately to
 detect c&rctnogenldty, and given the latency
 period of cancer,  these  studies would have
 to be carried out  for a much longer period.
 Statistical population samples for epldeml-
 ologlcal studies are also virtually Impossible
 given the latency  period for cancer and  the
 long-term exposure of the general popula-
 tion. Since there Is no sharp distinction be-
 tween  population groups  exposed to  low
 doses and higher doses of DDT,  adequate
 control groups  cannot  be  established. The
 "everything Is cancerous argument" falls be-
 cause It Ignores the fact that not all chemi-
 cals fed to animals In equally concentrated
 doses have produced the same tumorigenic
 results.
   b.  Environmental effects. The case against
 DDT Involves more, however, than a long-
 range hazard to man's health. The evidence
 presented  by the  Agency's Pesticides  Office
 and the Intervenors, EDF, compelllngly dem-
 onstrates the adverse Impact of DDT on  fish
 and  blrdllfe. Several  witnesses testified to
 first-hand observed effects  of DDT on  fish
 and  blrdllfe. reporting  lethal or  sub-acute
 effects on aquatic and avlan life exposed In
 DDT-treated  areas. Laboratory evidence Is
 also Impressively abundant to show the acute
 and chronic  effects of DDT on avlan animal
 species and suggest that DDT Impairs their
 reproductive  capabilities.™
   The petitioner-registrants'  assertion  that
 there Is no evidence of declining aquatic or
 avlan populations, even If  actually true, Is
 an attempt at confession and avoidance. It
 does not  refute the basic  proposition  that
 DDT causes damage to wildlife species. Group
 petitioners' argument  that  DDT Is only  one
 toxic substance In a polluted environment,
 and thus,  whatever Its laboratory effects, it
 cannot be shown  to be  the causative  agent
 of damage In nature, does not redeem DDT,
 but only underscores the magnitude of effort
 that will be necessary for  cleaning up  the
 environment. Were  we  forced to  Isolate In
 nature, rather  than In  the laboratory,  the
 effects of various  toxic substances. It would
 be difficult If not Impossible to make a judg-
 ment as to the chronic effects of any chemi-
 cal. As our  DDT  statement of March 1071
 has noted: "Development of  adequate test-
 Ing protocols and facilities  Is a priority  un-
 dertaking. But In  the  short term,  extrapola-
 tion from  small-scale  laboratory analyses
 must err on the  side of safety."  See DDT
 Statement of Reasons, at 11.
   Finally. I am  persuaded that a preponder-
 ance of the evidence shows that DDE causes
 thinning of eggshells In certain bird species.
 The  evidence presented Included  both lab-
 oratory data  and  observational data. Thus,
 results of feeding experiments were Intro-
 duced to show  that birds In the laboratory,
 when fed  DDT, produced  abnormally  thin
 eggshells. In addition, researchers have also
 correlated thinning of shells by comparing
 the thickness of eggs  found In nature with
 that of eggs taken from museums. The muse-
 um eggs show little thinning, whereas eggs
 taken from the wild after DDT use had  be-
. come extensive reveal reduced thickness.
   "See  the  testimony  of  Drs.  Tarzwell,
 Nicholson,  Philip  Butler,  Duke,  Burdlck,
 Dlmond, Rlsebrough, Hlckey, and Cade.
   While the Examiner erroneously excluded
 testimony as to economic losses caused  by
 DDT's  contamination  of the aquatic en-
 vironment—losses to commercial fishermen
 caused by Inability to market contaminated
 fish—this risk Is significant, even If It could
 not be economically quantified. Not all risks
 can be translated Into dollars and cents, nor
 can all benefits be assessed In cash terms.
                                   13371

  Group Petitioners and USDA argue that
the  laboratory feeding studies,  conducted
with exaggerated doses of  DDE and under
stress conditions, provide no basis  for ex-
trapolating to nature. They suggest that the
study results are contradictory  and  place
particular  emphasis  on documents  which
were not part of the  original  record and
the Inconsistencies In Dr. Heath's testimony
as brought out  during cross-examination.
Group Petitioners also contend that  the ob-
served phenomenon of eggshell thinning and
DDE residue data are tied  by a statistical
thread  too  slender to connect  the  two In
any meaningful way.
  Viewing the evidence as a total picture, a
preponderance supports the conclusion that
DDE does cause eggshell thinning. Whether
or not the  laboratory data above would sus-
tain this conclusion Is beside the point. For
here there Is laboratory data and observa-
tional  data, and  In  addition,  a scientific
hypothesis, which  might explain the phe-
nomenon.10
  B. Benefits—l.  Cotton. I am convinced by
the evidence that continued use of  DDT Is
not necessary to  Insure an adequate supply
of cotton at a reasonable cost. Only  38 per-
cent of  cotton-producing acreage Is  treated
with  DDT,  although  the  approximately
10,277.258 pounds used In cotton production
Is a substantial volume of DDT and accounts
for most of Its  use.  The record contains
testimony by witnesses called by registrants
and  USDA  attesting  to the  efficacy of or-
ganophosphate chemicals as  substitutes for
DDT and,  long-range, the  viability  of pest
management methods, such as the diapause
program. At present most  areas  that use
DDT combine It  with an organophosphate
and  toxaphene In a  4-2-1 mixture  (4 Ibs.
toxaphene,  2 DDT,  1  methyl  parathIon).
Some areas, however,  according to the  testi-
mony, which normally use DDT occasionally
apply concentrated methyl  parathlon In a
4-pound mixture.
  There Is evidence that  organophosphates
would  not  raise  costs to  the farmer and
might,  Indeed, be cheaper.  Any suggestion
thnt the  organophosphates  are  not eco-
nomically viable  cannot be  maintained In
face of  the undisputed evidence that cotton
continues to be tenable crop In Arkansas and
Texas where DDT use has declined." There Is
  "The  chief witness Introduced to rebut
Drs. Rlsebrough, Hlckey, and Cade was a
graduate student  with limited  training In
statistical analysis. In view of the credentials
of  EDF's witnesses—Dr.  Hlckey,  Professor
of  Wildlife  Ecology at College  of  Agricul-
ture, University of  Wisconsin; Dr. Rlse-
brough,  Associate  Ecologlst,  University of
California at Berkeley; and Dr. Cade, Pro-
fessor of Zoology  at  Cornell  and Research
Director of Cornell Ornithology Laboratory—
I cannot credit  this attempt  at rebuttal.
  The Hearing Examiner apparently resolved
the conflict In the evidence by concluding
that "there  was no evidence that DDT was
the only factor In a decline of bird popula-
tions •  • •" and that no evidence "focused
Us  direct thrust on damage to birds by the
uses of  DDT that are permitted under the
registrations In  question."  Examiner's  Re-
port, 70-71. In view of DDT's persistence and
mobility, evidence  as  to  the causal effect
of these  uses was not  required.
  At argument and by motion Oroup Peti-
tioners  hare  offered  additional  evidence,
some of which bears on the Issue of eggshell
thinning. I  have granted that motion  and
considered all that data.
  "The  parties have referred  neither In
briefs nor  argument  to  testimony  or  ex-
hibits describing In detnll the economics of
cotton production or  substitutes. There Is
general testimony that cotton producers re-
ceive  a  per bushel subsidy and that  thla
    (Footnote 24 continued on next page)
                                    FEDERAL REGISTER, VOl. 37, NO.  131—FRIDAY,  JUIY  7,  1972
                                                            -245-

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13372

also testimony In the record to the effect that
methyl  porathlon  coeta less per  application
than  the DDT-toxaphene formula. Hoc are
the testimony and exhibits that show cotton
Insect*  develop resistance  to organopho*-
phate chemicals to the point. The very same
exhibits make clear that DDT Is also subject
to resistance .•
  Group Petitioners and  USDA. while  not
disputing the lesser persistence  of organo-
phosphates, have stressed their demonstrated
scute tcxlclty. Wh!'c 'hey ::r^  toxic to bcne-
lu'lnl soil Insects and nori -target species, par-
ticularly birds  alighting  on  treated fields,
these  organophosphates break down more
readily  than  DDT. They apparently are  not
transported In  their toxic state to  remote
n-ear. v:ill'-:e DDT v.'liich hns been  found
tar from treated  areax  ana  consequently
do  not  pose the  same magnitude  of risk
to the aqviasphere. Beth testimony and ex-
hibits  also demonstrate  that organophos-
phates are less  acutely toxic to aquatic life,
although dllTerent compounds have different
toxlcltles.  The   effect  of  organophosphates
on non-target terrestrial life can, unlike the
effects of DDT, also be minimized by prudent
use. Application In known nesting areas for
rare or extinct birds can be avoided.
  2. Other crop and produce uses. The testi-
mony of  record, while sparse, shows  that
registered  alternatives,  primarily  organo-
phosphatea,  exist  for  all other crop  and
ornamental uses of DDT,  except  for storage
use on  sweet potatoes to control  weevils, on
heavy com borer Infestations of  green pep-
pers, and perhaps onions.*1
  3. Noncrop uses. In addition to the regis-
trations for use on  crops and In nurseries,
•everal registrations for noncrop uses are also
In issue. Admission 11  lists  "public  health
pests—bats  and  rodents,"   "Agricultural,
  »—Continued.
subsidy Is the difference between profit and
break-even. It  Is not clear whether or not
break-even  Includes a  return  to the farm
owner In terms of salary  or return on  his
Investment. While  some evidence  suggests
that organophosphates  are more costly, be-
cause of higher price and the need for re-
peated applications In concentrated quanti-
ties, there  Is little to suggest that  the pos-
sible  Increased  variable  cost  from use  of
organophoephates would be a  disincentive
to producers. Indeed, with subsidies It la Dot
clear what rate of return a cotton  producer
receives  for Invested capital. There  was  a
reference made  to  an unidentified  study
showing that the cost  of  using  substitutes
would Involve (16 million. This figure alone
baa no meaning. While later testimony sug-
gesta that  elimination  of DDT would  In-
crease variable costs per acre by 6 percent,
this, too. Is of limited significance  since the
record does not relate It to the support pro-
gram and the study  looked at only  a limited
area.
  "I  cannot accept  the suggestion that we
should continue to use DDT until It Is good
to the very last drop.  Whatever the long-
term  efficacy of  the organophosphates the
fact remains that they generally work. While
the fact of Insect resistance  Is Important
and underscores the need for retaining  a
variety of chemicals or methods to manage
the same pest  problem, thl* tact  does not
Justify  an  avoidable  use  of  a  harmful
chemical.
  •Toxaphen*  and  dlacinon are registered
for control  of cutworm* but It Is  not clear
from  the record as to whether or not these
chemicals are registered or effective to con-
trol cutworm Infestations on onions.  While
none, of the parties  have pointed to helpful
evidence In connection with use  for con-
trolling cutworms on onions and weevils on
•tared sweet potatoes, I have taken Judicial
notice of   the  nonexlstence of  registered
alternative*.
Health   and  Quarantine  Treatment*  In
Emergencies «e Recommended by and Under
Direction  of  State-Federal  OfSclals"  and
•fabric treatment" by the military.
  The record ts not, unfortunately, wen de-
veloped as to the scope or method of applica-
tion for then uses nor  a*  to toe overall
volume  applied for these purposes. While use
for bat  and mice control 1* characterized In
Admission 11  as a "public health use," ap- .
plication for these purposes Is not supervised
by puutlc health officials. The briefs suggest
that use for control of bats and mice Is a
proprietary use by the military, even though a
private  pest control operator testified  that
use for  bats was considered essential by pri-
vate operators." With respect to "Agricultural
and Quarantine" uses It Is difficult to deter-
mine  to  what extent  applications  are for
health purposes or for nuisance prevention.
  With  respect to all of these uses, both for
public health programs and proprietary use,
alternatives do exist. The Public Health Serv-
ice testified that DDT Is no longer the chemi-
cal of choice for controlling  disease vectors.
As for mice, warfarin Is used effectively, and
fumigation and nonchemlcal means are avail-
able for use on bate. Colonel  Fowler testified
that the military has not used DDT In this
country for 2  years for mothproofing  pur-
poses and  stated  that he  was  aware  of
alternatives.
  C. Weight to be  accorded the examiner's
opinion. In reaching the factual conclusions
set forth  In the  preceding sections, I  have
been  mindful  of  Group  Petitioners'  argu-
ment, stressed In their briefs and at oral
argument, that the Hearing Examiner's find-
Ings deserve particular deference In view of
his opportunity to resolve contradictions In
testimony based on demeanor evidence.
  Nowhere does the Examiner state that his
conclusions  were   based   on  credibility
choices.1* Whatever extra weight, then, that
might be due findings  based expressly on a
credibility judgment  is not appropriate in
the case before me. See, e.g., NLRB v. Dlnion
Coll Co., 201 F. 2d 484  (2d Clr. 1953) where
the Examiner's report set forth  his assess-
ment of the witnesses' credibility.'*
  IV. The application of the risk-benefit test
to the facts of record IB, by no means, simple.
We have noted in our statement of March IS,
1971,  that the variables  are numerous. It
should also be borne in mind that the varia-
ble* are not static In point of time. As build-
up of a chemical occurs or is detected In the
environment,  risk Increases.  Indeed, It may
be  that the same tendency of a chemical to
persist  or build  up  in the  food chain is
present  but  not  known  about  substitute
chemicals. It  may also be that circumspect
  "The  only evidence as to the amount of
DDT used for  these purposes  was given by
Col. Fowler, who said  the total used by the
military  for  bat and  mouse control is ap-
proximately 800-900 pounds.
  •During oral argument counsel admitted
that the Examiner's report did not purport to
make  findings based on credibility of wit-
nesses, nor could he point to findings which
might be explained In light of a credibility
contest.  (Transcript of Argument, p. 96-98.)
The basic  questions of fact in  this case, the
hazard to  man and the environment,  were
cast and resolved by the Examiner as "con-
clusions of law."  .
  •The  precedenta,  moreover, make  dear
that the Agency la free to make Its own  find-
ings and that the Examiner's findings and re-
port only comprise part  of the record which
a court will then evaluate. FCC v. AUentown
Broadcasting Corp., 349 U.S. 368 (19U): Unl-
varsal Camara  Corp. v.  NLRB. 340 OB. 474
(1961). Bven where an  Examiner's finding*
are  bated  on  credibility, tb* Agency  may
reach a contrary  conclusion.  Bee FCC v.
Allantown  Broadcasting Corp, supra.
application of a chemical ta limited quan-
tities for those uses most necessary changes
the benefit-risk coefflctont* so as to  tilt the
•cale* differently than when wo weigh aggre-
gate n*» tor ail purpose* against aggregate
benefits. Be* generally EOT v. EFA (opinion
at JwJg» Leventhal), supra.
  A. Bunt** of proof. The crux of a cancella-
tion proceeding la the safety of .the  product
when used a* directed or In accordance with
"commonly   recognized  practice."  Stearns
Phosphorus  Paste Co. v.  EPA, supra. This,
simply  stated,  means that this Agency has
the  burden  of going forward to establish
those risks which It brttavea  to require can-
cellation.90 In addition, an affirmative aspect
of the Agency's case should be the availabil-
ity of preferable substitute  means  of con-
trolling the  pests that are controlled by the
canceled chemical where the Agency Is rely-
ing on  this  fact to establish  that risks out-
weigh benefits.*1 Evidence Showing the avail-
ability  of a registered  chemical or other
means of  control which this  Agency's Pesti-
cides Office  Is prepared to recommend as a
substitute at that point in tune, counted with
the  Agency's proof  on risk, makes out  an
affirmative case."
  The burden of  rebuttal then falls on reg-
istrant* or users. They may either deck to ne-
gate the proof on risks either by rebutting
the basic  scientific data  or by showing that
a particular  use Is so limited as not to en-
  *° The legislative history of FIFRA. judicial
decisions  and  Agency  pronouncements all
state that the "burden of proof" remains on
the registrant to demonstrate that his prod-
uct satisfies the requirements for registration
under  the  Act. Bee S. Bept. 573  at 5 (88th
Cong., first sese., 1963); H. Rept. 1125 at  4
(88th  Cong., first Bess., 1963); EDF v. EPA,
supra; EDF v. Ruckelshaus, supra; Statement
of Reasons, Mar. 18, 1971. There has, unfor-
tunately,  been a great deal  of  misunder-
standing concerning these statements. Sim-
ply stated, the burden of proof referred to by
the legislative history 1* the burden of per-
suasion which  requires a party to establish
the existence of primary facts. It should not
be confused with the burden of going for-
ward which  if generally a rule to establish
the order for the presentation of evidence.
The burden of going forward may, however,
have substantive consequences. Where a party
which has the burden of going forward falls
to satisfy that burden,  the facts  win be de-
cided  against him, even though  the other
party  may have been  responsible  for .the
burden of persuasion.
  While in most legal proceedings the party
which has the burden of going forward bears
the burden of persuasion, this la not neces-
sarily  the  case.  On some Issues, like  con-
tributory negligence in some jurisdictions,  It
may be that once one party has introduced
evidence to  put  the  issue in the  case, the
other  party bears the burden of persuasion
on that point. In a FIFRA cancellation hear-
ing the proponent of cancellation bears the
burden of going forward, but does not bear
the burden of persuasion.
  » While  a  mere showing of a high degree
of risk would make out a prlma facie case for
cancellation, where the Agency la relying on
the  existence of an alternative rather than
simply a showing of risk. It should, as here,
present its own witnesses.
  0 This hearing won conducted under rules
which have since been amended. (See 37 FJl.
9478  (May 11, 1972)).  Under the Agency's
former rules registrants proceeded first at the
hearing. Thla order of presentation, which  Is
now changed, waa not prejudicial In this case.
The Agency more than discharged Its burden
to put on a prlma facia cat*. Registrant* had
an ampl* opportunity fox rebuttal. At wont
thl* inverted prercniaUoa unneoaiaMUy pro-
tracted the hearing.
                                     FEDERAL REGISTER, VOL 17, NO.  131—fUOAV,  JIRY 7,  1972
                                                            -246-

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                                                                                                                           13373
gender the risks from widespread use of the
chemical. They can also eeek to f»UMIah af-
gregate beneflte. Wben. u ben, the exist-
ence of alternative* bean on tbe benefit  of
tbe chemical under review they may chooM
to show nonvlabUlty of alternatives, ettber
for general substitution or In a particular ge-
ographical region."  They may also  aeek  to
show the nondeslnbllUy (or risks) of tit*
alternative If they  disagree with the  staff
judgment of this Agency.
  B. Application of rttk-beneflt to crop tuei
of DDT. The  Agency and  EOF have estab-
lished that DDT Is toxic to nontarget Insects
and  animals, persistent, mobile, and trans-
ferable and that It builds  up In the  food
chain. No label directions for use  can com-
pletely prevent these hazards. In short,  they
have established at the very least the risk  of
the  unknown. That risk  Is  compounded
where, as Is  the  case with DDT,  man and
animals tend  to accumulate and  store the
chemical." Thee* facts alone constitute risks
that are unjustified where  apparently safer
alternatives exist to achieve the same bene-
fit. Where, however, there Is a demonstrated
laboratory relationship  between tbe chemi-
cal and toxic effects In man or animals, this
risk  Is,, generally  speaking, rendered even
more  unacceptable,  If  alternatives exist.
In the case  before us  tbe risk to  human
health from  using  DDT  cannot be  dis-
counted. While these risks might  be accep-
table were we forced to use DDT, they are
not so trivial  that  we can be Indifferent  to
assuming them unnecessarily.
  The  evidence of record showing storage  In
man and magnification In the food chain Is a
warning to the prudent that man may be ex-
posing himself to a substance that may ulti-
mately have a serious effect on his health.
  As Judge Leventhal recently pointed out,
cancer Is a "sensitive and fright-laden" mat-
ter  and  noted earlier In his opinion  that
carcinogenic  effects  are "generally cumula-
tive  anxl irreversible when discovered."  KDF
v. EPA,'Blip Op. at  12 and 16. The possi-
bility that DDT is a carcinogen Is at present
remote and unquantlflable; but If It Is not
a siren to panic, It Is  a semaphore which
suggests  that  an  Identifiable public benefit
is required to Justify continued use of DDT.
Where one chemical tests tumorlgenlc  In a
laboratory and one does not, and both accom-
plish the same task, tbe latter la to  be pre-
ferred,  absent some extenuating  circum-
stances.
  The risks to the  environment from con-
tinued use of DDT are more  clearly estab-
lished. There  Is no  doubt  that DDT runoff
can cause contamination of waters  and given
Its propensity to volatilize and disperse  dur-
ing application, there Is no assurance  that
curtailed usage on  the order of 12  million
pounds per year will not continue to affect
widespread areas beyond tbe location of ap-
plication. The Agency  staff established,  as
well, the existence  of acceptable substitutes
for all crop uses of DDT except on onions
and sweet potatoes  In  storage and green
peppers.
  Registrants attempted but failed  to  sur-
mount the evidence of established risks and
the existence of substitutes by arguing that
   ra Where there Is a generally viable substi-
 tute, which will  Insure  an adequate  crop
 supply, the nonvlabUlty of the alternative In
 a particular area will bear on tbe advisability
 of a transition period. See part IV, Infra.
   •In enacting the present law one of the
 greatest concerns  expressed to  Congress was
 the risk of the unknown. See  statement of
 Congressman Dlngell. Hearings before the
 Subcommittee on Departmental Oversight
 and Consumer Relations of the House Com-
 mittee  on  Agriculture, at  W  (
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13374
onions as with peaimts.~none are apparently
registered.  No party has  cited  evidence  of
record showing what percent of  the onion-
producing  acreage  would be affected  by  a
cancellation of DDT.
  The evidence with respect to  use of DDT
as a "dip" to protect stored sweet potatoes
against weevil  infestation Is even spottier.
Neither counsel for the parties  nor our re-
search has pointed us  to  evidence of record
showing the  precise volume of DDT use for
this purpose. Its likely effect on the  envi-
ronment, or the degree of loss that might be
sustained  by producers.
  While It would  be  fur easier  simply  to
cnnrel  or  not cancel  the registrations for
these  uses.  I  believe  that environmental
problems  should be pcirscd with a scalpel,
not a hacksaw. While F.DP and my own staff
urge  cancellation, on the ground that pro-
ducers  can easily shift to producing differ-
ent crops, there Is no evidence as to how long
such  transition might require.  Moreover,  It
may be that continued use  of a limited vol-
ume  of DDT In these few areas, taken In
conjunction  with aggregate volume  of use
for other  purposes, like health, present  no
risk to the environment. Obviously much of
the  stress on  the  "global" environment  Is
reduced by curtailing overall volume of usage
and we must then estimate the Impact of
use, both  on the environment as a whole,
and the local  surroundings. Lastly, It may
well be relevant to examine the  Impact  on
overall supply of a commodity. Even though
peppers, onions, and sweet potatoes may not
 be food "staples," it may be that the other
acreage Is not suited  for  producing these
crops. In  that event, It will be necessary to
determine whether or not supplies will sat-
isfy demand, and whether or not a transition
period should be fixed to permit a market
adjustment."
   It  follows that additional evidence Is  re-
 quired to determine  the answers to these
 questions. In  the  Interim the cancellation
 orders will remain In effect, subject to regis-
 trants or  users petitioning to present addi-
 tional evidence. In that  event, a stay order
 will  Issue pending the determination  on
 remand.  If  these  users  or registrants can
 demonstrate that a produce shortage will re-
 sult and  their particular use of DDT, taken
 with other uses, does not create undue stress
 on  the general  or local environment, par-
 ticularly  the aquasphere, cancellation should
 be lifted.  If no produce shortage will result
 because other acreage Is suitable for these
 crops, It  shall still be open to demonstrate
 that  a transitional period Is  required  for
 switching to new crops. If the Interim use of
 DDT does not constitute an environmental
 risk, final orders of cancellation for these uses
 will  be deferred until the transition can be
 accomplished, provided  assurances are  re-
 ceived at the  hearing that formulators and
 users will not permit bootlegging.
   B. The  switch to methyl parathion. The
 need for a transition period arises also In con-
 nection  with  those  uses that are  being
 canceled  based on the  existence of methyl
 parathion.
   The record before me leaves no doubt that
 the  chief substitute for most uses of  DDT,
 methyl parathion. Is a highly toxic chemical
 and, If misused. Is dangerous to applicators."

   " It Is  a recognized policy of common  law
 nuisance  and  also of  Federal environmental
 legislation  to  afford affected  producers a
 transitional period for  Implementing  new
 requirements.
   •Not all  of the possible substitutes  for
 DDT are  equally  potent. For example, trl-
 chlorofon, monocrotophos,  malathlon,  and
 carbary), among others, are available to con-
 trol  many cotton  pests: cnrbaryl Is an all-
 purpose chemical for most cotton pests. It Is,
 however, abundantly clcnr Hint methyl para-
 thion will be widely used.
This was the virtually unanimous opinion
of all the wltneaae*. The Introduction Into
use of "rgaipphfThfit*!1 IMA in the post,
caused deaths among  user*  who  are un-
trained In their application and the  testi-
mony and exhibits of record point to the un-
happy experience of several years ago where
four deaths  occurred  at the  time methyl
parathion began to be used on tobacco cropa.
Other testimony noted the Increase In non-
fatal accidents and attributed almost  one-
half reported  pesticide poisonings to  the
organophosphate group.  A survey conducted
after the organophosphates began to replace
chlorinated hydrocarbons In Texas suggests
a significantly Increased Incidence of poison-
ings.
  That  the  skilled  and  trained user may
apply organophosphates with complete safety
Is of comfort only If there Is an orderly tran-
sition from DDT to methyl parathion so as to
train workers  now untutored In the  ways
of proper use.
  I am accordingly making this order effec-
tive as of December 31,  1972, Insofar as the
cancellations of  any  particular use Is pre-
dicated  on the availability  of methyl para-
thion  as a substitute.  In the months that
follow the Department of  Agriculture  and
State extension services and representatives
of  EPA  will  have time  to  begin educating
those workers who will have to  use  methyl
parathion In future growing seasons. Such a
program can also Introduce farmers to the
less acutely  toxic  organophosphates,  like '
carbaryl, which may be satisfactory for many
uses.                         •  •   —'
  VI. Far from being  Inconsistent with the
general  congressional mandate of FIFRA, a
period of adjustment to train users of methyl
parathion or  permit  a needed transition
where no substitutes exist Is  a  logical out-
growth of a sensible application of risk-bene-
fit analysis. While the legislative history does
not address the specific problem before me—
 the timing of cancellation orders—the hear-
ings that preceded the enactment of FIFRA
 Indicate that congressional concern for safety
 of  the farmer-user of pesticides was no less
 than  Congress' solicitude for the environ-
 ment. While Congress  ultimately struck a
 balance that  generally places the  risk of
 negligence on the applicator,  see Stearns v.
 EPA, supra,  It did so  In light of assurances
 that farmers are for their own safety as well
 as that of  the  environment  being  trained
 In proper methods of  application. See Hear-
 ings before  the Subcommittee  on Depart-
 mental  oversight and  Consumer  Relations
 of the  Rouse Committee  on  Agriculture,
 supra, at 64, 88."
   The  risk-benefit  equation  Is a  dynamic
 one.  Timing IB a variable In that equation.
 What may, In the long run, be  necessary to
 protect  the  environment could  be a short-
 term threat  to human health. This Is exactly
 the case before me now. The benefits of using
 organophosphates are  a long-range benefit

   •At  least  two courts have given express
 recognition  to the similarity between  the
 regulatory schemes In  FIFRA and the Food,
 Drug,  and  Coametlc  Act.  Bee Welford  v.
 Ruckelshaus, 439 P. 2d 598 (D.C. Clr. 1971);
 Nor-Am v. Hardln, 435 P. 3d 1133 (7th Clr.
 1970)  (en  bane). I believe that the  trail
 Congress Intended me  to follow Is  marked
 by Its directive In section 348 of  the Food,
 Drug, and Cosmetic' Act, 21  TJJ3.C. section
 348(f)(3) (1971), which permits the Secre-
 tary to set  an effective date for his orders.
 While  similar  language has  not  been  ex-
 pressly  Included In FIFRA, 1U omission can
 hardly  be considered advertent In view of
 the legislative history. See S. Kept.  No.  673
  (88th Cong.,  first session 1963);  H.  Rept.
 No. 1125 (88th Cong.,  second session 1964).
 The purpose of the 1984 amendments was to
 eliminate registration  under  protest.
•od the rtato of DDT result from continued
loot-term UM. In the very short run, how-
ever, the equation balance* out very differ-
ently.'0 LlkewlM, the prospect of dislocation
which might ensue were the use of DDT Im-
mediately halted where no alternatives exist
la a factor we must reckon with. The major
environmental regulatory statutes,  enacted
and  pending,  provide "leadtimu"  for  tm
adjustment to new requirements."
  While Impatlonco is understandable hi view
of the past history  of delay, v.u  must  mil
be lulled  Into the belief  Mint loiigHliiiHllni:
problems can be corrected by overnight solu-
tions. Today's decision provides a definitive
answer  to the status of  DDT  registrations
and  all concerned: to this Agency, fanners,
manufacturers,  the Department of Agricul-
ture,  and extension services;  all must pro-
ceed with  alacrity toward the implementation
of this  order.

             FACTUAL FINDINGS

              I. 6COPE OF  CASE

   A. PB Notices 71-1, 71-3. 71-5 canceled all
registered uses of DDT and TDE.
   B. Appeals  have been received by 31  for-
mulators who held registrations for formulat-
ing  DDT  or  TDE.  These  formulators  ap-
peared at this proceeding  by u single counsel.
   C. Wyco, Inc. and the Wallersttln Co  and
Stark BID'S. Nurseries have also appeured by-
separate counsel.
   D. The Plant  Regulation  Division of the
Department of Agriculture  was a.  party to
this hearing as a registrant and the Depart-
ment was an Intervenor as to all uses.
   E. Ell Lilly & Co. and H. P. Cannon & Sons
were parties to this hearing.
   F. National  Agricultural CheralcaJH Asso-
ciation; Environmental Defense Fond;  the
Sierra Club;  West Michigan  Environmental
Action Counsel; and  National  AucHibon
Society are Intervenor parties.
   Q. The following canceled uses were ap-
 pealed and at Issue In this hearing:

                 Crop  Uses
   I. Cotton.
   2. Beans (dry, lima, snap).
   3. Sweet potatoes.
   4. Peanuts.
   5. Cabbage,  cauliflower,   and   brussels
 sprouts.
   8. Tomatoes.
   7. Fresh market corn.
   8. Sweet peppers and pimenloes.
   9.  Onions.
   10. Oarllc.
   11. Commercial greenhouses.
   *I  do not believe that the  Seventh cir-
 cuit's decision In Stearns Phosphorous Paste
 Co. v. EPA, supra, precludes me from taking
 Into account  the short-term  dangers  that
 could result from Increased use of methyl
 parathion by untrained users. Steams holds
 that a product  Is not "mlsbrandcd" simply
 because It can  be highly dangerous if the
 user  Is careless. This  reasoning  does not,
 however, compel me to Ignore  the  tendency
 of human beings to be negligent where  we
 are dealing with the Implementation  of  an
 order that will Increase use  of a highly dan-
 gerous substance. Even negligence can  be
 minimized by training.
   "While the Examiner excluded from erl-
 dence a study of the DDT problem for this
 Agency  undertaken by  a  Committee of the
 National Academy of Sciences, It Is appro-
 priate to note that Committee recommended
 a phase-out period for the same reasons out-
 lined In this opinion. While I reach my con-
 clusions  without  relying on  that  report's
 factual  findings and recommendations, and
 base them on the record as compiled below,
 I believe the report was  erroneously excluded •
 from  the record, particularly In view of the
 offer by counsel for the Agency to produce u
 committee member for cross-examlmition.
                                      FEDERAL REGISTER, VOL. 37, NO.  131—FRIDAY, JULY 7, 1972

                                                             -248-

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                                                                                                                           JLOoiO
              Noncrop Vies

  1. Control o< house mice  and batt (mili-
tary only).
  2. Fabrk) treatment (military only).
  3. Disease vectors.
  4. Quarantine.
  5. Control  of body  lloe  In prescription
clr.ige.
       II. CHEMICAL PROPEKTIES OF DOT

  A. Basic findings:
  1. DDT can persist In soils for  years and
even dectvdes.
  2. DDT can persist In aquatic ecosystems.
  3. Because of persistence, DDT  Is subject
to transport from sites of application.
  a. DDT can be  transported by  drift dur-
ing aerln! application.
  b.  DDT can vaporize from crop« and soils.
  c. DDT can  be attached to eroding  soil
particles.
  4. DDT Is a contaminant of freshwaters,
estuaries and  the  open ocean, and It la diffi-
cult  or  Impossible to prevent  DDT  from
reaching aquatic areas and  topography non-
adjacent and  remote  from  the  site  of
application.
  B. UlUmat* finding:
  The abcw« factors constitute a risk  to the
environment.

in. ACTTVITT in FOOD CHACTJ AND  IMPACT ON
                 O&GANIBMS

  A.  Basic findings:
   1  DDT is concentrated In  organisms and
transferred through food  webs.
  a. DDT can b« concentrated In  and trans-
ferred   through  terrestrial   Invertebrates,
mammals,  amphibians,  reptiles,  and birds.
   b.  DDT can  be concentrated  and  trans-
 ferred In freshwater and marine plankton,
I i-mects,  molluscs,  oilier  Invertebrates, and
 fish.
   2.  The accumulation  In  the  food chain
 and crop residues results  In human exposure.
   3.  Human beings store DDT.
   B.  Ultimate finding:
   The above factors constitute an unknown,
 unquantlflable  risk  to  man   and   lower
 organisms.

          W. TOXICOLOGICAL UriECLt}

   A.  Basic findings:
   1.  DDT  affects  phytoplankton  species'
 composition  and  the natural   balance  In
 aquatic ecosystems.
   2.  DDT Is lethal to many  beneficial agri-
 cultural Insects.
   3.  DDT can have lethal and sublethal ef-
 fects on useful aquatic  freshwater Inverte-
 brates.  Including arthopods and  molluscs.
   4.  DDT la toxic to fish.       '
   6.  DDT  can  affect  the reproductive suc-
 cess  of  fish.
   6.  DDT  can have a variety of  sublethal
 physiological and behavioral effects on flab.
   7.  Birds can mobilize lethal  amounts of
  DDT residues.
   8.  DDT  can  cause  thinning of bird egg-
 shells and thus Impair reproductive success.
   9.  DDT  Is a potential human  carcinogen.
   a. Experiments  demonstrate  that  DDT
  causes  tumors In  laboratory animals.
   b. There Is some Indication of metastasis
  of tumors attributed to  exposure of animals
  to DDT In the laboratory.
   c. Responsible  scientists  believe  tumor
  Induction  In mice 18 a valid warning of pos-
  sible carcinogenic properties.
   d. There are no adequate negative experi-
  mental studies In other  mammalian  species.
   e. Then Is no adequate human epidemic-
  loglcal  data on the carclnogenlclty of DDT,
  nor  Is It likely that It can be obtained.
   f.  Not all chemicals show the same tumor-
  Igenlc  properties  In laboratory  testa  on
  animals.
       B. Ultimate finding:
       DDT presents a carcinogenic risk.
                     
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n.i'rro or within the District of Columbia or
r: y  American  territory  after December 81,
].:.;. unless Its label bears In a prominent
):.M.;on lu bold type and capital letters. In
a manner satisfactory to the Pesticides Regu-
lation Division, the following language:

      (1) For use by and distribution to
    only US. Public Health Service Of-
    ficials or for distribution by or on
    approval by the U.S. Public  Health
    Service to other Health Service Of-
    ficials for control of  vector diseases:
    (2) Kor iioe by  and  distribution to
    the  USDA or  Military  for  Health
    Quarantine Usr:  (3)  For use In tlie
    formulation for  prescription drugs
    for controlling body lice: (4) or In
    drug; for use  lu controlling  body
    lice—to  be   dispensed  only   by
    physicians.
      Use by  or  distribution to unau-
    thorized users or use for a purpose
    not specified hereon or not  In ac-
    cordance with  directions Is  disap-
    proved by the Federal Government:
    This substance Is harmful  to the
    environment.

  The  Pesticides Regulation Division  may
require such other language as It  considers
appropriate.
  This label may be adjusted to reflect the
terms «nd conditions for shipment for use
on green peppers In Del Marva, cutworms on
onions, and weevils on stored sweet  potatoes
If a  stay Is In effect.

  Dated: June2.1972.

             Wn-UAM D. RUCKELSHAUS.

   |FR Doc.72-10340 Filed 7-6-72:8:50 am)
                              FEDERAL REGISTER, VOL 37, NO. 131—FRIDAY, JULY 7. 1972

                                                         -250-

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                                  I B.

                                APPENDD;

                 DDT REGULATORY HISTORY:  A BRIEF SURVEY
Background

     DDT (Dichloro-diphenyl-trichloroethane), for many years one of the
most widely used pesticidal chemicals in the United States, was first
synthesized in 1874.  Its effectiveness as an insecticide, however, was
only discovered in 1939.  Shortly thereafter, particularly during World
War II, the U.S. began producing large quantities of DDT for control of
vector-borne diseases such as typhus and malaria abroad.

     After 1945, agricultural and commercial usage of DDT became
widespread in the U.S.  The early popularity of DDT, a member of the
chlorinated hydrocarbon group, was due to its reasonable cost, effec-
tiveness, persistence, and versatility.  During the 30 years prior to
its cancellation, a total of approximately 1,350,000,000 pounds of DDT
was used domestically.

     After 1959, DDT usage in the U.S. declined greatly, dropping from
a peak of approximately 80 million pounds in that year to just under
12 million pounds in the early 1970's.  Of the quantity of the pesticide
used in 1970-72, over 80 percent was applied to cotton crops, with the
remainder being used predominantly on peanut and soybean crops.  The
decline in DDT usage was the result of (1) increased insect resistance;
(2) the development of more effective alternative pesticides; (3)
growing public concern over adverse environmental side effects; and
(4) increasing government restrictions on DDT use.

     In addition to domestic consumption, large quantities of DDT
have been purchased by the Agency for International Development and the
United Nations and exported for malaria control.  DDT exports increased
from 12 percent of the total production in 1950 to 67 percent in 1969.
However, exports have shown a marked decrease in recent years dropping
from approximately 70 million pounds in 1970 to 35 million in 1972.

Public Concern

     Certain characteristics of DDT which contributed to the early
popularity of the chemical, particularly its persistence, later became
the basis for public concern over possible hazards involved in the
pesticide's use.  Although warnings against such hazards were voiced
by scientists as early as the mid-1940*s, it was the publication of
Rachel Carson's book Silent Spring in 1962 that stimulated widespread
                                 -251-

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public concern over use of the chemical,  After Carson's alert to the
public concerning the dangers of improper pesticide use and the need
for better pesticide controls, it was only natural that DDT, as one
of the most widely used pesticides of the time? should come under
intensive investigation.

     Throughout the last decade, proponents and opponents of DDT
have faced one another in a growing series of confrontations,
Proponents argue that DDT has a good human health record and that
alternatives to DDT are more hazardous to the user and more costly,
Opponents to DDT, admitting that there may be little evidence of
direct harm to man, emphasize other hazards connected with its use,
They argue that DDT is a persistent, toxic chemical which easily
collects in the food chain posing a proven hazard to non-target
organisms such as fish, and wildlife and otherwise upsetting the
natural ecological balance,

     Both the pro's and con's of DDT use were considered by four
Government committees who issued the following reports,;  (1)
May 1963, "Use of Pesticides," A Report of the President's Science
Advisory Committee (PSAC); (2) November 1965, "Restoring the Quality
of Our Environment," A Report of the Environmental Pollution Panel,
PSAC; (3) May 1969, Report of the Committee on Persistent Pesticides,
Division of Biology and Agriculture, National Research Council, to
Agriculture Department; (4) December 1969, Mrak Commission Report,
All four reports recommended an orderly phasing out of the pesticide
over a limited period of time.

     Public concern further manifested itself through the activities
of various environmental organizations.  Beginning in 1967, the
Environmental Defense Fund, the National Audubon Society, the
National Wildlife Federation, the Izaak Walton League and other
environmental groups became increasingly active in initiating court
proceedings leading to the restriction of DDT use at both local and
Federal levels.

State Regulatory Actions

     Varying restrictions were placed on DDT use in different States,

     DDT use was outlawed except under emergency conditions in
Illinois, Iowa, Massachusetts, New Mexico, New York, Rhode Island,
Vermont,  and Wisconsin.
                                  -252-

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     Alaska, Arizona, California, Colorado, Connecticut, Florida, Idaho,
Kentucky, Maine, Maryland, Michigan, Minnesota, New Hampshire, North
Carolina, Ohio, Utah, Virginia, and Washington have all placed some
limitation on the use of DDT.

     Although the remaining States have provisions for the "restricted
use" classification of pesticides, no specific mention is made of DDT.

Initial Federal Regulatory Actions

     The Federal Government has not been oblivious to the hazards of
DDT use as is indicated by various Government studies and actions
undertaken since the late 50's.

     1.  In 1957, as a matter of policy, the Forest Service, U.S.
Department of Agriculture (USDA), prohibited the spraying of DDT
in specified protective strips around aquatic areas on lands under
its jurisdiction.

     2.  In 1958, after having applied approximately 9-1/2 million
pounds of the chemical in its Federal-State control programs since
1945, USDA began to phase out its use of DDT.  They reduced spraying
of DDT from 4.9 million acres in 1957 to just over 100,000 acres in
1967 and used persistent pesticides thereafter only in the absence of
effective alternatives.  The major uses of DDT by the Forest Service
have been against the gypsy moth and the spruce budworm,  The develop-
ment of alternative pesticides such as Zectran, which was in operation
in 1966, contributed to further reduction in DDT use by the Department.

     3.  In 1964, the Secretary of the Interior issued a directive
stating that the use of chlorinated hydrocarbons on Interior lands
should be avoided unless no other substitutes were available.  This
regulatory measure, as well as others which followed, was reaffirmed
and extended in June 1970, when the Secretary issued an order banning
use of 16 types of pesticides, including DDT, on any lands or in any
programs managed by the Department's bureaus and agencies.

     4.  Between November 1967 and April 1969, USDA cancelled DDT
registrations for use against house flies and roaches, on foliage
of more than 17 crops, in milk rooms, and on cabbage and lettuce.
                                 -253-

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     5.  In August 1969, DDT usage was sharply reduced in certain
areas of USDA's cooperative Federal-State pest control programs
following a review of these programs in relation to environmental
contamination.

     6.  In November 1969, USDA initiated action to cancel all DDT
registrations for use against pests of shade trees, aquatic areas,
the house and garden and tobacco.  USDA further announced its
intention to discontinue all uses nonessential to human health and
for which there were safe and effective substitutes.

     7.  In August 1970, in another major action, USDA cancelled
Federal registrations of DDT products used as follows:  (1) on 50
food crops, beef cattle, goats, sheep, swine, seasoned lumber,
finished wood products and buildings; (2) around commercial.,
institutional, and industrial establishments including all nonfood
areas in food processing plants and restaurants, and  (3) on flowers
and ornamental turf areas.

EPA Regulatory Actions

     On December 2, 1970, major responsibility for Federal regula-
tion of pesticides was transferred to the U.S. Environmental Protec-
tion Agency (EPA).

     1.  In January 1971, under a court order following a suit by
the Environmental Defense Fund (EOF), EPA issued notices of intent
to cancel all remaining Federal registrations of products containing
DDT.  The principal crops affected by this action were cotton,
citrus, and certain vegetables.

     2.  In March 1971, EPA issued cancellation notices for all
registrations of products containing TDE, a DDT metabolite.  The
EPA Administrator further announced that no suspension of the
registration of DDT products was warranted because evidence of
imminent hazard to the public welfare was lacking.  (Suspension,
in contrast to cancellation is the more severe action taken against
pesticide products under the law,)  Because of the decision not
to suspend, companies were able to continue marketing their products
in interstate commerce pending the final resolution of the admini-
strative cancellation process.  After reconsideration of the March
order, in light of a scientific advisory committee report, the
Administrator later reaffirmed his refusal to suspend the DDT
                                 -254-

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registrations.  The report was requested by Montrose Chemical Corpora-
tion, sole remaining manufacturer of the basic DDT chemical,

     3.  In August 1971, upon the request of 31 DDT f emulators, a
hearing began on the cancellation of all remaining Federally
registered uses of products containing DDT.  When the hearing ended
in March 1972, the transcript of 9,312 pages contained testimony
from 125 expert witnesses and over 300 documents,  The principal
parties to the hearings were various formulators of DDT products,
USDA, the EOF, and EPA.

     4.  On June 14, 1972, the EPA Administrator announced the final
cancellation of all remaining crop uses of DDT in the .U.S. effective
December 31, 1972.  The order did not affect public health and
quarantine uses, or exports of DDT.  The Administrator based his
decision on findings of persistence, transport, biomagnification,
toxicological effects and on the absence of benefits of DDT in
relation to the availability of effective and less environmentally
harmful substitutes.  The effective date of the prohibition was
delayed for six months in order to permit an orderly transition to
substitute pesticides.  In conjunction with this transition, EPA and
USDA jointly developed "Project Safeguard," a program of education
in the use of highly toxic organophosphate substitutes for DDT.

     5.  Immediately following the DDT prohibition by EPA, the
pesticides industry and EOF filed appeals contesting the June order
with several U.S. courts.  Industry filed suit to nullify the EPA
ruling while EOF sought to extend the prohibition to those few uses
not covered by the order.  The appeals were consolidated in the U.S,
Court of Appeals for the District of Columbia.

     On December 13, 1973, the Court ruled that there was "substantial
evidence" in the record to support the EPA Administrator's ban on DDT.

Actions Taken Under the New Pesticides Law

     On October 21, 1972, the Federal Environmental Pesticides
Control Act, a far-reaching amendment to the Federal Insecticide,
Fungicide and. Rodenticide Act (FIFRA) was enacted.  These amendments
provide EPA with more effective pesticide regulation mechanisms than
were previously available under the FIFRA.
                                 -255-

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     1.  In April 1973, EPA, in accordance with authority granted by
the amended law, required that all products containing DDT be
registered with the Agency by June 10, 1973.

     2.  On April 27, 1973, EPA granted a request by the States of
Washington and Idaho for a temporary registration of DDT for use
against the pea leaf weevil.  A similar application was approved on
February 22, 1974, for use of DDT during the 1974 growing season.
The chemical was registered for 90 days following a determination
by EPA that control of the pea leaf weevil was an economic necessity
and that DDT was the only practical and effective control agent
available.  The EPA order designated spray restrictions, monitoring
guidelines, and research requirements for the control program.  The
order provided for further testing of three chemicals—methoxychlor,
Imidan, and malathion ULV—which have shown some promise as alterna-
tives to DDT.  Other possible long-range alternatives to DDT were
tested in 1974, as well.

     3.  On February 26, 1974, EPA granted a request by the Forest
Service for use of DDT to combat the Douglas-fir tussock moth
epidemic in the Northwest.  Previous requests by the Forest Service
had been denied on the grounds that the risks of DDT use was outweighed
the benefits.  A week long investigation in September 1973, a
technical seminar on November 16, 1973, and a series of hearings in
January 1974, aided EPA in reassessing the need for DDT.  On the basis
of information acquired during these sessions, the Administrator
concluded that the potential for an economic emergency existed in 1974
and that no effective alternative to DDT was available.  The control
program was carried out under strict spraying restrictions and with
a requirement that research programs to evaluate alternatives to DDT,
and monitoring activities, be conducted by the Forest Service.

     Use of a cancelled pesticide is made possible by the recent
amendments to FIFRA which permit EPA to exempt any Federal or State
agency from any of the provisions of the Act if emergency conditions
exist.  All such requests are considered on a case-by-case basis.

     4.  On March 14, 1975 the Administrator denied the State of
Louisiana a request for emergency use of 2.25 million pounds of DDT
on 450,000 acres of cotton to .control the tobacco budworm in 1975.
This decision was affirmed by the Administrator on April 1, 1975,
after reconsideration on the grounds of "no substantial new evidence
which may materially affect the 1972 order with respect to the human
cancer risk posed by DDT, the environmental hazards of DDT and the
need to use DDT on cotton."  (Federal Register, April 8, 1974, p.
15,962)
                                  -256-

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          Ill B.I

         APPENDIX
    Acute Human Hazard
Information on Alternatives
          to DDT
       Excerpts from
Substitute Chemical Program
Initial Scientific Review,
 completed as of May, 1975
             -257-

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                   Parathion and Methyl Parathion
Symptoms of Poisoning - The symptoms of mild exposure to parathion
or methyl  parathion as a result of orchard spraying or other activities
associated in the fruit-growing industry have been described by
Sumerford et al. (1953) and Arterberry et al. (1961).  The modes of
exposure and the symptomatology have been discussed by Hamblin and
Golz (1955).  The signs and symptoms of 246 patients admitted to a
hospital in Greece with acute parathion poisoning have been reviewed
by Tsachalinas et al. (1971).  Namba (1971) has presented an excellent
description of the signs and symptoms of organophosphate poisoning in
patients.  Reference should be made to Hamblin and Golz's paper (1955)
for the onset and progressions of symptoms in subjects exposed to
toxic amounts of parathion in spraying operations.  Namba (1971) has
classified the signs and symptoms observed in 77 patients who developed
poisoning by the application of ethyl and methyl parathion.  The more
prominent symptoms were weakness, nausea or vomiting, excessive sweating,
headache and excessive salivation.  Namba points out that if the exposure
to organic phosphorus insecticides is sufficient to produce symptoms,
they usually appear in less than 12 hours.  Symptomatology that appears
24 hours after exposure is unlikely to be due to these pesticides.  A
critical clinical observation is the occurrence of miosis, which is
found in about 50% of the patients, and the latter symptom appears in
subjects even in the mild cases.  Death is usually attributed to failure
of the respiratory muscles and paralysis of the respiratory center.
Cardiac involvement may occur, but is usually seen only at the terminal
stage.   Man appears to be more sensitive to the organophosphate insecti-
cides in that he exhibits symptoms earlier than experimental animals,
particularly central nervous system manifestations.  If an untreated
organophosphate-poisoned victim is alive after 24 hours, he is likely to
recover.  The account by Kanagaratnam et al. (1960) describes a parathion
poisoning incident resulting from the use of contaminated barley in India.
There were 53 persons involved, and the clinical features described
included collapse, fits, sweating, dyspnoea, the effect on the pupils, the
eye, blood pressure, coma, and muscular fasciculation.

     Gershon and Shaw (1961) felt that chronic exposure to organophosphate
compounds produced psychiatric disorders in orchard workers.  In a small
field survey, they observed in 14 men and two women schizophrenic and
depressive reactions with severe impairment of memory and difficulty in
concentration.  The range of exposure for these subjects was 1-1/2 to
10 years.

     No other surveys of this nature were found in the literature.
                                  -258-

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     Brown (1971) reported on the electroencephalographic changes and
disturbance of brain function following organophosphate exposure.  Acute
organophosphate poisoning disturbs central nervous system functions by
causing disorientation in space and time, a sense of depersonalization,
and hallucinations; with heavy exposure, convulsions occur. Acute inhi-
bition of brain cholinesterase would be expected to cause effects related
to the temporal lobe.  EEG changes in acute organophosphate poisoning
have been reported to resemble those seen in the interictal EEG of temporal
lobe epileptics.

Accidents - Parathion and methyl  parathion are the pesticides most frequently
cited in incidents involving accidental exposure to pesticides.  Preliminary
data from the EPA Pesticide Accident Surveillance System (PASS) shows that
parathion is the third and methyl  parathion is the fifth most frequently
cited pesticide in 1973.  Based on an analysis of PASS data, Osmun (1974)
stated that for 1972 and 1973, parathion and/or methylparathion were con-
nected with 78% of the reported episodes relating to agricultural jobs,
particularly those involving fields sprayed with pesticides for which safe
reentry times for workers had been set.

     Some 125 episodes involving methyl parathion are included in the PASS
computerized system.  Approximately 45, 30, and 15% of these episodes were
reported from EPA Regions IV, VI, and IX, respectively.  This distribution
is not consistent with that of the domestic consumption pattern.

     There are a number of limitations, however, in attempting to use PASS
data.  First of all, the cause-effect relationship between the pesticides
cited and the effects observed have generally not been established.
Second, generally only data for 1972 through about January 1974 have
been computerized and are readily available for retrieval.  Third, a
large portion of the data provided to PASS comes from California.  This
skewed distribution probably represents bias caused by the efficient
level with which the State of California documents pesticide information.
During a review of PASS files, data in addition to the preliminary informa-
tion found on the pesticide episode reporting form (Form ACEC1, December
1972) were found on only nine of the approximately 125 episodes involving
methyl parathion and 12 of the 257 episodes involving parathion.  Further
duplicate entries in PASS have been noted for a few incidents.
                                  -259-

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                  Data Relating to Other Substitutes


Methomyl

          Human Toxicity and Epidemiology

Symptoms of Poisoning and Antidotes - Warning symptoms as listed on
the label of Lannate$90% (methomyl) water soluble powder (EPA Reg.
No. 352-342) are typical of those associated with exposure to an
anticholinesterase agent.  These include weakness, blurred vision,
headache, nausea, abdominal cramps, sweating and constriction of
pupils.

Occupational and Accidental Exposure - Beginning in 1971, EPA and
the States of California and Arizona became aware of serious problems
in workers handling Lannat^"90% (methomyl) soluble powder.  The
California Department of Health estimated 150 incidents involving
Lannate poisoning in California.  There have been no fatalities.

     After an extensive investigation by State and Federal Officials
and with the assistance of Dupont Chemical Company and various users
it was concluded that most cases of 54 documented Lannate poisoning
cases would not have occurred if the label directions were followed
and proper protective clothing worn.  (Memo from Mr. Brian Sturgess,
Region IX to Acting Director Operations Division regarding Lannate
Investigations in Arizona and California, April  19, 1973).  Due to
possible inhalation of the powder, it is very important that goggles
and a mask or suitable respirator be worn.  It should be noted that
often the extreme heat in certain areas of California and Arizona
make the wearing of any protective equipment very difficult.

     Better hygiene and improved closed systems  for loading and mixing
pesticides would lessen the chance for accidents not only with Lannate
but other highly toxic pesticides.

     Two cases of methomyl  poisoning in men who  mix pesticides, probably
resulting from inhalation of powder during mixing, were reported in
Australia in early 1974.  Blood cholinesterase levels were between  0%-35%
for one individual and 35%-65% in the other reported poisoning incident;
normal values range between 80% and 120%.
                                 -260-

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     "One serious point was that when methomyl caused a fall in plasma
cholinesterase activity, further exposure to organic phosphate could
deplete red blood cell cholinesterase values as well.  Poisoning could
probably occur more quickly and could be potentiated by the carbamate
material."

     Other incidents involving methomyl poisoning were also reported,
but these cases were complicated by the fact that the men involved had
handled various other organophosphate insecticides during the same time
period they had come in contact with methomyl (Simpson and Penney, 1974),

     No epidemiology studies involving methomyl have been reported.
                                  -261-

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                               Aldicarb
Symptoms of Poisoning - Symptoms of aldicarb poisoning are typical of
those seen with anticholinesterase agents (see methomyl).

Accidents - Aldicarb has been cited in a small number of accidental
exposure reports.  The EPA Pesticide Accident Surveillance System
(PASS) computerized data base lists a total  of 11 episodes involving
aldicarb.  This data base includes most data reported for 1972 through
January 1974.  Eight of the 11 reported episodes took place in Region IX,
The available data, however, is not sufficient to establish any relation-
ship between accident frequency and specific uses of aldicarb.
                              Disulfoton
Accidental Exposures - Watson et al. (1971) reported the accidental
poisoning of cattle when eight discarded disulfoton bags were blown from
a potato field into a pasture.  As a result of chewing on the empty bags
containing disulfoton residues, one animal was found dead and several
others were severely sick.  Within three days, six additional animals
had died.  In addition to the bags containing residues, it was suspected
that some of the irrigation water from the sprayed field also entered
the farm pond used as a source of drinking water for the affected cattle.

     Accidental exposures to disulfoton are also recorded by the EPA Pesti-
cide Episode Review System (PERS).  The computerized PERS data base, which
generally included data through January 1974, shows disulfoton to be the
21st most frequently cited pesticide in the episodes* reported.  A total
of 63 disulfoton episodes are included in the computerized data (through
January 1974).  Twenty-eight additional episodes have subsequently been
reported.  Approximately two-thirds of these 91  episodes involved human
exposure.
   Episodes reported include those involving humans, animals, plants, and
   contaminated areas.   In most cases, however, disulfoton was not conclu-
   sively established as the cause of the episodes, i.e., cause-effect
   relationships generally have not been established.
                                  -262-

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The distribution of the reported episodes by EPA regions is as
follows:

Region
I
II
III
IV
V
VI
VII
VIII
IX
X
0
2
1
16
4
10
8
16
22
12
Unfortunately, the information available was too limited to establish
any relationship between the episodes and any specific application or
use of disulfoton.
                                  -263-

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                              REFERENCES
Arterberry, J. D., W. F. Durham, J.  W.  Elliot, and H. R. Wolfe,
   "Exposure to Parathion," Arch. Environ. Health. 3:476-485 (1961).

Brown, H. W., "Electroencephalographic Changes and Disturbances of Brain
   Function Following Human Organophosphate Exposure," Northwest Med.,
   70:845-846 (1971).

Fredriksson, T., "Studies on the Percutaneous Absorption of Parathion
   and Paraoxon.  Part II.   Distribution of 32P-Labeled Parathion
   Within the Skin," Acta Derm. Venerol.. 41:344-353 (1961).

Gershon, S., and F. H. Shaw, "Psychiatric Sequelae of Chronic Exposure
   to Organophosphorus Insecticides," Lancet, pp. 1371-1374 (1961).

Kanagartanam, K., W. H.  Boon and T.  K.  Hoh, "Parathion Poisoning from
   Contaminated Barley," Lancet. 1:538-542 (1960).

Namba, T., "Cholinesterase Inhibition by Organophosphorus Compounds
   and Its Clinical Effects," Bulletin of the World Health Organization,
   44:289-307 (1971).

Osmun, J. V., Internal EPA Memo to Ed Johnson, "PASS Information Relating
   to Agricultural Jobs" (1 April 1974).

Osmun, J. V., "PASS Information Relating to Agricultural Jobs,"
   Internal EPA Memo to Ed Johnson (1 April 1974).

Quarles, J., "Worker Protection Standards for Agricultural Pesticides,"
   Federal Register, 39(62)-.16888-16891 (10 May 1974).

Simpson, G. R. and D. J. Penney, "Pesticide Poisonings in the Namoi
   and Macquarie Valleys, 1973," Med. Journal. August, 1:258-260 (1974).

Sumerford, W. T., W. J.  Hayes, Jr.,  J.  M. Johnston, K. Walker, and
   J. Spillane, "Cholinesterase Response and Symptomatology from
   Exposure to Organic Phosphorus Insecticides," AMA Arch. Ind. Hyg.
   Occup. Med.. 7:383-398 (1953).
                                 -264-

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Trefilov, V. N., Jr., I. S. Faernan, Jr., and E.  P.  Borisona, Jr.,
   "The Degree of Contamination of the Special  Clothing and Skin
   Coverings of Workers in the Manufacture of Metaphos and Chlorophos,"
   Gigiena Truda I Prof. Zobolevoniga. 15(2):51-53 (1971).

Tsachalinas, D., G. Logaras, and A.  Paradelis,  "Observations on 246
   Cases of Acute Poisoning with Parathion in Greece," Eur. J.  Toxicol.,
   4:46-49 (1971).
                                 -265-

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                                      Ill B.2

                                     APPENDIX
                                 EPA Report of National
                                 Pesticide Episodes*
                                 for DDT Substitues
                                 1971-1974
Primary DDT .
Substitutes
Parathion
Malathion
Methyl
Parathion
Carbaryl
Me thorny I/
Lannate
Phosdrin
Diazinon
Chlordane
27 Other DDT
Substitutes**
TOTALS
Human
Accident
Episodes
230
115
84
60
101
119
105
112
391
1317
Animal
Poisoning/
Contamination
64
24
12
31
2
4
7
9
212
365
Contamination
pf fnftfj/wfttp,r
70
24
42
15
7
14
12
28
269
481
Total
Episodes
366
162
153
109
105
131
132
140
830
2128
% of total that
are humans
injuries
63
71
55
55
96
91
80
80
47
62
    *
     Confirmed episodes reported in this table have not been  differentiated
from those which are not confirmed cases of pesticide injury.

       Other DDT Substitutes  reported  include:
       Methoxchlor,  Endrin, Azinphos Methyl, Guthion,
       Azodrin,  Galecron,  Toxaphene, EPN,  Di-syston,
       Dasanit,  Naled,  Dimethodate/Cygon,  Bidrin,
       Dyfonate, Heptachlor,  Dieldrin,  Aldr.in,
       Thimet, Systox,  Dylox, Dipterex, Carbophenothion
       Meta-Systox-R Galecron, Endosulfan  (Thiodan, SD-
       8447/ Gardona, Furadan, Aldicarb/Temik,  Surracide


Source:  Special Ingredient Report, Pesticide Episode Review  System,  Pesticide
         Use Analysis Branch, Operations Division,  OPP, EPA,  Feb.  19, 1975.

                                       -266-

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             Ill D. 1

            APPENDIX
Efficacy and Cost Effectiveness of
      Alternatives to DDT for
        Cotton Insect Pests
           Excerpts from
    Substitute Chemical Program
       Minieconomic Review,
               1975
                   -267-

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                                Methyl Parathion

     The use of methyl parathion on cotton In 1972 Is estimated at
33,500,000 Ib of active ingredient, i.e., 84.37. of the total domestic
consumption.  It is primarily used to control the cotton boll weevil,
bollworm and tobacco budworm, but is also recommended for control of
thrips, cotton leafworms, grasshoppers, fall armyworms, spider mites,
fleahoppers, lygus bugs, aphids, garden webworms, false chinch bugs,
cabbage loopers and cutworms.

     Methyl parathion can be applied by itself or in combinations with
other insecticides.  Prior to the restriction of DDT a typical applica-
tion consisted of 0.5 gal/acre of a mixture of 4 Ib toxaphene, 2 Ib DDT
and 0.5 Ib of methyl parathion to control bollworms.  The number of ap-
plications would vary depending upon the degree of infestation.  A high-
use farmer might make 14 to 15 total applications, with one or two of
these applications consisting solely of methyl parathion to suppress
the late hatch of bollworms.  Many states are now recommending a formu-
lation consisting of 6 Ib of toxaphene and 3 Ib of methyl parathion per
gallon at a rate of 1 to 2 qt/acre.

Efficacy Against Pest Infestation - The use  of methyl parathion
expanded significantly as resistance  of the  tobacco budworm to DDT
increased.   Adkisson et al.  (1965)i/  found a high  level of DDT resis-
tance in the budworm and bollworm.  Tests showed that methyl parathion
killed 85% of the bollworm larvae when applied at  0.25 Ib/acre whereas
1.0 Ib/acre of DDT killed only 51%.

     Wolfenbarger et al.  (1971)^/ found that methyl parathion killed 85%
of the bollworms and tobacco budworms.  Yields in  a test at Brownsville,
Texas, in 1967 increased 689 Ib of  seed cotton over the check.  Good con-
trol of the bollworm, tobacco budworm, and pink bollworm was achieved.
I/  Adkisson, Perry L.,  and Stanley Nemec, "Efficiency of Certain Insecti-
      cides for Killing  Bollworms and Tobacco Budworms," Progress Report
      PR-2357, Texas Agr. Exp. Sta. (1965).
2f  Wolfenbarger, D. A., and Rex McGarr, "Low Volume and Ultra-Low
      Volume Sprays of Malathion and Methyl Parathion for Control of
      Three Lepidopterous Cotton Pests," Production Research Report No.
      126, U.S. Department of Agriculture and Texas Agr. Exp. Sta. (1971),
                                     -268-

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     Netnec et al. (1968)i/ evaluated ULV and CLV roethyl parathlon sprays
at College Station, Texas In 1966 and achieved 100% kill of the boll-
worm and budworm 48 hr after application of 1.0 Ib/acre.  They concluded
that ULV sprays should provide more effective and economical control.

     Hopkins et al. (1970)2' evaluated methyl parathion and other in-
secticides in 1968 and 1969 at Florence, South Carolina, and found that
methyl parathion gave good control of the bollworm and boll weevil.
Yields increased 1,629 Ib/acre in 1968 and 867 Ib/acre in 1969 compared
to the untreated checks.  The yields from the untreated checks were 255
and 10 Ib/acre, respectively.

                           3/
     Adkisson et al. (1967)—  compared various insecticides and found that
methyl parathion at 1.0 Ib/acre killed 100% of the bollworra larvae after
48 hr and 897» kill was achieved when methyl parathion was applied at 0.5
Ib/acre.  They also found that 0.75 Ib/acre methyl parathion provided
97% kill of tobacco budworm larvae after 48 hr and 100% kill of the adult
boll weevil under the same conditions when 0.25 Ib/acre were applied.
These tests were conducted at College Station, Texas, in 1966.

     McGarr et al. (1969)—'  evaluated insecticides at Brownsville, Texas,
in 1968 and reported that although methyl parathion was effective against
the budworm and bollworm it did not give adequate control.  Yield increases
from three tests varied from 6 to 219 Ib/acre.  When methyl parathion was
applied at 2.0 Ib/acre, better control was achieved and yields increased
845 Ib/acre.

     In 1968, Neraec et al. (1968)—' noted that the tobacco budworm popula-
tion in the Lower Rio Grande Valley, and perhaps near College Station
I/  Nemec, S. J., P. L. Adkisson, and H. W. Borough, "Laboratory Tests
      of Ultra-Low Volume and Conventional Low Volume Sprays for Con-
      trolling the Bollworm and Tobacco Budworm," J. Econ. Entomol.,
      61:209-213 (1968).
2/  Hopkins, A. R., H. M. Taft, W. James, and C. E. Jernigan, "Evalu-
      ation of Substitutes for DDT in Field Experiments fof Control of
      the Bollworm and the Boll Weevil in Cotton, 1967-1969," J. Econ.
      Entomol.. 63:848-850 (1970).
      —~- —" L -* JL -*                                            /
3j  Adkisson, Perry L., and S. J. Nemec, "Insecticides for Controlling
      the Bollworm, Tobacco Budworm, and Boll Weevil," MP-837, Texas
      Agr. Exp. Sta. (1967).
4/  McGarr, R. L., and D. A. Wplfenbarger, "Field Evaluations of Insecti-
      cides for Control of Cotton Insects, Brownsville, 1968," Progress
      Report PR-2670, Texas Agr. Exp. Sta. (1969).
5/  Nemec, S. J., P. L. Adkisson, and H. W. Dorough, "Laboratory Tests of
      Ultra-Low Volume and Conventional Low Volume Sprays for Controlling
      the Bollworm and Tobacco Budworm," J. Econ. Entomol.. 61:209-213 (1968).

                                -269-.

-------
had developed a low-level resistance to methyl parathion:  large doses
of the insecticide were needed to kill the budworms in laboratory tests.
The LD-Q values had also indicated a 2.0- to 2.5-fold increase over the
previous year.  These tests showed a 977. kill in 48 hr when applied
at 2.0 Ib/acre on College Station larvae.  This dropped to a 41% kill
rate when 0.5 Ib/acre was applied.  There were no indications of re-
sistance in the bollworm or voll weevil.

     Nemec conducted similar tests in 1969 (Nemec, 1970l/) and found
that the 11)50 value for methyl parathion increased 1.5-fold over the
1968 value in budworms from the Brazos River Valley and twofold over
the 1968 value in the Welasco area.  Methyl parathion at 2.0 Ib/acre
resulted in a 90% kill in 48 hr at College Station in 1969.  At 0.5
Ib/acre it gave a 44% kill.  In Welasco the results at the above rates
vere 79% and 23%, respectively.
                        n I
     Nemec et al. (1973)—'  summarized the yearly tests comparing the
effect of methyl parathion on the budworm and bollworm.  He reported
that prior to 1968 when resistance was detected in the budworm the
cost of control was $28/acre.  By 1972 the cost for control of the
bollworm complex averaged $60/acre due to higher rates and more fre-
quent applications of insecticides, greater populations of the budworm
and higher costs of certain insecticides.

     The results of tests showed that the U^n values for methyl para-
thion on the budworm increased 50-fold between 1964 and 1972 at College
Station, Texas.  A fivefold increase from 1968 to 1972 was reported in
the Rio Grande Valley, Texas.

     Some resistance of the bollworm to methyl parathion was also in-
dicated.  The LbjQ values at College Station were at the same level
from 1967 to 1971, but doubled in 1972.  Bollworms in the Pecos area
were shown to be more tolerant to methyl parathion than those from
College Station.
\J  Nemec, S. J., "Topical Application and Caged Plant Evaluations of
      Insecticide Toxicities to Bollworms, Tobacco Budworms and Boll
      Weevils," Progress Report PR-2845, Texas Agr. Exp. Sta. (1970).
2/  Nemec, S. J., and P. L. Adkisson,  "Organophosphate Insecticide
      Resistance Levels in Tobacco Budworm and Bollworm Populations
      in Texas, Investigations of Chemicals for Control of Cotton
      Insects in Texas," Technical Report No. 73-20, pp. 18-25,  Texas Agr.
      Exp. Sta. (1973).
                                      -270-

-------
     Wolfenbarger  et  al.  (1973)I/  evaluated budworm resistance  to methyl
 parathion in Texas, Mexico,  Central  America, Florida,  and Mississippi,
 and  found the highest levels of  resistance in  the Mante  Tampico area  of
 Mexico.   They concluded  that these insects in  this  area  and  Brownsville,
 Texas were resistant  to  methyl parathion while those in  Mississippi,
 Southern  and Western  Mexico  were susceptible.   The  bollworms from Central
 America and Southern  Mexico  were resistant to  methyl parathion  whereas
 the  United States  resident bollworms were susceptible.

     Apparently, the  resistance  of the budworm to methyl parathion  is
 limited to the Texas  area.   Canerday (1974)2/  showed that there were
 no substantial and consistent differences in the response of bollworms
 and  budworms to methyl parathion in  tests conducted in Georgia  between
 1970 and  1972.

 Cost Effectiveness of Pest Control - Numerous  studies  have been con-
 ducted comparing increased yields  of methyl parathion  treated cotton.
 Most of these studies were made  available from the  Texas Agricultural
 Experiment Station and were  supplemented by tests conducted  in  Mississippi,
 Louisiana,  and South  Carolina.   The  tests covered the  period from 1956
 to 1972.   The 1972 farm  value, including an allowance  for support payments,
 was  15.1C for the  lint and 2.5C  for  the seed in a pound  of seed cotton.
 Therefore,  the total  farm value  of a pound of  seed  cotton was 17.60 in
 1972 (Agricultural Statistics, 1974.1/).  Methyl parathion costs averaged
 $l/lb in  1972 (Chambers  and  Miller,  1974*./).

     The  range of  yield  changes  from all of the data reviewed varied
 from a loss  of 52  Ib/acre to an  increase of 1,629 Ib when compared  to
 untreated test plots.  The economic  benefit after subtracting the cost
 of the methyl parathion  ranged from  a loss of  $20.15/acre to a  gain of
 $270.45/acre.

     The  results of the  yield tests  are tabulated in Table 25.
I/  Wolfenbarger, D. A., M. J. Lukefahr, and H. M. Graham, "LD5Q Values
      of Methyl Parathion and Endrin to Tobacco Budworm and Bollworms
      Collected in the Americas and Hypothesis on the Spread of Resistance
      in These Lepidopterans to These Insecticides," J. Econ. Entomol.,
      66:211-216 (1973).
]J  Canerday, T. D. , "Response of Bollworm and Tobacco Budworm in Georgia
      to Methyl Parathion," J. Econ. Entomol., 67:299 (1974).
3/  Agricultural Statistics, 1973, U.S. Department of Agriculture, (1973).
47  Chambers, William, and Daniel Miller, Farmland Industries, Kansas
      City, Missouri, personal communication with Mr. David F. Hahlen
      (1974).
                                  -271-

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             Table 25.  RESULTS OF METHYL PARATHION APPLIED TO COTTON PESTS

Application

Date
1967
1956
1956
1959
1960
1961
1967
1967
1968
1969
1971
1971
1971
1971
1972
1973
1972
1971
1971
1963
1966
1969
1971
1971
1966
1966
1969
1973
1967
1968
1969
1968
1969
1967

1968



1968

1968


Rate
(Ib Al/acre)
1.25
0.3
0.25
0.25
0.25
0.25
0.25
0.75
1.0
1.0
0.25
0.125
0.25
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
0.75
0.75
0.75
0.75
1.0
1.0
1.0
1.0
1.0
0.75
2.0
2.0
1.25
1.25
1.0
0.75

No.
8
9
9
13
14
13
11
11
6
10
7
7
7
7
10
3
12
7
8
12
9
8
7
7
9
9
7
5
12
4
9
13
16
17
17
6
11
12
17
12
12
8
6
6
Yield
increase*
(Ib/acre)
436
1,530
476
68
265
290
487
194
119
775
122
158
97
255
197
34
366
337
499
350
165
547
376
460
177
75.
773
220
201
157
801
1,629
867
689
576
219
175
6
845
800
636
419
629
411
Additional
income*
($/acre at
17.6
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                         Table 25.  (Continued)
Date
1969
1969
1969
1970
1971

1971
   Application
    Rate
(Ib Al/acre)
1972
1972
    1.5
    1.5
    1.6
    2.0
    1.5
    1.17
    1.5
    1.5
    1.5
    1.5
    1.5
    0.8
    1.5
    1.5 .
    0.8
    1.5
    1.5
No.

 6
 6
 8
13
12
 6
 4
 6
 6
 8
 8
 8
 8
 8
 8
10
 8

Yield
increase*
(Ib/acre)
65
105
65
601
236
115
290
98
(52)
439
596
449
711
614
384
414
. 364
Additional
income*
($/acre at
17.6c/lb)
11.44
18.48
11.44
105.78
41.54
20.24
51.04
17.25
(9.15)
77.26
104.90
79.02
125.14
108.06
67.58
72.86
64.06
Application
   cost (AI
$l/lb + 50c/
application)

    12.00
    12.00
    16.80
    31.50
    24.00
    10.02
     8.00
    12.00
    12.00
    16.00
    16.00
    10.40
    16.00
    16.00
    10.40
    20.00
    16.00
Economic
benefit*
   ($)

   (.56)
   6.48
  (5.36)
  74.28
  17.54
  10.22
  43.04
   5.25
 (21.15)
  61.26
  88.90
  68.62
 109.14
  92.06
  57.18
  52.86
  48.06
Source

  JB/




  I/

  I/

  m/
  o/
(Note:   Income  and benefit figures have been adjusted for error  in  source  document.
 *  Data in parentheses indicate decreases yield, income, and economic benefit.
 a/  Cowan, C. B.,  Jr., and J. W. Davis, "Field Tests With Conventional Low
       Volume or Ultra-Low  Volume Sprays for Control of the Boll Weevil,
       Bollworm, and  Tobacco Budworm on  Cotton in 1967," J. Econ. Entomol.,
       61:1115-1116 (1968).
 b/  Bost,  W.  M., Director, Cooperative  Extension Service, Mississippi State
       University,  State College, Mississippi, Summary of Test Results at
       Stoneville and Verona,  Mississippi,  and Costs of Pesticides, personal
       letter to Mr.  David  F.  Hah1en.
 £/  Cox,  John A.,  Director, Louisiana Cooperative Extension Service, Baton
       Rouge,  Louisiana,  Summary of Test Results in Louisiana, personal
       letter to Mr.  David  F.  Hahlen (1.974).
 d/  Legett, J. E., T. C. Cleveland, and W. P. Scott, "Comparison of Several
       Insecticide Combinations  for Control of Heliothis  spp.,"  J. Econ.
       Entomol., 65:1182 (1972).
 e/  Hopkins, A. TT, H. M.  Taft, W. James, and C. E. Jernigan, "Evaluation
 "~     of  Substitutes  for DDT in Field Experiments  for Control of  the Boll-
       worm and the Boll Weevil  in Cotton,  1967-1969," J. Econ.  Entomol.,
       £3:848-850  (1970).
 f/  Wolfenbarger and McGarr, op. cit.  (1971).
   /  McGarr and Wolfenbarger, op. cit.  (1969).
                               -273-

-------
                         Table 25.   (Continued)
h/  Hanna, R. L., "Field Performance of Chemicals for Control of Tobacco
      Budworras, Bollworms, and Carmine Spider Mites on Cotton, College
      Station, 1968," Progress Report PR-2671, Texas Agr. Exp. Sta. (1969).
i/  Hanna, R. L., "Field Tests of Chemicals for Control of Tobacco Budworms,
      Bollworms, and Carmine Spider Mites on Cotton, College Station,"
      Progress Report PR-2842, Texas Agr. Exp. Sta. (1970).
J/  Cowan, C. B., Jr., and J. W. Davis, "Field Evaluation of Insecticides for
      Control of the Boll Weevil, Bollworm and Tobacco Budworm on Cotton,
      Waco Area, Central Texas, 1968," Progress Report PR-2672, Texas Agr.
      Exp. Sta. (1969).
k/  Hanna, R. L., "Field Tests of Chemicals for Control of Tobacco Budworms
      and Bollworms on Cotton, College Station," Technical Report 19,  pp.
      19-22, Texas Agr. Exp. Sta. (1971).
I/  McGarr, R. L., "Field Tests With the Delta-Endotoxin of Bacillus
      thuringiensis HD-1 and Chemical Insecticides for Control of the
      Tobacco Budworm and Bollworm and the Cotton Leafperforator, 1970
      and 1971, Investigations of Chemicals for Control of Cotton Insects
      in Texas 1970-1971," Progress Report PR-3082, pp.  1-4, Texas Agr.  Exp.
      Sta. (1972).
m/  Hanna, R. L., "Field Tests of Chemicals for Control of Tobacco Budworms
      and Bollworms on Cotton, College Station, Investigations of Chemicals
      for Control of Cotton Insects in Texas, 1970-1971," Progress Report
      PR-3084, pp. 22-36, Texas Agr. Exp.  Sta.  (1972).
n/  Cowan, C. B., Jr., and J. W. Davis, "Chemicals Evaluated in Field Tests
      Against Cotton Insects, Investigations of Chemicals for Control of
      Cotton Insects in Texas," Technical  Report No. 73-20, pp. 9-12, Texas
      Agr. Exp. Sta. (1973).
o/  McGarr, R. L., "Field Tests With Bacillus thuringiensis HD-1 and Chemi-
      cal Insecticides for Control of the  Tobacco Budworm and the Bollworm
      at Brownsville, Texas, 1972, Investigations of Chemicals for Control
      of Cotton Insects in Texas," Technical  Report No.  73-20, pp. 13-17, Texas
      Agr. Exp. Sta. (1973).
                                      -274-

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                                     Aldicarb
     Approximately 440,000 Ib AI of Temik™ were used to treat cotton
insects and nematodes in 1972.  It has been shown to be effective in con-
trolling thrips, aphids, boll weevils, leaf miners, desert spider mites
and fleahoppers.

Efficacy Against Pest Infestation

     Temik®  has been evaluated for insect control on cotton by a number of
researchers.   These tests were conducted prior to registration and in non-
commercial trials since registration.  For this reason the results may not
be representative of actual field conditions, but they have been included
so that the review may be more complete.   (See Table 14.)

     Beckham (1970).!' evaluated Temik® and other insecticides for the
control of thrips on cottotv in Georgia.  Results of tests conducted in 1967
and 1968 showed that Temik®  was highly effective in thrips control.  Davis
and Cowan (1972)2J showed that Temikxy applied in the seed furrow at planting
gave effective control of thrips, the cotton aphid, and the cotton fleahoppers,
Davis and Cowan  (1974) —' conducted tests with Temik®- and concluded that
effective control of thrips,  cotton aphids and cotton fleahoppers was
achieved.  The director of the Cooperative Extension Service in Mississippi,
W. M. Bost (1974)A/, reporting on tests of Temik& at Verona, Mississippi,
in 1971, found the pesticide gave excellent thrips control and reduced the
number of boll weevils.  Its effect on fleahoppers was inconclusive.

     Fifty additional tests,  conducted from 1965 to 1973, compared yields
of TemikMN-treated plots at Stoneville, Mississippi (Bost, 1974).  Sub-
stantial yield information was also obtained from Union Carbide pesticide
petitions registered with EPA.
IV  Beckham, C. M., "Influence of Systemic Insecticides on Thrips Control
      and Yield of Cotton," J. Econ. Entomol.. 63:936-938 (1970).
£/  Davis, J. W., and C. B. Cowan, Jr., "Field Evaluation of Three Formula-
      tions of Aldicarb for Control of Cotton Insects," J. Econ. Entomol..
      65:231-232  (1972).                                              \	
_3_/  Davis, J, W. , and C. B. Cowan, Jr., "Early Season  Insects on Cotton:
      Control with Two Systemic Insecticides," J. Econ. Entomol.. 67:130-131
      (1974).
4/  Bost, W. M., Director, Cooperative Extension Service, Mississippi State
      University, State College, Miss.1, Personal letter to D. F. Hahlen
      (Midwest Research Institute, St. Louis, Mo.)  (1974).
                                         -275-

-------
      In addition to the above test data, Union Carbide has submitted the
 results of 1974 efficacy and comparative yield tests  for cotton.  This data
 has been compiled and evaluated in the same manner  as the published data
 and is presented in Table 15.  These tests are results of"commercial use and
 are likely to be more representative of actual field  conditions than the
 experimental trials in Table 14.  The tests were  conducted in several states
 and, therefore, probably cover a wide spectrum of environmental conditions.
 Most of the yield increases are averages of several tests and in the cases
 where the number of tests was given, this number  has  also been presented.
 The average change in yield has been calculated as  a  weighted average based
 on the number of tests from which each yield  change was derived.  This
 supplementary data.-on cotton gave no indication of  the efficacy of insect
 control but the tests did report increases in yield of from 0 to 390 Ib/acre
 in South Carolina and Alabama respectively.   The  weighted average of all the
 tests indicated that the use of Temik (K>caused an average increase in cotton
 yield of 75.6 Ib/acre.

 Cost Effectiveness of Pest Control

      The 1972 price received by farmers for cotton  was 24.0c/lb for lint.
 Additional income from cottonseed of  4.2c/lb  and  government price supports
• of 12.5c/lb brought the total income  to 40.7
-------
                                   Table 14.  SUMMARY OF  EFFICACY TESTS ON COTTON
i
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Date
WMB^WMM
1964


1964

Unknown
Unknown

0
1
1965

1965
1965

1965

1965






Application
(Ib Al/acre)
0.6
1.0
2.0
2.0
4.0
1.06
0.5
1.0
.6/100 Ib seed
.0/100 Ib seed
2.0
1.0
3.0
1.0
2.0
0.6
1.0
3.0
3.0
3.1
3.1
3.7
3.7
Yield
increase*
(Ib/acre)
8
37
73
(98)
65
(192)
328
277
152
87
(119)
(38)
851
83
523
396
917
395
130
300
(60)
820
60p
Additional
income*
($/acre at
40.7c/lb)
3.26
15.06
29.71
(39.89)
26.46
(78.14)
133.50
112.74
61.86
35.41
(48.43)
(15.46)
346.36
33.78
212.86
161.17
373.22
160.77
52,91
122.10
(24.42)
333.74
(244.20)
Aldicarb cost Economic
at $9.50/lb
($/acre)
5.70
9.50
19 . 00
19 . 00
38.00
10.07
4.75
9.50
5.70
9.50
19.00
9.50
28.50
9.50
19.00
5.70
9.50
28.50
28.50
29.45
29.45
35.15
35.15
benefit*
($ /acre). Source
(2.44) a/
5.56
10.71
(58.89)
(11.54)
(88.21)
128.75 b/
103 . 24
56.16
25.91
(67.43)
(24.96)
317.86
24.28
193.86
155.47
363.72
132.27
24.41
92.65
(53.87)
298.59
(279.35)

-------
                                             Table 14.  (Continued)
i
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Date
1966


1966

1965
1965
1966
1966
1966


1966















Application
(Ib Al/acre)
0.98
1.94
3.68
1.1
2.5
1.0
3.0
3.0
3.0
1.0
2.0
3.0
1.0
2.0
3.0
0.55
1.25
1.72
2.56
0.60
1.38
1.90
2.68
1.0
1.0 + 1.0
1.0 + 2.0
1.0 + 3.0
Yield
increase*
(Ib/acre)
892
839
586
230
365
(38)
851
1,253
1,281
(210)
360
(100)
320
250
350
558
661
1,413
1,224
300
230
60
(70)
(281)
(281)
150
207
Additional
income *
($/acre at
40.7c/lb)
363.04
341.47
238.50
93.61
148.56
(15.46)
346.36
509.97
521.37
(85.47)
146.52
(40.70)
130.24 .
101.75
142-45
227.11
269.03
575.09
498.17
122.10
93.61
24.42
(28.49)
.(114.37)
(114.37)
61.05
84.25
Aldicarb cost
at $9.50/lb
($/acre)
9.31
18.43
34.96
10.45
23.75
9.50
28.50
28.50
28.50
9.50
19.00
28.50
9.50
19.00
28 . 50
5.23
11.88
16.34
24.32
5.70
13.11
18.05
25.46
9.50
19.00
28.50
38.00
Economic
benefit*
($/acro) Source
353.73 b/
323.04
203.54
83.16
124.81
(24.96)
317.86
481.47
492.87
(94.97)
127.52
(69.20)
120.74
82.75
113.95
221.88
257.15
558.75
473.85
116.40
80.50
6.37
(54.95)
(123.87)
(133.37)
32.55 .
46.25

-------
                                              Table 14  (Continued).
i
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i



Date
•M^^^MW
1966


1967
1968
1970




1972

1970

1972

1972

1972


. 1972
1972



Application
(Ib Al/acre)
0.1
0.25
0.5
1.0
1.0
0.6
2.1
0.9
1.8
1.0
0.8
1.2
1.0
2.0
1.0
1.125
1.0
0-5
0.33
0.67
1.0
0.5
2.0
2.0

Yield
increase*
(Ib/acre)
614
937
970
54
152
• 296
384
351
394
381
309
443
307
164
11
231
433
221
907
898
701
595
632
846
Additional
income*
($/acre at
40.7c/lb)
249.90
381.36
394.79
21.98
61.86
120.47
156.29
142.86
160.36
155.07
125.76
180.30
124.95
66.75
4.48
94.02
176.23
89.95
369.15
365.49
285.31
242.17
257.22
344.32

Aldicarb cost
at $9.50/lb
($/acrc)
0.95
2.38
A. 75
9.50
9.50
5.70
19.95
8.55
17.10
9.50
7.60
11.40
9.50
19.00
9.50
10.69
9.50
4.75
3.14
6.37
9.50
4:75
19.00
19.00

Economic
benefit*
f$/acre) Source
248.95 b/
378.98
390.04
12.48 £/.
52.36
114.77 d/
136.34
134.31
143.26
145.57
118.16 £/
168.90
115.45 I/
47.75
(5.02) SJ
83.33
166.73 . h/
85.20
366.01 I/
359.12
275.81
237.42 £/
238.22 JL/
325.32 y

-------
                                             Table 14.  (Continued)
i
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Date
1971


1965
1965
1965
1965
1965
1966
1966
1966
1966
1966
1966
1967
1967
1967
1967
1967
1967
1968
1968
1968
1968
1969
1969
1969
1969


Application
.(lb Al/acre)
0.25
0.5
1.0
1.0
2.0
0.5
1.0
2.0
0.5
0.1
0.25
0.5
1.0 + 2.0
1.0 + 4.0
0.5
0.75
0.25
0.1
0.25
0.5
0.25
1.0
0.25
0.5
0.25
0.1
0.25
0.5

Yield
increase *
(Ib/acrc)
300
197
50
83
523
(114)
157
538
1,258
614
937
970
150
206
310
542
585
10
321
134
277
207
280
81
363
675
293
266
Additional
income*
($/acre at
40.7c/lb)
122.10
80.18
20.35
33.78
212.86
(46.40)
63.90
218.97
512.01
249.90
381.36
394.79
61.05
83.84
126.17
220.59
238.10
4.07
130.65
54.54
112.74
84.30
113.96
32.97
147.74
274.73
119.25
108.26

Aldicarb cost
at $9.50/lb
($/acre)
2.38
4.75
9.50
9.50
19.00
4.75
9.50
19.00
4.75
0.95
2.38
4.75
28.50
47.50
4.75
7.13
2.38
0.95
2.38
4.75
2.38
9.50
2.38
4.75
2.38
0.95
2.38
4.75

Economic
benefit*
_C$/acrc) Source
119.72 W
75.43
10.85
24.28
193.86
(51.15)
54.40
199.97
507.26
248.95
378.98
390.04
32.55
36.34
121.42
213.46
235.72
3.12
128.27
49.79
110.36
74.80
111.58
28.22
145.36
273.78
116.17
103.51

-------
                                            Table 1A.   (Continued)
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Date
1970
1970
1970
1971
1971
1971
1971
1971
1971
1971
1971
1972
1972
1972
1972
1972
1972
1972

Application
(Ib Al/acre)
0.25
0.5
0.1
0.1
0.25
0.5
1.0
0.25
0.5
1.0
0.25
0.25
0.25
0.25
0.5
0.25
0.25
0.5
Yield
increase*
(Ib/acre3
545
536
207
232
260
223
330
117
308
366
155
657
137
195
198
49
53
171
Additional
income* Aldicarb cost
($/acre at
40.7c/lb)
221.82
218.15
84.25
94.42
105.82
90.76
134.31
47.62
125.35
148.96
63.09
267.40
55.76
79.37
80.58
19.94
21.57
69.60
at $9.50/lb
($/acrc)
2.38
4.75
0.95
0.95
2.38
4.75
9.50
2.38
4.75
9.50
2.38
2.38
2.38
2.38
4.75
2.38
2.38
4.75
Economic
benefit*
($/acre) Source
219.44 k/
213.40
83.30
93.47
103.44
86.01
124.81
45 . 24
120.60
139.46
60.71
265.02
53.38
76.99
75.83
17.56
19.19
64.85

-------
                                            Table 14.   (Continued)
ro
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i


Date
1973
1973
1973
1973
1973
1973
1973


Application
(Ib Al/acre)
0.3
0.6
0.15
0.3
0.6
0.5
1.0

Yield
increase*
(Ib/acre)
89
120
130
281
189
228
215
Additional
income*
($/acre at
40.7c/lb)
36.22
48.84
52.91
114.37
76.92
92.80
87.50

Aldicarb cost
at $9.50/lb
($/acre)
2.85
5.70
1.43
2.85
5.70
4.75
9.50

Economic
benefit*
($/acre) Source
33.37
43.14
51.48
111.52
71.22
88.05
78.00
                                                                                           benefit.
*  Data in parentheses indicate decreases in yield,  income,  and economic
JL/  Union Carbide Corp., EPA Pesticide Petition Files,  Section 11.
b/  Union Carbide Corp., EPA Pesticide Petition 8F0637.
£/  Bcckham, op cit. (1970).
jd/  Davis and Cowan, op cit. (1972).
e/  Davis and Cowan, op cit. (1974).
£/  Birchfield, W., "Cotton," Fungicide and Nematocide Test Results of 1970t Report No. 277,
      American Phytopathologlcal Society, St.  Paul, Minn.  (1970).
_£/  Blackman, op cit. (1972).
h/  Birchfield, op cit. (1972).
il  Bird et al., op cit. (1972).
j/  Smith, F. H., "Cotton." Fungicide and Nematocide Test Results of 1972, Report No. 312,
      American Phytopathological Society, St.  Paul, Minn.  (1972).
k/  Bost, op cit.  (1974).
Note:  AI = active ingredient.

-------
                               Table 15.   1974 RESULTS OF TEMIK® APPLICATION ON COTTON








1
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i




Location
Calif. -Ariz.
Calif. -Ariz.
Texas
N.C.-S.C.
Ark. -Mo.
Georgia
Alabama
Mississippi
S.C
S.C.
S.C.
S.C.
S.C.
Average, All
Application
(Ib Al/acre)
.6
2.0
.6
.6
.6
.6
.6
.6
.6
.6
.5
.5
.5
Tests .6
Yield Change
(Ib)
79
144
93
11
73
274
390
40
0
25
50
25
25
75.6
Value of —'
Yield Change ($)
32.15
58.61
37.85
4.78
29.71
111.52
158.73
16.28
0
10.18
20.35
10.18
10.18
30.77
Temik®.?/
Cost
5.70
19.00
5.70
5.70
5.70
5.70
5.70
5.70
5.70
5.70
4.75
4.75
4.75
5.70
Economl c 3/
Benefit
26.45
39.61
32.15
-1.22
24.01
105.82
153.03
10.58
-5.70
4.78
15.60
5.43
5.43
25.07
No.
Tests
14
N/S
25
20
5
10
2
45
1
1
1
1
1

I/  Change in cotton yield x $.407/lb (1972 average price).
21  Lb Al/acre x $9.50/lb AI; since most Temik ® Is applied at planting, application cost (usually calculated
      with planting costs) is not evaluated.
3/  Value of Yield Change minus Temik ® Cost equals Economic Benefit.
Note:  N/S - pests not specified;  AI ~ active ingredient.
Source:  Comparative yield data submitted to EPA by Dr. Richard Back, Union Carbide Corporation, Washington, D.C.

-------
                               Malathion
     The use of malathion on cotton is primarily for control of the boll
weevil as it enters diapause.  It is also recommended in some areas for
the  control of thrips, two spotted spider mites and grasshoppers.

Efficacy Against Pest Infestation - The three major insects that attack
cotton are the tobacco budworra, the bollworra and the boll weevil.  Malathion
is relatively ineffective against the budworm and bollworm and is not
recommended in some states for this use against those insects.  In a test:
of several organophosphate insecticides, Plapp (1971)—' found that malathion
was  not highly toxic to either the budworrn or bollwora.  Similar results
were obtained by Cowan and Davis (1968).?/ who concluded that malathion did
not  control bollworms or tobacco budworras.

     Malathion has been found to be effective on  the boll weovil  as  i-t
enters diapause.  Lloyd et al. (1972)!/ concluded  that  ULV  formulations
of malathion gave effective control of boll weevils during  tests  con-
ducted in 1966 and 1967 in Carroll County and State College,  Mississippi.
Applications of 0.25 to 0.50 Ib of malathion every 4 to 5 days  provided
effective control.  Cowan and Davis (1968) also concluded that  ULV appli-
cations of malathion at 0.4 to 0.8 Ib/acre gave good control  of the  boll
weevil.  These tests were conducted at Waco, Texas, in  1967.
J./  Plapp, F. W., Jr., "Insect Resistence inHeliothis:  Tolerance  in
      Larvae of 11. virescens as Compared with II.  zea to Organophosphate
      Insecticides," J. Econ. Entomol.. 64:999-1002 (1971).
2f  Cowan, C. B., Jr., and J. W. Davis, "Field Tests with Conventional
      Low Volume and Ultra-Low-Volume Sprays for  Control of the Boll
      Weevil, Bollworm and Tobacco Budworm on Cotton in 1967," J. Econ.
      Entomol.. 61:1115-1116 (1968).
J3/  Lloyd, E. P., J. P. McCoy, W. P. Scott, E. C. Burt, D. B. Smith, and
      F. C. Tingle, "In-Season Control of the Boll Weevil with Ultra-
      Low-Volume Sprays of Azinphosmcthyl or Malathion," J. Econ. Entomol.,
   •   65:1153-1156 (1972).
                                     -284-

-------
     There appears to be little change in the efficacy of malathion to
the boll weevil.  Namec and Adkisson (1968 to 1972)17 have conducted
toxicity tests of insecticides to the boll weevil.  Data since 1968 are
shown below.
Table 34.  MALATHION EFFICACY TESTING RESULT ON BOLL WEEVILS
Insecticide

Malathion
Malathion
Malathion
Malathion
Malathion
  Lb/acre
    0.5
    1.0
7. kill (48 hr)

      78
      92
      82
     100
     100
Year

1968
1969
1970
1971
1971
     Cantu and Wolfenbarger (1969 to 1972).?/ have conducted tests on the
toxicity of two spotted spider mites to malathion.  The results as shown
below do not indicate any reduction in efficacy over a 4-year period.
Table 35.  MALATHION EFFICACY TESTING RESULTS ON SPIDER MITES


Insecticide
7o concentration
	(ppm)	
   7. kill after 72 hr
     (foliar spray)
Malathion
Malathion
Malathion
Malathion
Malathion
Malathion
Malathion
Malathion
      0.25
      0.01
      0.25
      0.01
      0.25
      0.01
      0.25
      0.01
           90
           27
           88
           24
           86
           20
           88
           20
 Year

 1969
 1969
 1970
 1970
 1971
 1971
 1972
 1972
     On the basis of these results it appears that there is no reduction
in the efficacy when malathion is used to control the boll weevil and two
spotted spider mites.
I/  Nemec, S. J., and P. L. Adkisson, "Laboratory Tests of Insecticides
      for Bollworm, Tobacco Budworm and Boll Weevil Control," Investiga-
      tions of Chemicals for Control of Cotton Insects in Texas  (1968-1972)
2/  Cantu, E., and D. A. Wolfenbarger, "Effectiveness of Experimental
      Insecticides for Control of the Tobacco Budworm, Boll Weevil, Fall
      Armyworm, and Two Spotted Spider Mites," Investigations of Chemicals
      for Control of Cotton Insects in Texas (1969-1972).
                                          -285-

-------
Cost Effectiveness  of Pest  Control  - There have been a limited number of
studies on the change in cotton yield due only to the use of malathion.
It is most often used in mixtures with methyl parathion to control the
budworm and the boll weevil.

     Yield increases from tests comparing malathion-treated cotton to
untreated test plots varied widely  depending .upon the number of applica-
tions and the degree of pest  infestation.  Data were only available from
seven tests conducted in Mississippi and Texas.

     The wide range in yield  increase is often due to the variance in
the rate of pest infestations.   Pfrimraer et al. (1971)!.'  reported that
during tests in 1969 a field  that normally produced 1,500 to 2,000 Ib
of seed cotton per  acre produced only one-tenth of the normal yield
without any insecticidal treatment.

     The 1972 price received  by farmers for cotton was 24.0c/lb for
lint.  Additional income from cottonseed at 4.2c/lb and government price
supports of 12.5c/lb brought  the total income to 40.7c/lb of cotton
(Agricultural Statistics, 197l2/).   Malathion costs averaged $1.20/lb
(Bost 19743/); application costs are $1.25 per treatment.  Economic
benefits would range from $5.95 to  $683.96.

     The range of yield changes from all of the data reviewed varied
from a small gain of 20 Ib/acre to  a substantial increase of 1,730
Ib/acre when compared to untreated  test plots.   The economic benefit
after subtracting the cost  of the malathion ranged from $6.70/acre to
$700.21/acre.
I/  Pfrimmer, T. R., R. E. Furr, and E. A. Stadelbocher,  "Materials for
      Control of Boll Weevils, Bollworms, and Tobacco  Budworms  on Cotton
      at Stoneville, Mississippi," J. Econ. Entomol..  64:475-478 (1971).
I/  Agricultural Statistics 1973. U.S. Department  of Agriculture (1973).
3/  Bost, W. M., Director, Cooperative Extension Service,  Mississippi
      State, Mississippi, personal letter to D. F.  Hahlen (1974).
                                         -286-

-------
     The results of the yield tests are tabulated below.

Table 36.  YIELD AND BENEFIT ANALYSIS RESULTS OF MALATHION ON SELECTED
           COTTON PESTS
                                                  Application


Date
1956
1956
1958
1967
1967
1967
1967
Application

Rate
(Ib Al/acrc)
1.0
1.0
0.5
0.25
0.5
0.4
0.8


No.
5
9
7
13
13
3
3
Yield
increase
(Ib/acrc)
205
458
714
1,730
1,170
20
40
Additional
income
($/acre at
40.7C/1M
83.45
186.41
290.60
704.11
476.19
8.14
16.28
Cost at $1.20/lb
plus treat- Economic
meat cost
at $1.25/
effort
12.25
22.05
12.95
20.15
24.05
2.19
3.63
benefit
($)
71.20
164.36
277.65
683.96
452.14
5.95
12.65

Source
a/
a/
£/
£/
a/
b/
y
£/  Bost,  oa,  cjjt.  (1974).
b/  Cowan  et  al., op. ctt. (1968).
                                           -287-

-------
                                   Parathion
      Parathion  is  registered  for  a wide variety of  cotton  insects.   The
 tobacco  budworm, bollworra, boll weevil, aphids, fleahoppers,  leaf hoppers,
 cabbage  loopers, spider mites, and thrips  are major cotton pests  treated
 with parathion.  Application  rates vary from 0.25 to 1.0 Ib/acre, depend-
 ing upon the  type  of  insect.  The number of  applications depends upon
 the degree  of infestation.  Repeated  applications are recommended for the
 bollworm, budworm,  and boll weevil until adequate control  is  achieved.

 Efficacy Against Pest Infestation - Data is  available on the  efficacy of
 parathion for control of  the  budworm,  bollworm, and boll weevil— the three
 major cotton  pests—'from tests conducted  in Texas.

      Adkisson et al.  (1966)i' compared a wide variety of insecticides
 for control of  bollworm larvae near College  Station, Texas in 1965.   The
 use of parathion resulted in  a 70% kill after 48 hr when applied at  0.5
 Ib/acre.

      Adkisson et al.  (1967)^.' conducted similar tests in 1966 and reported
 an 85% kill of  bollworm larvae 48 hr  after parathion was applied at  0.5
•Ib/acre.  Parathion was also  less effective  against the  budworm with an
 83% kill at 0.75 Ib/acre  after 48 hr  compared to a  97% kill for 0.75
 Ib/acre  of  methyl  parathion.  Against  adult  boll weevils,  0.25 Ib/acre of
 parathion resulted  in a 97% kill  after 48  hr compared to 100% for methyl
 parathion at  the same rate.

      Wolfenbarger  (1973)^' found  that  tobacco budworms from a susceptible
 strain were 2.45 times more resistant  to parathion  than  to methyl para-
 thion during  tests  conducted  in Brownsville, Texas  in 1970.
 I/ Adkisson,  Perry L., and  S. J. Nemec,  "Comparative  Effectiveness of
       Certain  Insecticides for Killing  Bollworms  and Tobacco Budworms,"
       Publication  B-1048, Texas Agr.  Exp.  Sta.  (1966).
 2/ Adkisson,  Perry L., and  S. J. fremec,  "Insecticides  for Controlling
~~\^__the  Bollworm, Tobacco  Budworm,  and  Boll Weevil,"  MP-837,  Texas Agr.
       Exp.  Sta.  (1967).
 J3/ Wolfenbarger,  D. A., "Tobacco Budworm:   Cross Resistance to Insecti-
       cides in Resistant Strains and  in a Susceptible  Strain,"  J.  Econ.
       Entomol..  66:292-294 (1973).
                                       -288-

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Cost Effectiveness of Pest Control - Information was found on .only one
test relating yield changes to parathion usage.  Bost (1974)-'  summarized
tests conducted between 1956 and 1973 at Stoneville, Mississippi.  The re-
sults of one test in 1956 showed a 253 Ib/acre gain over an untreated check
vhen nine applications of parathion at 0.5 Ib/acre were made.

     The 1972 price received by farmers for cotton was 14.0c/lb for lint.
Additional income from cottonseed of 4.2c/lb and government price supports
of 12.5c/lb brought the total income to 40.7c/lb (Agricultural Statistics,
1973).-'  Parathion costs averaged $l/lb in 1972, while application costs
averaged $.50 per treatment (Chambers et al., 1974).-'

     Using the above cost and price data, the additional income would
amount to $102.98/acre.  Subtracting the cost .of parathion at §9.00/acre
would result in an economic benefit of $93.98/acre when"parathion was used
to control boll weevils, bollworms, and tobacco budworms.
  \J  Bost, W. M., Director, "Cooperative Extension Service Mississippi
       State University, Mississippi State Mississippi, Summary of Test
       Results at Stoneville and Verona, Mississippi, and Costs of Pesti-
       cides," personal letter to Mr. David F. Hahlen (1974).
  2J  U.S. Department of Agriculture, Agricultural Statistics 1973.
  3J  Chambers, William, and Daniel Miller,Farmland Industries, Kansas
       City, Missouri, conversation (1974).
                                     -289-

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                Ill  D.2

                APPENDIX


THE VALUE OF DDT IN  COTTON PRODUCTION



     PRELIMINARY SUMMARY REPORT

                  TO

   ENVIRONMENTAL PROTECTION AGENCY


          CONTRACT  #  68-01-2483
             JULY L 1975
      MANAGEMENT SCIENCE SYSTEMS
       6121 Lincolnia Road • Alexandria, Va. 22312 • (703)750-2660
                  -290-

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     Some farmers and  their  representatives  contend that they should



be allowed, once again, to use DDT  in  the  production of cotton.  The



question of social costs and benefits  must be  answered.  The social



costs of using DDT are still very controversial  and this study does



not attempt to address them.  The purpose  here is,  rather,  to assess



the potential benefits of allowing  DDT utilization  in cotton produc-



tion.





     In order to allow for both within and among region changes in



crop production within a framework  which takes account of historic



responsiveness, >a constrained optimization.model was employed.  The



lineas: programming  (LP) model previously developed  by MSS was modi-








(BASE2) which allowed  DDT for cotton in 1975;  and an alternative



which did not (COTQDl).





The Linear Programming Model



     Activities were defined by producing'  (129)  regions to provide



for



     «•  production of  crops  (by method, land class  and region) ;



        and



     e>  costs of change from historic,  production patterns.



Activities were defined 3>y consuming1 region  '.?':)  to pro-ride for



     ft  exports of: co*r;p.oo:lties;



     o  utilization of commodities  for faod; and



     e.  trcu.ispor.tation of corn;::oditios  between  pairs of consuming



        regions.



                                -291-

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Constraints were defined by producing  are to

      e  limit land use to the quantity actually available (by

         land class);
      •  to provide crop acreage targets;  and

      •  limit the proportion of cotton acreage using DDT.

Constraints were defined by consuming  region to

      •  balance commodity production and  demands.

The  objective was to  minimize production  cost, transportation cost
and  flexibility penalties.

The  Base Model

      The LP model constrained the maximum production of  cotton using

DDT  and using no pestu'cides to be no greater than the proportions

shown in Table 1.  The "Doane" regions referred to are:

      2 - Georgia, Carolinas, Virginia;
      3 - Texas, Oklahoma;
      4 - Kentucky, Tennessee, Alabama,  Arkansas, Mississippi and
          Louisiana;
      5 - Missouri; and

      6 - California,  Arizona, New Mexico.
As Table 1 shows, only regions 2 and 4  utilized DDT in any signifi-
cant  proportion.

    Two benefits may accrue to the use of DDT—decreased costs and increased efficacy.
This analysis focuses on the interregional impacts of changes in cost which resulted
from the DDT cancellation. The questions of efficacy and yield effects were evaluated
only in as much as  fewer applications per year were assumed to be required with DDT.
This phenomena was  reflected in regional insecticide cost estimates.   A second cost
impact occurs because DDT
                                 -292-

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costs less than alternative insecticides.  Table 1 shows the assumed



costs of insecticide  (including application) when DDT is allowed and



when it is not.





     In the LP model three distinct cotton production activities were



defined on each land class in each producing area:



     ©  Cotton with DDT  (constrained to be less than the proportion



        of total cotton shown in Table 1);



     ®  Cotton with other insecticides;



     ©  Cotton with no insecticides (constrained to be less than the



        proportion receiving none as shown in Table 1).





Results of the Base Model



     Tables 2 and 3 illustrate the conformance of the model results



with both observed and projected acreages and total production.  All



results are somewhat lower than the observed and projected levels.



This occurs because of substantially lower export requirements shown



in Table 4.  With lower total demands, of course the acreage and



production will decline.





     Table 5 shows the regional distribution of cotton production



for both models and for observed. 1973.  The distribution in the models



show a greater concentration in Texas than has been observed histori-



cally.  Otherwise the distribution is quite similar.





     Table 6 shows the regional distribution of cotton acreages



among the insecticide options.  These data correspond with the upper



limits imposed on "DDT" and "No Pesticides" as shown in Table 1.
                                -293-

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Results of the No DDT Model (COTQD1)



!     With DDT disallowed, certain production shifts must occur.  The



farmers who had used DDT must replace it with some other insecticide



or stop producing cotton.  As shown in Table 5, very few reduced pro-



duction.  The Atlanta region declined by 3,900 acres (.4%), Memphis



declined. 8,900 acres (.4%), New Orleans declined by 24,000 acres



(7.2%), Louisville declined by 600 acres (34,0%) and San Francisco



increased by 17,500 acres  (2.2%).  Since the yield is higher in the



San Francisco region, total production remained constant even though



total acreage declined by 19,900 acres  (.18%).





     It follows that most farmers utilized other, higher cost, insecti-



cides.  Table 7 shows that this is the case.  Comparing it with



Table 6 shows that nearly all the cotton previously using DDT was
                             -__T^ 4- r
     The land idled by those farmers who elected not to grow cotton



in the southeast and delta states was generally left idle, although



2,250 acreas in the Atlanta region were planted to soybeans.  In



Memphis, cotton is shifted to higher yielding land classes, causing



a degradation in soybean and oat yields there.  The land in San



Francisco on which cotton production was increased was previously



slack; thus no shift in other crops was observed.






      There  was  a  negligible  impact  on  equilibrium  prices  which  are,



by definition,  the marginal  cost  of production.  Since  each region



was  forced  in each solution  to  produce some  cotton using  other  in-



secticides  for  each  acre  using  DDT,  and since there was no direct
                                -294-

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yield impact, the marginal cost of production was not increased by



the removal of the low cost option.  Thus comsumers are not noti-



ceably impacted by the removal of DDT.






     Average costs were, of course, increased.  This reduces the



return to land,  which is a proxy for net farm income.  Table 8




illustrates the changes in land values.  The Memphis region suf-



fered most with a decline of 1.93% in return to land.  Other



regions in the southeast and delta also suffered some loss with



Atlanta declining .37% and New Orleans declining .93%.  The San



Francisco region, conversely, realized a gain of .26%.  These



changes are quite small even on a regional basis—although some



individual farmers may suffer substantial losses.  At the national



level, the returns to land declined by .08%.





Summary and. Conclusions



     Given the data on comparative insecticide costs and DDT upper



limits, the impact of restricting DDT use on cotton is quite small.



The national impact is negligible for both producers and consumers.



Regionally, there are small losses in some regions and gains in one



for producers.  On the basis of this study, we must conclude that the



value of DDT in cotton production is not overwhelming.
                                -295-

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Table 1.  Historic cotton insecticide use.
Doane
ReQion
  2
  3
  4
  5
  6
Insecticide Cost    Proportion Treated
DDT
$ acre
48.53
-
24.47
. -
—
Other
$/acre
59.60
15.03
27.05
6.19
12.38
DDT Any
30.00
-
26.9
—
—
93.1
27.2
79.0
28.0
72.4
 Table  2.   Comparison of observed and projected planted
           acreage (million acres).
                 1973
Barley
Corn
Cotton
Soybeans
Oats
Sorghum
Wheat

	Total
     11.33
     71.61
     12.50
     57.30
     19.21
     16.26
    247.22
T-imi=>-f-ri=>nrl
  1975	

   11.33
   66.85
   12.62
   55.72
   15.01
   15.66
   _58.49

  235.68
Mnd p 1
 1975

  8.38
 54.18
 10.97
 49.35
 10.32
 15.05
.45.00

193.25
                             -296-

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Table 3.  Comparison of observed and projected  crop
          commodity production  (millions).
                  Observed   Time Trend    Model
                    1973        1975         1975

Barley  (bu)          424.2      460.2        337.8
Corn  (bu)          5,636.6    5,760.1     5,389.7
Cotton  (ba)           13.2       13.3        11.2
Soybeans  (bu)      1,568.4    1,508.8     1,622.6
Oats  (bu)            663.2      564.2        457.0
Sorghum  (bu)         936.6      946.1        865.8
Wheat (bu)         1,.711.2    1,826.5     1,402.9
Cottonseed  (cwt)      98.96     110.0        92.7
Table  4.   Comparisons  of  observed and projected crop
           commodity  consumption  and export (millions)
               Domestic  Consumption            Export
               (excluding  Feed)
              Observed      Model        Observed      Model
              	1973        _L9.7JL          1973          1975

Barley  (bu)      145.        186.1           66.0         50.5
Corn  (bu)        423.0       769.5        1,258.0        932.5
Cotton  (ba)        7.47        7.4            5.0          3.8
Soybeans1        141.0       180.9          681.         565.9
Oats  (bu)         03.0       124.4           24.0          5.0
Sorghum  (bu)       6.0        33.9          212.0         74.6
Wheat  (bu)       526.4       608.7        1,184.2        701.9
Cottonseed1(cwt)   9.7        12.4           37.0         26.3
  Estimated
                             -297-

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Table 5.  Regional Distribution of cotton acreage as
          percent of US total:  base model, with DDT
          disallowed, observed 1973.
Ar.la.nta
Jacksonville
Memphis
Houston
New Orleans
Louisville
St. Louis
Amarillo
San Francisco
Los Angeles
—Total
Observed
1973
11.28
.09
23.19
18.04
4.34
.003
1.50
31.09
7.17
3.28
Bcise Mode
1975
8.48
.11
21.70
20.60
3.04
.02
.83
36.26
7.14
1.81
100.00
100.00
DDT Disallowed
_	1.975

    8.46
     .11
   21.66
   20.64
    2.83
     .01
     .83
   36.32
    7.31
    1.82
  100.00
Table 6.  Regional distribution of cotton acreage by
          insecticide treatment:  base model (million
          acres).
   Region

Atlanta
Memphis
Houston
New Orleans
Louisville
St. Louis
Amarillo
San. Francisco
Los Angeles
—Total
NO
Pesticide
.125
.500
1.645
.070
-
.066
2.842
.216
.055
5.520

DDT
.266
.641
-
.090
-
-
-
-
-
.996
Other
Pesticides
.539
1.241
.615
.174
.002
.026
1.133
.567
.144
4.439
Total
Acreage
.930
2.381
2.260
.334
,002
.091
3.978
.783
.199
10.972
                             -298-

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Table 7.  Regional distribution of cotton acreage by
          insecticide treatments:  model with DDT
          disallowed (million acres).
   Region

Atlanta
Jacksonville
Memphis
Houston
New Orleans
Louisville
St. Louis
Amarillo
San Francisco
Los Angeles
—Total
    No
Pesticides

   .124

   .498
  1.645
   .065

   .066
  2.842
   .221
   .055
  5.517
DDT
   Other
Pesticides
Total
.802
-
1.874
.615
.245
.001
.026
1.133
.580
.144
.926
.012
2.372
2.260
.310
.001
.091
3.978
.801
.199
        5.419
           10.952
Table  8.  Returns to land by region.
   Region
Atlanta
Jacksonville
Memphis
Houston
New Orleans
Louisville
St. Louis
Anarillo
San Francisco
Los Argeles
      Base
     Model
      DDT
   Disallowed
                  ($ million)    ($ million)
     45.35
      3.74
     63.53
     48.38
     10.47
     11.95
     44.39
    121.48
     33.41
      7.73
          Change
45.19
3.74
62.30
48.38
10.37
11.95
44.39
121.48
33.50
7.73
- .37
0.00
-1.93
0.00
- .93
0.00
0.00
0.00
+ .26
0.00
                             -299-

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I
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                                                          S       ^ MOINES


                                                             OMAHA ,\        O /CHICAG
KANSAS • \   IlOUIS*

CITY

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