AUGUST 1976
                    Criteria and Evaluation Division
                    Office of Pesticide Programs
                     Washington, D.C. 20460

August 1976
Criteria and Evaluation Division
Office of Pesticide Programs
U.S. Environmental Protection Agency
Washington, D.C.  20460

Mention of trade names or commercial
products does not constitute endorse-
ment or a recommendation for use.


     On May 7, 1974, the Environmental Protection Agency published

in the Federal Register a statement of policy announcing its inten-

tion to prepare Environmental Impact Statements in connection with

its most significant regulatory actions, although not required to

do so by law.  On October 21, 1974, the Agency published procedures

for the preparation of such voluntary statements and specified the

regulatory actions that would be covered, including actions to cancel

registered uses of pesticide products containing certain chemicals

thought to cause unreasonable adverse effects on the environment, as

provided for under section 6(b) of the Federal Insecticide, Fungicide

and Rodenticide Act, as amended.  This is the first draft Environmental

Impact Statement submitted in connection with a section 6(b) action.

     A notice of intent to cancel certain registered uses of pesticide

products containing chlordane and heptachlor was published in the

Federal Register on November 26, 1974.  The notice stated that an

Environmental Impact Statement would be available in approximately

60 days.  However, unforeseen delays were encountered and the statement

has only now become available.

     On July 29, 1975, the EPA Administrator issued a notice of intent to

suspend the registration of uses of pesticide products containing chlordane

and heptachlor for all uses for which cancellation had been proposed,

pending a final cancellation decision.  On December 24, 1975, the

Administrator issued a notice of suspension.

     Single copies of the draft impact statement are available to all

agencies, organizations and individuals who are interested in the pro-

posed cancellation of heptachlor and chlordane uses.  Their comments

are invited.  A public hearing, which is underway, was requested by persons

who may be adversely affected by actual cancellation.  Comments received

from reviewers of the draft impact statement will be made available to

assist any party in its participation in the hearing.  During the hearing,

parties may raise, in the form of testimony and exhibits for the record,

any issues prompted by comments on the draft impact statement.  Otherwise,

comments submitted on the draft statement will be included in the record

of the hearing only if the person submitting the comment indicates a

willingness to appear at the hearing for the purpose of cross-examination

on the comment submitted.

     Comments on this draft statement, including an expression of

willingness or unwillingness to appear as a witness at the cancellation

hearing, should be sent to the following address:

                    Federal Register Section
                    Technical Services Division (WH-566)
                    Office of Pesticide Programs
                    Environmental Protection Agency
                    Room 401, East Tower
                    401 M Street, S. W.
                    Washington, D. C.  20460




  I.  BACKGROUND	     1


      A.   Alternatives Considered 	

      B.   Four Major Alternatives Examined  	

          Alternative 1	    13
          Alternative 2	    17
          Alternative 3	    26
          Alternative 4	    29

      C.   Alternatives Compared 	    32



      1.   Notice of Intent to Cancel	    41

      2.   Estimated Domestic Use of Chlordane and Heptachlor  ....    44

      3.   Examples of Possible Substitutes for Chlordane
          and Heptachlor	    45

      4.   Quantity of Chlordane and Heptachlor Used,
          by Alternative	    49

      5.   Estimated Impact of Alternative Courses of
          Action	    50

      6.   References	    51

                                SUMMARY SHEET


                        OFFICE OF PESTICIDE PROGRAMS

 1.   Name of Action:

     Administrative, as authorized under section 6(b) of the Federal

     Insecticide, Fungicide, and Rodenticide Act, as amended.

 2.   Description of Action:

     On November 26, 1974, the Environmental Protection Agency published

     in the Federal Register a notice of intent to cancel all registered

     uses of pesticide products containing chlordane and heptachlor, ex-

     cept subsurface applications.  This action will be followed by a

     public hearing and final decision by the EPA Administrator.

     Because chlordane and heptachlor are used for such a variety of

     pesticidal purposes, the effects of cancellation will be felt through-

     out the United States.  However, a particularly noticeable impact is

     expected in the states of Ohio, Indiana, Illinois, Iowa and Missouri

     where, in corn production, these chemicals receive their greatest

     agricultural use.

3.   Summary of Environmental Impact:

     Current uses of these chemicals are producing widespread environmental

     contamination.  Residues are found in soil, air, water and food and in

     wildlife and man.  EPA has concluded on the basis of scientific

     evidence that these chemicals are carcinogenic and that their

     omnipresence in the environment represents a serious health risk.


      The intended cancellation,  if  carried out, would lead  to substantial

      reduction in environmental  residues, with consequent reduction  in  the

      risk of illness and death and  the  accompanying  economic and  social

      costs.   However, cancellation  will also have  some adverse  effects.

      Allowing continuation of chlordane and heptachlor use  for  subsurface

      ground  insertion for termite control will permit continuation of what

      is thought to be a slight long-term human health risk.   (However,  that

      risk is accepted in order to avoid the substantial  economic  and social

      impact  expected if that use, for which there  do not appear to be any

      effective, environmentally  preferable substitutes,  were  cancelled.)

4.    Alternatives Considered:

      *  No Cancellation Action

      *  Cancellation of All Uses

      *  Cancellation of All Uses Except Subsurface Ground  Insertion  for

         Termite Control and the  Dipping of Roots  or  Tops of Nonfood  Plants

         (The selected alternative)

      *  Cancellation of Food and Feed Crop Uses  Only

5.    Agencies and Organizations  From Which Comments  Have Been Requested:


        Department of Agriculture
        Department of Commerce
        Department of Interior
        Department of Health, Education, and  Welfare


        Each state pesticide control agency

        Each state "clearinghouse" agency,  as defined in OMB Circular A-95


          Registrants of chlordane and heptachlor products

          Velsicol Chemical Corporation

          National chemical and agricultural trade associations

          National environmental and conservation organizations

          Any parties to the public hearing not included in the above

 6.      The Council on Environmental Quality (CEQ) will issue a notice

        (approximately in September 1976) in the Federal Register on

        the draft impact statement's public availability.  Comments are

        due 45 days from publication of the CEQ notice listing the

        public availability of this statement.

 7.      Individual Copies May Be Obtained:

        Free of charge from:

        Federal Register Section
        Technical Services Division (WH-569)
        Office of Pesticide Programs
        Environmental Protection Agency
        Room 401, East Tower
        401 M Street, S. W.
        Washington, D. C.  20460


        For sale by:

        U. S. Department of Commerce
        National Technical Information Service
        Springfield, Virginia ^22151

        This draft impact statement is accompanied by supporting documentation

which includes reviews of information on chlordane and heptachlor and the

economic implications of cancellation or suspension.

                             I.  BACKGROUND

     Chlordane and heptachlor belong to a group  of  chlorinated  hydrocarbon

insecticides known as "cyclodienes," which also  includes  aldrin,  dieldrin,

endrin, thiodan and telodrin.  Chlordane was first  registered for use in the

United States in 1948 and heptachlor in 1952.  Over the years,  they have been

used in relatively large amounts in a growing number of products  to control a

wide variety of pests, for both agricultural and nonagricultural  purposes.

About 1,700 products containing these chemicals  are currently registered for

over 400 registrants.  (This does not include products registered by states

for intrastate uses.)

     Principal uses are in farm crops, termite control, home lawns and gardens,

control of house pests, and certain limited special uses.  Most uses involve

direct application to the soil.  Currently, about 23 million pounds are used in

the United States annually, of which about 21 million are chlordane and 2 million

are heptachlor (see Appendix 2).  The sole U. S. manufacturer of both chemicals is

the Velsicol Chemical Corporation, a subsidiary of Northwest Industries, Inc.

Summary of Characteristics and Effects

      (The following discussion summarizes scientific and technical data contained

in the EPA review reports which are listed in Appendix 6 as references 1,  3 and 4.

Anyone wishing more details  or bibliographies of basic sources may obtain copies of

these reports.)

     Chlordane and heptachlor, as manufactured and marketed domestically  in their

"technical" forms, are complex mixtures  of  substances  rather than  single  "pure"

chemicals.  Consequently,  their interaction with the environment is  complex and

imperfectly understood.

      Probably  the  most  notable  characteristic of  these chemicals is persistence

 in the  environment.   They  do  not  readily break  down or degrade into harmless


      When  they do  break down, certain  of the initial breakdown substances are

 potentially more hazardous than the  parent  chemicals.  The best known of these

 substances is  heptachlor epoxide,  a  metabolite  (a substance produced by biological

 processes  in or by living  organisms) of heptachlor.  Because chlordane averages

 about 10%  heptachlor  content, its  use  also  leads  to the presence of heptachlor

 epoxide  in the environment.   Oxychlordane,  a toxic metabolite of chlordane, has

 been  studied less  extensively,  and its effects  are not as well understood.

      Chlordane and heptachlor,  and/or  their toxic metabolites, have been found

 to persist in  the  soil  for years  following  application.  Residues are widely

 found in agricultural soils in  the U.  S. and Canada.  In the case of chlordane,

 which is the more  persistent, as much  as 16% of the original amount applied for

 crop  pests has been  found  in  soil  15 years  later. When applied underground for

 termite  control, 15%  has remained  after 21  years. Heptachlor and its metabolite,

 heptachlor epoxide, have been found  in detectable amounts 12 years after surface


     Because most  uses  involve  soil  application,  the movement and fate of these

chemicals  following such uses are  of primary concern.  Both are virtually insoluble

in water and they  become tightly bound to soil  particles.  Therefore, they offer

considerable resistance  to movement  into underground and surface waters.  In areas

of extensive use,  however,  some residues have been found in the water and sediments

of rivers, lakes and  estuaries, and, in a few instances, in public drinking water

supplies.  Residues have been found in the Sargasso Sea, which encompasses the

Bermuda Islands.  A few cases of contamination of private wells as a result of

termite control use have also been reported.  Both chemicals are volatile

(heptachlor more so than chlordane), and their vapors have been detected both in

the vincinity of sites of application and in ambient air samples.  They have also

been found in rainwater and dust.  In one reported case, dust particles containing

chlordane and heptachlor epoxide were borne by air currents from Dallas to Cincinnati.

     Certain food and feed crops, especially root crops, have been shown to

accumulate residues of both chemicals by absorption from the soil.  Chlordane,

heptachlor and heptachlor epoxide have been found as low-level residues (with

occasional moderate or high levels) in earthworms, shellfish, fish, birds,

and mammals.  Heptachlor has been observed to concentrate at levels thousands

of times greater than the surrounding water medium in several aquatic species.

Some aquatic species such as catfish, bluegill, and rainbow trout have been

shown to be sensitive to the toxic effects of low level concentrations.

Considerable mortality among birds, mammals, fish and other aquatic species

has been recorded in areas recently treated with heptachlor.  Reductions in

bird populations have been observed to continue for up to 3 years following

heptachlor application.  However, long-term effects on wildlife are largely unknown.

     Through monitoring and surveillance activities, the Food and Drug Administra-

tion (FDA) and the U. S. Department of Agriculture  (USDA) regularly find residues

of these chemicals, and/or their metabolites in food and feed crops, in meat,

fish and poultry, and in dairy products and eggs.  Heptachlor epoxide occurs

more frequently, expecially in meat, fish, poultry, and dairy products.  Residue

 tolerance  levels  (which represent the maximum level of a pesticide legally

 allowed in marketed foods) have been established by EPA for certain food and

 feed  crops.  FDA  and USDA, who enforce the tolerance levels, have also established

 enforcement action levels for some foods not covered by tolerance levels.  The

 Food  and Agriculture Organization and the World Health Organization of the United

 Nations have established acceptable daily intake (ADI) levels for man.  The

 most  recent available results of FDA market basket residue surveys suggest that

 ADI levels were not normally being exceeded in 1972.  However, in light of

 present knowledge concerning the health effects of these chemicals, tolerance

 levels and ADI levels may no longer be adequate to protect against serious

 health effects.

      In recent years, EPA's human monitoring survey has found residues of

 heptachlor epoxlde and oxychlordane in from 90 to 96% of a national sample

 of human adipose  (fatty) tissue.  Heptachlor epoxide has also been found in

 the tissues and organs of stillborn infants, indicating transfer from mother

 to offspring.  Both heptachlor expoxide and oxychlordane have been found in

 human milk samples.

     Controlled tests with laboratory animals, primarily rodents, have demon-

 strated that these chemicals produce both short- and long-term health effects.

When administered in relatively heavy doses through feeding, skin application,

or intravenous injection, they were found to affect primarily the central

nervous system, causing death in a matter of hours or days.  Long-term tests,

in which lower doses were administered through feeding for periods of up to

2 years, demonstrated that both chlordane and heptachlor induce microscopic

changes in the liver,  and changes in liver weight, affect liver enzyme activity

and cause increased mortality in offspring.   Tests to determine the effects

of long-terra exposure through inhalation are lacking.

     Tests of chlordane, heptachlor,  and heptachlor epoxide for mutagenic

(hereditary change) or teratogenic (developmental) defects  in offspring

were negative.

     In 1959, Kettering Laboratory reported  on a long-term  study conducted

for Velsicol in which rats fed heptachlor epoxide developed tumors  of the

liver and other organs.  In a study which was completed in  1965 by  an EPA

scientist, K. J. Davis (who was then with the Food and Drug Administration),

mice fed heptachlor and heptachlor epoxide developed liver  tumors.   EPA con-

sultants and outside experts, who recently re-evaluated those two studies,

concluded that they demonstrated the chemicals to be carcinogenic.

     In 1973, the International Research and Development Corporation completed

two 18-month studies for Velsicol, one in which mice were fed chlordane and

the other in which mice were fed a mixture of heptachlor and heptachlor

epoxide.  Significant liver hyperplasia (abnormal increase in the number

of cells) was observed in both cases.  Review of data from these experiments

by EPA consultants and experts at the National Cancer Institute indicate that

many of the test animals developed malignant liver tumors.

     On October 21, 1974, the National Cancer Institute (NCI) issued a

"Memo of Alert" stating that preliminary results of recently completed

rat and mouse studies indicated that both chlordane and heptachlor showed

carcinogenic activity in the livers of mice.  A draft "Preliminary Report,"

dated January 23, 1975, provided more details concerning the studies.  A

final report on these studies has not yet been issued.

     Although a few reported human deaths and illnesses have been attributed

to poisoning from accidental exposure to chlordane and heptachlor, these have

often been under circumstances that did not rule out other possible causes.

The few known studies of workers engaged in the manufacture, formulation or

application of these chemicals suggest some possible short-term effects but

permit no definitive conclusions as to long-term effects.

     Because chlordane and heptachlor are widespread through the environment,

occurring commonly in food and human tissue, it is impossible to conduct

pesticide-free, controlled studies on human populations.  For the most part,

impact on human health must be derived from animal studies and other indirect

evidence, as just outlined.

     In summary, the salient facts concerning chlordane and heptachlor are:

     1.  They have been used for over 20 years in considerable quantities

         for a variety of crop and noncrop pest control purposes.

     2.  They are chemically similar; chlordane contains about 10% heptachlor.

     3.  They and their toxic breakdown products are very persistent

         in the environment, resisting chemical or biological breakdown

         into harmless substances.

     4.  They or their toxic breakdown products are found as residues

         throughout the environment, i.e., in soil, water, air, wildlife,

         and food.

     5.  Their toxic breakdown products are found to have accumulated

         in human adipose tissue and in human milk.

     6.  They and some of their breakdown products are acutely toxic

         to many forms of life, in addition t'o target species.

     7.  Heptachlor epoxide has been found to have accumulated in

         the organs of stillborn infants.

     8.  Heptachlor, heptachlor epoxide and chlordane induce tumors

         in laboratory animals, and thus pose a cancer threat to man.

Basis for Hearing

     In 1969, the U. S. Department of Health, Education and Welfare Commission

on Pesticides and Their Relationship to the Environmental Health recommended

restricting the use of certain persistent pesticides  (including chlordane and

heptachlor) in the United States to specific essential uses which would

create no known hazard to human health or to the quality of the environment.

In a March 1971 statement, the Administrator of EPA announced that  reviews

were being initiated concerning the registration of certain pesticide products,

including those containing chlordane and heptachlor.  In 1972, a special EPA-

sponsored review committee, which included a representative of USDA, completed

a scientific review and  filed  a report on each chemical  (references 3 and 4).

The evidence then available was not thought  to warrant immediate restrictive

action on registered uses.  As part of its continuing review, EPA  recently

updated the 1972 scientific reports  (reference 1) and, in  addition, performed

an economic and social analysis to examine the consequences  of  cancelling

 the registered  uses  of  these  two  chemicals  (reference  2).   These  recent  studies

 revealed certain  new information:

      1.   Without  a cancellation action,  uses  of  these  chemicals would be

          expected to increase, particularly in light of  the cancellation of

          aldrin and  dieldrin, since  chlordane and  heptachlor are  used as

          substitutes for many uses of  aldrin  and dieldrin.   Environmental

          residues would therefore be expected to increase.

      2.   There  are additional reports  on accumulations of heptachlor

          epoxide  in  the organs and tissues  of stillborn  infants and in

          human  milk.

      3.   Results  of  earlier laboratory tests  on  animals  have been re-

          evaluated and are now considered to  be  evidence of carcinogen-


      4.   Preliminary information  from  the National Cancer Institute

          suggests additional  evidence  of a  cancer  threat.

      In  addition, in the course of the recent aldrin and dieldrin cancella-

tion  and suspension  hearings, EPA has  clarified  certain  concepts  concerning

regulation of these  kinds of  chemicals.   (This was reflected in three

documents published  in the Federal Register on October 18,  1974 under the

heading  "Shell  Chemical Co. et_ al	Consolidated  Aldrin/Dieldrin Hearing.")

The nature and  amount of evidence necessary to justify a restrictive action

was defined more  clearly and  the  concept of carfinogenicity was amplified on

the basis of recent  scientific evidence  and hypotheses.  These concepts

regarding principles of chemical carcinogenesis were relied upon by the

Administrator in issuing registration regulations under Section 3 of the

Federal Insecticide, Fungicide, and Rodenticide Act, as amended.  These

regulations provide that when there is evidence that a pesticide may have

"unreasonable adverse effects on the environment," the burden is placed

on the prospective registrant to prove why registration should not be denied.

     The risks and benefits of chlordane and heptachlor were reevaluated

in light of the new evidence and the most recent scientific hypotheses.

As a result, the Administrator found that continued use of heptachlor

and chlordane posed a substantial question of safety.  Accordingly, he

proceeded under Section 6(b) of the Federal Insecticide, Fungicide, and

Rodenticide Act, as amended, with a notice of intent to cancel certain

registered uses of products containing chlordane and heptachlor on the

basis that currently registered uses may cause "unreasonable adverse

effects on the environment."  (See Appendix I, "Notice of Intent to Cancel.")

     A public hearing, which is underway, has been requested by persons who

may be adversely affected by actual cancellation.

     In the evaluation that follows, Part II discusses alternative courses

of action considered by EPA prior to its decision to proceed with  the notice

of intent to cancel and examines and compares the possible effects of  four of

these alternatives which were thought to warrant  further  exploration.   Part III

summarizes the possible effects (adverse and beneficial,  short-term and long-

term, and irreversible and reversible) of the course of action  proposed in

the notice of intent to cancel.

     This evaluation is based primarily on the information available to EPA at

the time the decision was made^ to issue the notice of intent to cancel.  The

evidence, sufficient to raise a serious question as to "unreasonable adverse

effects on the environment" and thus to warrant a notice of intent to cancel,

need not be so complete or thoroughly analyzed as the Administrator's final

decision following the public hearing.  A major purpose of the hearing is to

provide the mechanism for generating and bringing together all the information

needed to test the premises upon which the original decision was based.  Then,

in light of the more complete evidential base, the Administrator can make an

informed final decision which confirms, modifies or reverses the original decision.

                              II. ALTERNATIVES


     Under the Federal Insecticide, Fungicide, and Rodenticide Act, as amended,

the EPA Administrator may restrict the use of pesticides to reduce their poten-

tial hazard in several principal ways, including:  (1) requiring changes in la-

bel instructions, (2) limiting use only to trained and certified applicators,

and (3) cancelling or suspending and cancelling, some or all registered uses.

He may also impose other regulatory restrictions which he deems appropriate in

specific cases, such as seasonal and/or geographic pound limitations on use,

annual permit requirements, control of distribution (including sale and pur-

chase) , and allowing use only in conjunction with certain other approved pest

control techniques.  Any of these restrictive actions may be taken singly or in

combination.  They may be initiated at one time or phased in over a longer time

interval.  Thus, there are many courses of action open to the Agency in any given

situation, especially when all possible combinations are considered.

     In evaluating the problem posed by chlordane and heptachlor, EPA considered

its many options and concluded that effective control could most logically be

attained through the cancellation mechanism.  Any action short of cancellation

was not felt to be consistent with the magnitude of the problem.  However, the

possibility of strengthening use restrictions, should any be appropriate, as

well as cancellation, will also be considered during the hearing.  The option of

immediate suspension of registration, pending a final cancellation decision, was

considered, but did not originally seem to be warranted.  However, information

subsequently available to the Administrator indicated that continued use of  the

chemicals during the cancellation proceedings would constitute an "imminent

 hazard" as defined in the Act, and, on July 29, 1975,  he issued a notice of in-

 tent to suspend.  On December 24,  1975, the Administrator suspended the regis-

 tration of uses of chlordane and heptachlor on lawns,  gardens,  turf and for

 household pest control.   He allowed the continued use  of chlordane and heptachlor

 on some minor crops and  for control of cutworms on corn through August 1, 1976.

      Four major cancellation alternatives were thought to warrant closer exami-


      1.   No Cancellation Action.

      2.   Cancellation of All Uses.

      3.   Cancellation of All Uses  Except  Subsurface Ground Insertion for

          Termite Control and the Dipping  of Roots or Tops of Nonfood Plants.

      4.   Cancellation of Food and  Feed Crop Uses  Only.

      The  potential  effects  of each alternative were examined, to the extent

 that  available information  permitted,  and are summarized below.   (See Appendi-

 ces 4 and 5 for summaries of estimated effects.)

      Final  cancellation  of  all registered pesticide uses of aldrin and diel-

 drin  (except  restricted  termite use, dipping of roots  and tops  of nonfood plants,

 and use in  a  totally  effluent-free  moth-proofing  system)  was announced in an EPA

 order dated June 30,  1975.   Furthermore,  Shell Chemical  Company,  the sole manu-

 facturer  of aldrin and dieldrin, has stated that  it  does not intend to continue

 their production even for the  exempted  uses.   Therefore,  because  chlordane and

 heptachlor  are  interchangeable  with aldrin  and dieldrin  for many  uses,  it is

 assumed,  in considering alternatives,  that  without  EPA restrictive action on

 chlordane and heptachlor  their  volume  of  use will increase  substantially as they

are substituted  for aldrin and  dieldrin uses.


Alternative 1:  No Cancellation Action

     EPA could permit continuation of all presently registered uses.

1.   Environmental Effects

     (a)  Adverse

     Due to their persistence, each additional application of these chemicals

tends to add to previous residues and raise the total residue levels in the en-

vironment.  Thus, the environmental burden may worsen even if the annual volume

used were to remain at present levels.  However, the volume used is expected to

increase at first quite rapidly as chlordane and heptachlor are substituted

for aldrin and dieldrin, with smaller increases thereafter.   (For most uses,

heptachlor is applied at about the same rate as aldrin and dieldrin, but

chlordane must usually be applied at two or three times the rate of the

other pesticides to provide a comparable degree of control.)  Increased use

will further increase the likelihood of residue buildup, with consequent in-

creased risk to man and other living things.  Contamination of drinking water

supplies may occur more often and reach higher levels.  Plants, including food

and forage crops, may accumulate higher residue levels, and as a result, there

are likely to be higher and more widespread residues in the human diet.  Residue

accumulations in wildlife are expected to increase; episodes  of direct kills from

the acute toxicity of heptachlor would probably occur more frequently, and  there

would be greater likelihood of long-term effects.

     Finally, since EPA has concluded that human exposure  to  present  levels of

these chemicals poses a risk to human health, notably the  threat of cancer,  con-

tinuing all registered uses would serve to continue this risk.  As  residues in

 food and other sectors of the environment increase and become  more widespread,

 the risk will increase.   The net effect will be a growing risk of  otherwise

 avoidable illness and death from cancer.

      (b)  Beneficial

      There are no known benefits to the natural environment or to  human health

 from continued use of these chemicals.

 2.   Economic and Social Effects

      (a)  Adverse

      The presently observed distribution of these chemicals in the environment

 and  their known effects,  as outlined in Part I, have  been interpreted by EPA as

 constituting  a real,  although largely unquantified, adverse effect on the envi-

 ronment.   If  this effect  were more precisely measurable,  it would  be possible to

 assign  it,  at least in part,  a dollar cost.   For example,  if we could project

 with a  moderate degree of certainty the number of deaths  and illnesses  that would

 result,  it  would be relatively easy to calculate a resulting dollar loss from

 lost earning  power due to premature death and the medical care costs for avoid-

 able health effects.   In  some instances,  risk ratios  for  different levels of ex-

 posure  to  toxic chemicals have been derived  from the  results of tests with labora-

 tory animals.   However, uncertainties concerning average  total exposure of the

 human population and  the  direct applicability of animal exposure experience to

 man  would render mortality and morbidity  predictions  and  consequent dollar loss

 calculations  extremely unreliable.   Effects  such as the pain and suffering asso-

 ciated with illness and death and  the loss  of wildlife species can probably never

be assigned meaningful dollar values  or other quantified measures  of impact.

Although it is quite unsatisfying to be unable to define the precise size and

nature of the impact, available evidence clearly indicates the possibility of

a considerable health and environmental impact, with accompanying economic and

social costs.

     The ready availability, relatively low cost, and well-demonstrated

effectiveness of chlordane and heptachlor encourage unnecessary use; a part

of the amount used often produces no direct pest control benefit.  According

to an estimate cited in EPA's economic study (Reference 2), as much as 50% of

use on corn may be unnecessary.  Unnecessary use increases the probability of

development of pest resistance, needlessly kills beneficial parasites and adds

to the total environmental burden without compensating benefits.

     (b)  Beneficial

     Economic benefits of continued use of chlordane and heptachlor in agricul-

ture take the form of higher yields and/or lower costs than with use of best

available alternatives.  To these primary benefits  (yield and cost) must be added

secondary benefits which take the form of impacts on farm prices for not only the

crops on which chlordane and heptachlor are used but also for other crops.  In

turn, these impacts on farm prices of chlordane/heptachlor-treated  crops and

related crops lead to impacts on the cost of food to the consumer.

     There are two ways of looking at yield benefits in the  agricultural  area.

First, there is benefit in terms of increased  yields to the  individual farmer

and to the total agricultural sector due to pest control with  the best available

chemical or other methods.  Then there is increased yield  attributable uniquely

 to chlordane  and heptachlor, above and beyond any increase attainable with

 the next best available pesticide or other control measures.  The latter

 increase, which is more meaningful in this context, should be approximately

 equivalent  to the loss in yield that would be expected if chlordane and

 heptachlor  were cancelled and therefore not available.

     The EPA economic study  (reference 2) included a special analysis to

 determine the economic effects of cancellation on corn production  the

 area of greatest agricultural use of chlordane and heptachlor.  The study con-

 cluded that, while cancellation could have significant adverse effects on certain

 corn-growing areas or groups of farmers, the overall impact on the national

 economy would be slight.   (The findings are discussed at greater length,

 commencing  on page 19.)  This result can be taken to mean that current use of

 chlordane and heptachlor on  corn may have slightly beneficial economic effects

 on a national scale, while providing more substantial benefits to limited areas

 and groups  of farmers.

     Since  the study estimated that cancellation of uses in other areas of

 agriculture would produce few significant adverse economic effects, benefits

 attributable uniquely to chlordane and heptachlor use in those areas can also

 be assumed  to be slight.

     Use in termite control presumably prevents a substantial annual loss in

damage to structures.  No reliable estimate of such benefits has been obtained,

however.  The benefits of home, lawn and garden uses and other special uses are

 even less measurable, but they apparently contribute to improving the quality

of  life of  the user.  Because alternative controls may be unavailable for

certain pests in turf and nursery plants,  chlordane and heptachlor may be

assumed to have unique but unmeasured value in controlling such pests.

Alternative 2:  Cancellation of All Uses

     EPA could take this most thorough approach of cancelling all currently

registered uses.

1.   Environmental Effects

     (a)  Adverse

     As on-hand supplies of chlordane and  heptachlor products are depleted,

they will be replaced to a considerable extent with other pesticide products

already registered for the same uses.  This does not mean, however, that the

other pesticides are equally effective for each use or that they would necessari-

ly be used as replacements.  (See Appendix 3 for examples of a few currently

registered uses of chlordane and heptachlor and other registered chemicals which

are possible substitutes in those uses.  Reference 1 contains a more complete

listing of registered chlordane and heptachlor uses and substitute chemicals).

It is not possible to predict at this time which of the other chemicals would

most likely be employed as substitutes for chlordane and heptachlor, although

state agricultural extension services have been contacted for their recommenda-

tions.  Substitutes will generally be much less persistent than chlordane and

heptachlor.  However, some of them, particularly the organophosphates, will be

more acutely toxic and will thus pose a greater short-term risk to those exposed

to them in manufacturing and application.   Some of the substitutes may also

be more mobile in the environment, but this detrimental quality may be

largely offset by their lack of persistence.

      While  the  aldrin and dieldrln cancellation action would continue to permit

 use  of aldrin and dieldrin, under specified conditions, for termite control, Shell

 Chemical Company has indicated that it does not intend to market aldrin or dieldrin

 even for that use.  If aldrin and dieldrin were unavailable and if chlordane and

 heptachlor  were cancelled for termite control, compounds such as BHC, lindane,

 pentachlorophenol, creosote and coal tar neutral oils which are registered for

 termite control would remain the only registered substitutes.  Only the first two

 of these pesticides are registered for subterranean soil use, and none are as

 persistent  as aldrin, dieldrin, chlordane or heptachlor.  Since aldrin and

 dieldrin are very similar to chlordane and heptachlor in their probable effects

 on the environment and human health, cancellation of one pair of chemicals for

 termite control without also cancelling the other would bring little improvement

 in environmental effects.  If all four chemicals were cancelled, the total envir-

 onmental burden of these persistent and hazardous pesticides would be reduced.

 However, adverse economic effects would be likely (see last paragraph, p. 24).

      (b)  Beneficial

     Total  cancellation is the only alternative that would promise eventual

elimination of all environmental contamination and risk to living things

attributable to these chemicals.  Although as a result of their persistence they

or their toxic metabolites would be found in the environment In detectable amounts

for years to come, there should be-a general decline from present residue levels,

the rate of decline varying greatly in different sectors of the environment.

(This expectation has been borne out in the case of DDT, wherein recent DDT

residue data have reflected gradual declines in food and wildlife, paralleling

declining use of that chemical.)

     Residues in soil and aquatic sediments would probably persist the longest,

dropping off quite rapidly in the first four or five years, but more gradually

thereafter.  In most cases, they should decline to undetectable or trace levels

within 25 to 30 years.  However, soil residues from subterranean applications,

such as termite control, may last longer.   Food residues should drop off quite

rapidly in the first few years thus reducing what is currently thought to be the

most dangerous source of human exposure.  Most air and water contamination should

decline to trace levels within 5 to 10 years.  Accumulations in wildlife should also

subside in a relatively short time, the rate of subsidence differing with the

species, its location in the food chain, and other factors.  Being less persistent,

pesticides used as substitutes for chlordane and heptachlor products would be

less prone to accumulate in the environment.  Consequently, the environmental burden

of chlordane and heptachlor residues would not be replaced by equal residues of

the substitutes.

     Furthermore, the EPA economic study  (reference 2)  estimated  that one of  the

effects of cancelling chlordane and heptachlor use in corn would  be a substantial

increase in the total corn acreage on which no pesticide at all is used.  This

would be due to a combination of factors including termination of chemical

controls on corn land where chlordane and heptachlor were previously used and

replacement of discontinued corn acreage in infested areas with new corn acreage

in uninfested areas.  Therefore, at least in corn, there would not be a one-

for-one replacement of chlordane and heptachlor with other pesticides and the

 environmental burden of all pesticides would be reduced.

      In  general,  the exchange of persistent chemicals with long-term effects

 on  the environment  for shorter-lived but sometimes acutely toxic chemicals should

 result in a substantial net gain to the environment and human health.  There

 would be some increased risk of acute toxic effects to the relatively small

 population of manufacturing, formulating and application workers because they

 would be handling more of the acutely toxic pesticides than at present.  However,

 that increased risk should be small and should be outweighed by the reduction in

 long-term health risks to the population at large, which includes the workers.

 A direct risk which is known by those to be exposed (such as plant workers and

 field applicators of acutely toxic substances) can be protected against through

 proper precautions.  Also, as the presently developing EPA-State program to

 train and certify applicators progresses, the risk of acute effects from accidents

 and misuse by applicators should be further reduced.  On the other hand, long-term

 exposure of the general population to ubiquitous chemical contaminants such as

 chlordane and heptachlor from food, air and water cannot be avoided by indivi-

 dual precautions.  No known change in the preparation of the principal contami-

 nated foods in the home, for example, would significantly reduce exposure through

 food.  Moreover, although drastic changes in eating habits such as elinimating

 meat and dairy products could reduce exposure, such a change is not feasible

 since these products are major sources of nourishment in this country.

 2.  Economic and Social Effects

     (a)   Adverse

     The  increased use of more acutely toxic substitute pesticides may produce

some increase in deaths and injury through accidents and misuse, with resulting

costs.  If such costs occur, they would be of major consequence to affected

individuals and their families.  However, on a national scale,  they should

be relatively small compared to the costs of the suspected long-term health

impact on the general public from chlordane and heptachlor use.

     Total cancellation would certainly have an impact on the chemical

manufacturer (Velsicol) and the other firms presently marketing products

containing chlordane or heptachlor.  Any loss in jobs and income (the magnitude

presently unknown) could be offset by new jobs and income created by increased

demand for other pesticide products used as replacements for chlordane and


     In the agricultural area, adverse economic effects can result from unavail-

ability of effective substitute chemicals or other pest control methods.  They

can also result when substitutes are available, but (1) are more expensive (2)

are less effective, or (3) require more manpower and time to use.  Although

substitutes will most often be more expensive than chlordane and heptachlor,

that in itself will not be necessarily be a deterrent to their use since

pesticides are a relatively small part of crop production costs.  Where a

serious insect problem in a given crop has previously been controlled with

chlordane or heptachlor and where available substitute controls would not be

economically acceptable, the land may be converted to production of  another

crop or agricultural purpose less vulnerable to the problem  insects.  This alter-

native agricultural purpose, however, may represent a less productive use  of

land than the original crop.

      Corn production presently accounts for the largest agricultural use of

 chlordane and heptachlor.  Consequently,  the most serious economic impact

 from  cancelling  agricultural uses could be expected in corn.  However, during

 the aldrin/dieldrin proceeding the Administrative Law Judge and the Administrator

 found that  insect problems in corn production have been reduced in recent years

 and that effective pesticide alternatives are available for the important corn


      EPA's  economic study  (reference  2) indicates that, in Midwestern Corn Belt

 States, chlordane, heptachlor, aldrin or  dieldrin were in 1973-1974 used on an

 estimated 8.8 million acres of corn  (or about 12% of total corn acreage) annually.

 The study estimated the  combined economic impact of cancelling use of all four

 pesticides  in corn.  One estimate, based  on "worst case" assumptions, that is,

 most  pessimistic estimates of infestation by soil insects and decline in yield,

 found  that  by 1977 corn  production could  decline by 36.9 million bu, or about

 0.7%  of total production for that year.   This decline would be accompanied by

 an increase in total corn  acreage, an increase in acreage of other grains to

 compensate  for decreased corn production, and changes in the price of the other

 grains, ranging  from a slight decline in  the price of soybeans to an increase of

 2.5%  for sorghum.  Price impacts of  this  magnitude, though significant, are minor

 in comparison with ordinary year-to-year  changes due to weather and other factors.

     Consumer prices for meat, poultry, eggs, and other products requiring sub-

stantial feedgrain input could increase by about 0.4 to 0.5%.  This could result

in an increase of about  0.19% in total food costs to the consumer, or an annual

per capita  increase of about $1.70 for food.  Due to the nature of the market

structure for agricultural commodities, these adjustments would result in

a net increase in overall agricultural income; however, the increase would

not be distributed evenly among farmers or producing areas.  Many of the

farmers who had previously used chlordane and heptachlor would experience a

drop in income, while farmers who benefited most from the price increase

would be in areas where chlordane and heptachlor either were not used or

were less essential in corn pest control.  This change in distribution of

agricultural income, the reduced efficiency in land use (more land in corn

but less total production), along with the increase in the price of corn

and other agricultural commodities, are found to add up to a slight but

discernible adverse impact on the national economy.

     These results, it should be remembered, are based on "worst case"

estimates.  It is unlikely that such high level pest infestations would

occur in all impacted states in any one year; at least there is no record

of outbreaks of these pests on such a scale.

     A subsequent analysis of the impact of cancelling corn use was based on

more probable or "typical case" assumptions concerning insect infestations and

crop loss.  This resulted in a projected increase  in the price of meat  and

related products of only about 0.015 - 0.019% and  an increase in total  food costs

of 0.0072% - or an annual per capita increase of about 6.5$ for food.   This

quite negligible impact is much more likely than the impact estimated  for  the

"worst case" situation.

     Florida citrus producers face potentially  large impacts  due to  can-

cellation of aldrin and dieldrin.  If, as some  Florida citrus specialists

indicate, chlordane and heptachlor are the only feasible  substitutes for control

 of  Fuller's  Rose  Beetle  a pest problem in Florida's east coast groves  then

 cancellation of chlordane and heptachlor, along with aldrin and dieldrin, could

 produce  substantial adverse impact.  However, chlordane and heptachlor have not

 hitherto been used extensively for Fuller's Rose Beetle, and their efficacy is

 uncertain.   Also, state and Federal registrations are inconsistent, with no

 present  Federal registration for either chlordane or heptachlor for control

 of  Fuller's  Rose  Beetle in citrus.  It is, therefore, not possible at present

 to  ascribe a specific impact on Florida citrus to chlordane and heptachlor


     Several states estimated that cancellation of chlordane and heptachlor

would produce a significant impact on strawberry production, but EPA has not

yet obtained sufficient information to assess the extent of such impact.  For

other crops  in which chlordane and heptachlor are used, effective substitutes

are generally available, and the adverse economic effects of cancellation are

expected to  be slight.

     Since aldrin and dieldrin are not likely to be available for any pesticide

uses, including termite control, chlordane and heptachlor remain the principal

chemical means for termite control.  If they, too, become unavailable due to

cancellation, the economic effects should be substantial.  The other pesticides

presently registered for termite control (BHC, lindane, pentachlorophenol,

creosote, and coal tar neutral oils) are shorter-lived and generally thought

to be less effective.  Only the chlorinated hydrocarbons, BHC and lindane,

are registered for subterranean soil use.  Due to the need for more frequent

application of the substitutes, costs to consumers for termite control services

would probably increase markedly.  The lesser effectiveness of the

substitutes and higher application costs could cause some consumers to do

without termite control services entirely.   Thus,  there could be considerable

losses from an increased rate of termite damage.   Probable effects on the

termite control companies are hard to estimate.  As the companies and consumers

adjust to the less persistent substitutes,  the longer-term effect could be an

increase in termite control business due to the need for more frequent

application of the less persistent chemicals.

     In areas of use other than agriculture and termite control, the economic

effects of cancellation are even more difficult to estimate since the benefits

of use are also so difficult to measure.  Among these other uses are the control

of insect pests inside houses and other buildings, on home gardens, on lawns

and turf, on shade trees, and ornamentals,  on forestry plantations, on

agricultural premises, in nurseries and in sewage  treatment plants.  Also

included are control of crabgrass on lawns and turf, mosquito control and

seed treatment.  In most cases, effective,  environmentally-preferable substitute

pesticides are registered for the chlordane and heptachlor uses, and little or

no interruption of the benefits currently obtained is anticipated.

     In summary, a significant economic and social effect may be felt in a small

sector of the pesticides industry, and by certain farmers, nurserymen, and pest

control operators.  On a national scale these effects should be slight.  However,

the probable Increase in termite damage, due to lack of  suitable substitute

pesticides, could produce a substantial economic  loss, even on  a national scale.

      (b)   Beneficial

      The  most  important  economic  and  social benefits would result  from reduction

 and eventual elimination of  the human illness and death that may result from

 current and projected  uses of  chlordane  and heptachlor.  The associated medical

 care costs and costs of  lost productivity  and suffering, disruptions of family

 life,  and other psychological  and social effects would also be eliminated.

 (Although all  sectors  of the economy  have  experienced serious price increases

 over the  past  several  years, recent increases in the costs of health services

 have exceeded  those  of any other  sector.)

     To the extent that  alternative chemical pesticides are more expensive, less

 effective, or  simply more trouble to  use,  some  farmers may be led  to modify their

 present agricultural practices to minimize the  use  of chemicals.   The same con-

 siderations could lead to reduction in use of chemicals for primarily cosmetic

 or  convenience purposes,  as  in household and home garden and lawn  uses.  The

 end result could be  a  reduction in the total burden placed on the  environment in

 the form  of pesticide  chemicals,  with accompanying  costs, and some saving in the

 energy now expended  in the manufacture and application of those chemicals.

Alternative 3:   Cancellation of All Uses Except Subsurface Ground  Insertion

                 for  Termite  Control and  the Dipping f_ Roots or Tops of Non-

                 food Plants

     The  EPA Administrator's notice of intent to cancel, published November 26,

1974, proposed this  limited  cancellation of registered uses of chlordane and


1.   Environmental Effects

     (a)  Adverse

     Although most of the benefits described under Alternative 2 (Cancella-

tion of All Uses) would still be realized,  continuation of termite control

uses would permit continuation of some possible threat to human health and

the environment.  While subsurface application of these chemicals around the

foundations of structures should minimize movement within or from the soil
and should therefore present a much lower risk to man and other living things

than surface and above-surface uses, several uncertainties remain.  The fact

that private well contamination has been reported in conjunction with termite

control suggests that even with subsurface application, some direct threat

to human health would remain.  Also, during their many years of persistence

following subsurface application, these chemicals continue to represent

possible surface problems should the soil be disturbed through such activities

as demolition or construction.

     Since both chemicals are volatile, their vapors may filter up through

the soil and contaminate the air in the immediate vicinity of the structures

around which they are buried.  The present lack of test data concerning the

long-term effects of low vapor concentrations  is particularly serious because

any potential vapor problem from termite control use would be centered in

the immediate vicinity of human habitation.  Furthermore, this potential

risk should be viewed in light of the fact that at present an estimated 35%

of the total chlordane and 26% of the total heptachlor used annually in the

United States (or about 7.3 million pounds and .5 million pounds, respectively)

 go  to  termite control.

     Dipping of the roots or tops of nonfood plants, the other regis-

 tered  use that would be exempt from cancellation under this alternative,

 should have minimal impact.  This use relates to preventive treatments

 to  ensure insect-free nursery plants which are to be shipped from

 quarantined zones, as required by the U. S. Department of Agriculture

 under  its plant quarantine authority.  Chlordane is currently recom-

 mended for quarantine use to control such pests as the Japanese Beetle

 and the White-fringed Beetle.  Dipping of roots and tops would pre-

 sumably involve relatively small quantities in containers where there

 would be little release to the environment.  The specific procedures

 allowed under this expected use will not be spelled out until the

 hearing.  Depending on the procedures finally authorized, there may

 be  problems in such areas as disposal of used dip solutions, contam-

 ination of balls of soil attached to the roots of shipped shrubs and

 trees, and exposure of nursery personnel.

     (b)  Beneficial

     This alternative would terminate what are considered to be the

 most significant sources of environmental contamination by these

 chemicals  those resulting from soil-incorporated uses, and applica-

 tion to the ground surface and to plant foliage and other above-

 ground uses.  It is these uses that permit most of the extensive

environmental  diffusion observed for these chemicals.  Cancelling

such uses should result in essentially the same decline in soil,

water, and air contamination and residue levels in food, wildlife and

man, as expected under Alternative 2.  The risk to wildlife and to human

health should be similarly reduced, with the exception of the possible

remaining risk from termite control uses, as discussed on page 27.

2.  Economic and Social Effects

     (a) Adverse

     Adverse economic and social effects would be much the same as

under Alternative 2 (cancellation of all uses) except that those

attributable to cancellation of termite control uses would be avoided.

     (b) Beneficial

     Benefits would be essentially the same as under Alternative 2,

less those attributable to termite use cancellation.  The chlordane-

heptachlor part of the pesticides Industry would retain a considerable

demand for these products for termite control uses  (presently estimated

at 35% of total chlordane used and 26% of total heptachlor used in the

U.S.).  Any increased termite damage to structures  due  to cancellation

would be avoided.  The benefits in terms of reduced social and economic

Impact from mortality and Illness would be similar  to Alternative  2  but

diminished to the extent that termite control uses  pose a risk to

human health.

Alternative 4:  Cancellation of Food and Feed Crop  Uses Only

     This Alternative represents an  even more limited cancellation

action than the preceding alternative.   It focuses  on a major source

of human exposure  the diet.  It would continue registrations not

only for termite control but also for uses on lawns and flower gardens,

inside homes, and other uses where the likelihood of contamination of

food or feed would be slight.  Uses on nonfood field crops, such as

flax and tobacco, which could be grown on land that might later be used

for food or feed crops, would also be cancelled.

1.  Environmental Effects

    (a) Adverse

    This Alternative would produce the same adverse effects as Alter-

native 3 (cancellation of all uses but termite control and dipping

of plant roots and tops), plus some additional ones.  It would permit about

8 million additional pounds of chlordane and 312,000 additional

pounds of heptachlor to enter the environment annually, above amounts permitted

under Alternative 3.  Since these additional amounts would be applied to the

ground surface or used above the surface, they could move about more extensively

in the environment than amounts applied below ground for termite control.

They could more readily find their way into the air and water and would

therefore constitute a more direct threat to wildlife and man.  In addition,

by continuing to permit extensive uses in and around the home, direct, day-

to-day exposure of people would remain high.

    Although the degree of added risk from these uses is not known,

any such risk is less defensible than the risk that may be involoved in

termite control.  Not only can such uses lead to wider dispersion

in the environment, but, unlike termite control, there are effective

and environmentally-preferable substitute products currently regis-

tered for most of these uses.

     (b)  Beneficial

     Elimination of food and feed crop uses should, in about 3 to

5 years following last use, reduce residues of chlordane and heptachlor

in the human diet to relatively negligible amounts.  A substantial

decline in soil, water, and air contamination and in residue levels

in wildlife and man would be expected, although it would be less

rapid or complete than under Alternatives 2 or 3.  Thus, the risk

to human health and wildlife would be substantially lessened, but

not to the extent resulting from Alternatives 2 or 3.

2.  Economic and Social Effects

     (a)  Adverse

     Adverse effects in the agricultural sector and on consumer food

prices would be about the same as under Alternative 2 (cancellation

of all uses).  The chlordane-heptachlor part of the pesticides'

industry may suffer the loss of some jobs and revenues, but  to a

lesser extent than under Alternatives 2 or 3.  These losses may be

offset by increased demand in other sectors of the industry  for

substitutes for the cancelled chlordane and heptachlor products.

     There would be some additional social and economic costs resulting

from any adverse long-term health effects caused by  the additional uses

permitted under this alternative.  They should be  relatively small,

 however,  since human exposure through the diet would be virtually


      (b)  Beneficial

      Agricultural benefits would be approximately the same as those

 described under Alternative  2.  The impact on the chlordane-heptachlor

 industry  would be less than  under Alternative 3, since more uses would

 be permitted.  Those additional uses presently account for an estimated

 37% of the chlordane and 15% of the heptachlor used annually.  Therefore,

 about 72% of present total annual chlordane use and about 41% of

 heptachlor use could continue.  Any adverse economic effects from uses

 cancelled under Alternative  3, but not cancelled under this alternative,

 would be  avoided.   (Such effects are thought to be minimal, however.)

 As under  Alternative 3, there would be little impact on termite control

 companies, or increased termite damage to structures.  The economic

 and social benefits resulting from reduced risk of mortality and Illness

 should be substantial  somewhat less than Alternative 3 and considerably

 less  than Alternative 2.


      In making its decision, EPA had first to choose between "no

 cancellation action" and "some cancellation action."  Alternative

 1 could be selected only if  it was determined that chlordane and

heptachlor, as presently used, do not cause "unreasonable adverse

effects on the environment."  EPA concluded from the available

evidence, as summarized in Part I, that present uses of these chemicals

do adversely affect the environment,  including a substantial degree

of risk to the human population.  In light of such risks,  EPA

determined that there was a substantial question of safety and proposed

to cancel certain uses as detailed in Alternative 3.   The  adverse effects

of these uses were judged to outweigh any known benefits from continued

use.  This action gave registrants an opportunity to demand a public

hearing in which they have the burden of demonstrating that the risks

posed by the uses to be cancelled are outweighed by the benefits

derived from these uses.

     Cancellation of all uses, Alternative 2, represents the most

thorough solution to the problem.  It would ensure that all hazards

resulting from current chlordane and heptachlor uses would eventually

diminish to zero.  Such an action would also, of course, produce the

greatest adverse economic impact on individuals and organizations

which benefit from currently registered uses of these chemicals.

Even at worst, the adverse economic effects which could include lower

crop yields, additional termite damage to structures, higher operating

costs, higher prices, lost income, and inconvenience, would be on a

relatively small scale and represent a rather minor impact on the

national economy.  In most areas of use these effects would be minimized

by the availability of other pesticides which are registered for the

same uses as chlordane and heptachlor products.  However, in the major

use area of termite control there are no currently registered, environ-

mentally-preferable substitutes which are thought to approach the

effectiveness of chlordane and heptachlor.  But  fortunately, when

used  for  termite  control,  chlordane and heptachlor are usually applied

below the ground  around  the  foundations of termite-threatened structures

where, in the  light of current knowledge, they would seem to pose a

minimal threat  to the environment and  to human health.

      Alternative  3, therefore, would remove most environmental risks

while permitting  continuation of what  seems to be a minimal risk in

one major use  area, termite  control, thereby avoiding sharp economic

dislocations in that area.

      Alternative  4 reflects  an even more limited cancellation approach.

11 would only  cancel those uses involving application on or around

food  or feed crops, on the assumption  that (1) control of residues

in the human diet will remove an important human exposure, and (2)

risks from other  uses are  outweighed by the benefits of those uses.

It would permit continuation of the same registered uses as Alternative

3, plus other nonfood and  nonfeed crop uses, such as control of pests

inside houses,  in flower gardens, lawns and turf, agricultural premises,

and nurseries.  However, Alternative 4 is not well-founded on several

c ounts.  The benefits of these kinds of uses are quite intangible and

immeasurable.   Although  they provide convenience to the users, they

apparently are  not of great  economic consequence.  Furthermore, for

almost all these  uses, there are effective, environmentally-preferable

substitutes already registered.  In addition, these uses all involve

application to  ground surface or above ground surface, which is thought

to constitute a much more  serious risk to the environment than subsurface

application as in termite control.  In addition, many of these uses

involve direct exposure of homeowners and home gardeners and their


     In light of the foregoing considerations, EPA chose Alternative 3

(cancelling all uses except subsurface termite control and the dipping

of roots or tops of nonfood plants) and published the notice of intent

to cancel (see Appendix 1).  The belief that use for termite control

poses minimal environmental risks and provides substantial benefits

in protecting dwellings led to the exemption of that use from cancellation

     The matrix display, Appendix 5, attempts to compare in a simplified

way the probable effects estimated for the four alternatives.


     While this type of evaluation can help guide decision-making,

it is limited by the need to consider many factors that are neither

measurable nor capable of being weighed precisely against one another

or against other factors that are quantifiable.  Differing perceptions

as to how real are the risks and benefits and how much weight to give

one versus the other will lead to different conclusions.  The final

decision, then, at best, will represent an informed judgement that will

not be beyond dispute.

     In selecting Alternative 3, EPA has attempted to balance costs

and risks against benefits.  Where risks and benefits seemed relatively

equal, preference was given to minimizing the human health risk.

     In summary,  the principal effects of Alternative 3 are estimated

as follows:

1.  Beneficial

     a.   Probable substantial reduction in long-term risk to human

         health and wildlife.

     b.   Probable substantial reduction in economic and social loss

         due to long-term human health effects of chlordane and


     c.   Substantial reduction in environmental contamination.

     d.   Avoidance of the economic impact in the area of termite

         control  that would  result from cancellation of that use.

2.  Adverse

     a.  Some possible long-term risk to human health and the environ-

         ment due to a presumably slight, but not fully defined,  hazard

         from continued use of chlordane and heptachlor for termite


     b.  Some possible risk to human health and the environment from

         increased use of substitute pesticides which, while generally

         less persistent, may be more acutely toxic.

     c.  Minor economic and social impact on a national scale, with

         moderate impact in a few sectors of agriculture and a few

         nonagricultural activities.

     d.  Minor economic impact on the pesticides industry.

Short-term and Long-term Considerations

     Persistent pesticides, such as chlordane and heptachlor, can

produce residues in various sectors of the environment in the short

term and, with continued use, these can be built to higher-level

residues in the long term.  They can produce acute toxic effects in

man and wildlife as well as delayed effects such as tumors or

mortality in offspring.

     In general, Alternative 3 would produce both short- and  long-

term effects of about the same magnitude in each major impact area

(see Appendix 5).  Effects on the environment would be felt quite

early  following cancellation and they would continue  to be  felt  as

long as the cancellation remained in force.  Some effects on  human

health would begin shortly after cancellation,  e.g.,  the  possible


increase in acute effects from use of some substitute products,  and

the relatively early drop-off in crop residues which would reduce

the exposure and resulting risk of eventual chronic effects.   Such

effects would also continue indefinitely.  Economic and social effects,

too, would occur early following cancellation and continue at about

the same level thereafter.  However, some of the initial effects

should be ameliorated over time.  These would include reduced crop

production which would be counterbalanced in subsequent years by

the planting of increased acreage and by the development and

adoption of other pest control methods, as well as lost jobs  and

income in the pesticides industry which may be offset by the

increased demand for other chemicals to replace heptachlor and


Reversible and Irreversible Aspects

     The proposed action and most of its effects are reversible.

Even if cancellation is carried out, registration could be reinstated

later in the light of new evidence or other changed circumstances.

By the same token, chlordane and heptachlor uses not covered by the

present cancellation action could be cancelled at a later date.  If

cancellation were carried out and later rescinded, all beneficial

effects and most adverse effects of cancellation would rapidly

dissipate, to be replaced with the effects originally estimated

for "no cancellation."

     Irreversible effects, in the form of human death,  chronic illness,

or other permanent damage to health (and the resulting  economic and

social consequences), are expected to occur in greater  or lesser

degree under any of the three alternatives which permit continuation

of all or some uses of these chemicals.  Only Alternative 2 (cancella-

tion of all uses) would lead to virtual elimination of  such irreversi-

ble effects (excepting effects from the use of substitute pesticides).

Under the selected alternative (Alternative 3), adverse human health

effects are expected to be minimal; therefore, irreversible effects

are also expected to be minimal.

     Among wildlife, mortality and long-term effects from continued

uses would be considered reversible as long as populations of individual

species remain at levels above the point of no return leading to

extinction and as long as reproductive ability is not seriously impaired.

Because available evidence does not suggest any threat of species

extinction due solely to chlordane and heptachlor use,  irreversible

wildlife effects are not anticipated under any of the alternatives.

                                IV.   APPENDICES






                                                   APPENDIX  I

                                       NOTICE  OF  INTENT  TO  CANCEL
              IFIU, 792-2]
      Intent To Cancel Registrations
  On March 18.  1971. Uie Administrator
of this  Agency  announced  that  active
internal review \vas being Initiated on a
number of pesticide  products. Including
those containing  chlordanc  nnd  h'ep-
tachlor. As the result of such review and
(or the reasons set forth In the attached
statement of reasons, I and that the con-
tinued  registration  and use  of  these
pesticides  appear  to  pose  substantial
questions of safety amounting to an un-
reasonable risk to man  r.nd the environ-
ment. I therefore serve and file  11.Is
notice of  intent, together with Ik   at-
tached statement of reasons,  to cancel
all  registered u--.cs  of hcptachlor  and
chlordanc withl.: thirty (30) days, pursu-
ant to section C of  the Federal Insec-
ticide, Fungicide, and  Rodcnticidc  Act,
ns amended, (80 Stat, 973. 7 U.S.C. 13Gd>,
with the exception of the Uf e  of hepla-
ehlor or chlordane  through subsurface
Eround  insertion for  termite control and
the dipping of roots  or tops of nonfood
plants. Any affected  party may contest
till?  action by requesting a  hearing on
specific  registered uses  on  or  before
December 20, 197-1. Pcquests for hcurinns
should  be submitted  to  the Arjcnoy's
hcnri'.ig clcik nt  the following address:
  Mrs. Deity J. nmings
  He.-ring Clerk
  U.3. Environmental Protection Agency
  Ro>m 1010. Wntcraldo MallEast Tower
  401 M Street. SW.
  WuhUigton. D.C. 20400
  The proposed cancellation shall become
final and effective thirty  (30) days from
thu dulc of this notice as to those vejl-
trn.'d. uses for which a hearing In not re-
qucitcd by any Mflected party. The pro-
j'O.ed cfinccllnllnn shall  not take effect
11 <-rtrdi:ijf any registered use lor which a
hearing is requited until the hearing
ha-j  been  coniplotcd, unless there is a
concurrence from all parlies tc the pro-
ceeding. The  ...:cncy reserves the op-
portunity to present evidence on any
registered use affected by this order re-
gardless of whether or not a hearing has
Veen r  authorises the Administrator of
the Environmental Protcc' on Agency (or
his dpslgnee) to issue a notice of Intent
to cancel the rc?lsl. > tlon  of a pesticide
or to hold u hearing "filf it appears to
the Administrator tluit a pesticide or . .s
labeling  '  * docs not comply with the
provisions of this  act or,  when used In
accordance will)  widespread  and com-
monly  recognized  practice,  geneially
causes unreasonable adverse effects OH
the  environment   * *."  The  phrase
'unreasonable adverse effects on  the en-
vironment" is defined in section 3 of the
Act (7 U.S.C. 136(bb)) as ''any unreason-
able risk  to man or the environment tak-
ing  into  account  the economic,  social,
and environmental costs and benefits of
any pesticide."
  The Act also prohibits the sale of pesti-
cides which ore misbranded. A product
is con Adored misbrahdcd U the label does
no I  contain  directions  for use  and p.
warning  or caution statement which arc
nccessai-y and if compiled v.ith p.ic  ade-
quate to  protect health and the environ-
ment. (7  U.S.C.  136(a) (1)  (F) and (Q>.)
  Hcptachlor and chlordanc are chlori-
nated hydrocarbon insecticides, and have
a chemical structure which is similar to
that of Aldrln and Dicldrin. Both pesti-
cides consist of a complex mixture of
compounds  whose ratios In  the  final
technical product have been standard-
ized.  Technical  hepUchlor   consists
primarily of pure hcptachlor (70-73 per-
cent),  garoma-chlordr.nc  (20-23  per-
cent),  nonachlor  (4.5-5 percent.1, and
small amounts of both  the initial rc-
nctant (hexachlorocyclopentudienc) nnd
chlorcne. Technical  chlordanc consists
primarily   of    approximately    equal
amounts of alpha-chlordnne and paro-
ma-chlordanc . (lotal:  435  percent),
pure heptachlor  (10.'_3 percent^, non-
uc-hlor n
eroxldc  may nlso be formed  y sii! 01-
canlsms.  In  nddllion,  :.  cf;cd  l. r.icr
more toxic  t  insects and  rrssh  water
animals than heptachlor has been shown
to be formed on exposure of heptachlor
to  sunli.'ht.  Oxychlordane.  a  maior
metabolite of chlordane, found primarily
in animals  (including man), is lormcd
very slowly In normal liver tiss-te. Its
formation, moreover,  Is accelerated  by
*he presence of compc>"nds such as DDT,
dieldrin, or heptabarl  uU.
               HI. USES
  Heptachlor and chlordanc have been
used  extensively in  the  United States
since the 1950's. In 1971, 70 percent of
the approxlmn My one million "pounds of
htpt.ichlor used in U.S. agriculture was
as a soil treatment for a wide variety of
crops. Its primary use was  on  cor.  but
aUo included vegetables,  cereals, fora'.o
crops, seed  crops, and seed  treatment;,.
The remaining 30 percent was used j\ i
the  protection  of commercial and resi-
dential structures against termites Hnd
for a variety of nursery, lawn,  ond ear-
den applications, and for foliar applica-
tion to.ditch bpnkr, roadsides nnd vacant
fields. Total use of he.4achlor  lucre
than tripled in 1972, of which  over  1.7
million pounds \vas used for termite.1! nrd
structural pest control  ulone,  anc'  1 u
million pounds was used on acrirjhural
crops, it is estimated that the u.-,'- of
heptnchlor on com alone could incie.tMi
to 3 million pounds in 1975.
   ChJordane is used in  much  prctitt-r
quantities than heptachlor, and  Ic o-ic
of the most widely usi'd  houschoU ;...!
garden pesticides. The quantity ti=ed hij
Increased from approximately 11 millum
pounds In 1971  to between 15-16 miii':i
rounds In 19V2. About 00 percr-nt of t.ie
1972 volume was used for tcrmiU' cMiticl
and other household and conmici inl a-i-
plications.  including  crabgrav, cot'.iol,
uso  on shade tr>cs aud oniameii'u:-<. ni.d
treatment of indoor pusts. An acUiiUunni
6.5 million pounds were applied to com.
 grain, fiber and forage crops, am!  a
variety of fruits and vegetables.  C!i!cr-
datie  Is also used ns a seed treatment
 and in summer months Is applied directly
to wat^r in sewage treatment plants for
control of Psyclwda  larvae.

   There arc alternative pesticides regist-
ered for virtually  nil of the rtU^t'.red
uses of  both hcptachlor  and chlnrdnnc.
As  registered  alternatives,  thc.*e  icsu-
cldcs should be effective  although there
may be  geographical arras or f]>omi
situations where this is not true.  M:\av
of these substitutes may be more expen-
sive than hcplochlor and clilordanc.  In
addition, most arc  less  persistent,  al-

 Ihrmith  I'i'rclit.'ncc i:; frequently imt
 crltlc.il faclor l terms  of  efficacy. In
 the  case of s'.'lii'iriai-o termite  roinrol.
 however, per. r.l^iiru  Is  cilticnl.  A!drin
 nntl cilfl  rln ate Die principal other pcr-
 sl.-.lrnl ycsth-k!-, p'-c-'.?uUy registered for
 subsurface  ni plication fur termite  con-
 trol.  Tl:e:e i'-.-. of siii'rin .->nd  rt:.li:ri;i
 were not ricliu.'i-d i;i  tin  r..i  cm  SU-.IK-.--
 5.ic!i order of Hi.' Aiiminislnlor nor in t':it;
 cancellation re. ion now iir-mlms.
   AltlK.-p.ll  S%-:IIP  .ilfi-ni lives  limy l,e
 mere bcul<-l.v (o\lj '.hiu-. i.cptachlor ;a:d
 chlurdnno. hnzarils to applicators may be
 minlinr.-.id by  ailhi. rcnrn to  labeling i'.i-
 .'.rooiionr- n.nrt i-'ii'-rr-r nVuvm.:. v.'ilh "if!
 benefit of cJiniinatinrf llv: chronic cTect;
 Of l.Pl-t.-U '.111'/ ,tl vl (<)loi'i1.'i1ir but thc>s
 uict^oiL-  should !>'.- thoroughly  colored
 in the hcarlnc".
              V. TOMCIVY

   Heptaciilor nnd  clunrcUiic arc chlori-
 nated hvdrotailjJti p^ticid?.-. v.hleh are
 bread siieclrir-.i  j.'e-.'lciric.s ni.cl are- U>XK
 to nouliTget PV-...><.,.K p. well :": to In-
 sect pchls. n<.i'uctii..is in bird  i.O)ni!;V. ions
 following appHc; i .en cf heota'-hloi- to a:i
 urea  liave been re r or tod  frequently. If is
 diffi.-ult, however. (o r,r:'crmmc wh:r.. 1111-
 paot  Iheso toMCilles  hv.c  on  sprc'.cs
 popu'iV.'ons. .v; o"r.i-ed to Individual Hill
 or \\ikllM" or  ;>. ^-i.ic  Icc.U ])opulnt.ions.
   Hcplachlor   mid   chlordune   ha\e
 detnomlratci1  l-ale  e<7rcinoscnicity
 Panel of  the HEW Secretai-y's Commis-
 sion on Pctticidc.^ nnd their Relationship
 to Environmental Health judced hrptn-
 chlor cpoxidc "posiii\-c for tumor induc-
 tion on the basis of lc;;ls conducted  :u!c-
 quak'ly in one or  more species,  the re-
 sults  being significant at the 0.01 level."
 Subsequent analy.-is by pathologist* re-
 vealed a high incidence of  carcinomas
 In animals from the experiment (crcaWr
 than 90  percent incidence  in  animals
 Blven heptachlor cpoxidc).
   In  addition  a  tv.-o-.%ear focdlns study
 of lit'ptachlor cxpoxlde to 225 CFN r.i.ts
 shoved a significant intixa.se in the num-
 ber of animals with  tumors at  the 0.5
 ppm  fcediiiR level, ond for all test ani-
 m;ils ^t all fccdlnb IPVIK '0.6 ppm to 10
ppm)  when  the gro'ips were combined.
 TT.e tumors were found primarily in the
 endocilnc ornans. but  a sub tnntial num-
 ber of  liver tumors wr re found in  the
 tr^atwl animals while  no Itvrr tumors de-
 veloped in the control ;froup.
   There Is cvlclcnn- of embryotoxicHy on
 the p.irt  of both hrptachlor and chlor-
 dnnc  to some strains of raU or  mice.
 Embryotoxlcity Is  of  particular  impor-
 tance since heptachlor cpoxide  residues
have boen d< K.rted in human fetuses aurt
nconr.tes. 'riine Is addilfonal evidence i:i
the litcniture nullrlins other toxic effects
of a chronic n.'iUire attributable to hep-
tachlor and i.hloidnne. All such nv Idcnce
.ilioulil bo further explored In  the hear-
  r;ince  technical  chlordane  grncrally
rontalns 8 to in percent hcptnehlor, all
of the findiiHis reported above for hepta-
chlor and ir-s mci:i>x>litc; nrc i\ievant r;.rs after application.
Ill  addition,  hoptcihiur  |j Quite  vola-
tile. Ciilordane If  nNo \o!:iillc,  thoujii
somewhat less  to  than he^lachlor,
CMordanp vpnors  c;.n i.onetr, Io pack-
aeinR material nnd roi.'.ammatc  food in
homes in which i: I.-, used.
  Although \ve do not have data which
can  be considered  representative of  the
amblc'.il air natic:v.ir.y, limited sampling
of  si>s  selected  for other  pm-poocs
s'lo-.ved Uie presence of hcptaclilor, and
io a very llm;tcd  r-xlcut, chlordnnc. Tiii^
uidicatc.i that air can be  a  source  for
human intake of the*? compounds.
  A.S persistent compounds, hcptachlor.
chlordane,  and  Uicir metabolites  are
subject to considerable movement from
the site  of actual  application. Residue;-
of both  heptachlor and  chlordane can
be picked up from the soil and translo-
cated to  various parts of plants. Rem-
nant residues are particularly significant
in root crops such as carrots, potatoes,
and beets. In addition, residues of chlor-
dane vne detected in  alfalfa  growth.
sampled at 2 months, 4  months, and 1
ycur after ;rppllcatio;i to soil, at a dosage
of 5 to 10 pounds  acttnl chlordane  per
acre. One of  the major residues found In
alfalfa was oxychlordane (17  percent) .
  Although low In water solubility, their
afllnity for liplds  and their ability to ad-
here to particulatc matter make hepta-
chlor and chlordane  subject  to bloac-
cumulation and  transfer in  the  food
chain, particularly in nauatlc species.
While heplotthlor and chlordane would
appi'nr to bo relatively  Immobile once
they are  bound to the soli, CM  labeled
pesticides  from  treated  fields cast  of
DnllaK, Texas, v/crc monitored and Intel-
found  to have been deposited by roln
over Cincinnati, Ohio. The dust deposits
contained 0.5  ppm chlordane. Treated
r-c-il Is also subject to water erosion, ulti-
mately leading to aquatic contamination,
Including contamination of phytoplank-
ton and fish.
  Chlorinated   hydrocarbon  pcs-ticidcs
have been delected in surface waters In
i or.cenlrations of  10-150 ppt. Hcptarhlor
eomcnti.Uions in the Upper Mississippi
and Missouri River Basins were all in the
iiiirts-pcr-trillion  range and  in  many
mcr basins of  the  count- '. ran"ed be-
t-.vci-n 5-30 ppt.   Hcptaehlor  pjioxidc
concentrations have ranged between 5-40
  Hcptaehlor,  licptarhlor  epoxklc and
chlordane residues nave been found frc-
ci'ently in fish, birds, and other  ,-.inMne.
Heptachlor epoxldc has  bscr. dct.?trd In
birds at levels of 0.01-1.0 ppm. Ch!c.-'-il me
residues  in n.--h hpvc renei ally bcc-n \ftr,
than 05  ppm.  Blues-.lll  growth 'va re-
duced In  heptachlor-tu-.ited lumiU at a
concen'ratlnn In the water of 00" j>i''".
Heptachlor and heptachlor cpoxidc icsl-
ducs of 0.01-8.46 ppm were fcmit! in lish
fro.n the  Great Lakes area.
  Hcptaehlor cpoxidc has also been dis-
covered in  the  tissues of several mani-
maU, including  proni:hoin antelope- (0.03
ppm), and mountain  goats  in South
Dakota (0.12 pp:n>. which Is  indicu.ive
of its widespread distribution.
  Heptachlor,  hetihu-hkn epo. ide. fud
chlordane residues linv also bee:i foun'l
in food samples. Market bp.skct sair.jjles
'or lotal diet studies .'.ere purcliascd fr ,:'.i
retail itorcs on H bi-monthly baii.s in fr.e
ie7ions of the  United States over a O'.v.
j^.r  period.  Hcptaehlor  cpoxi-le \-ts
commonly found in the  ^'Iry,  incat. fish
and poultry components of the d'.-.t. \U-'T
the  residue levels  ranging lr.>;n trare
(0.001 ppm) up to .03  ppm. The same
surveys have Indicated  the presence of
chlordane with first quarter 1974 levels
being found at 0.01 to  0.3 ppm  in sir.-
ni leant percentages of  cattle  and poul-
try. The primary source of such r.t-iducs
in these products is probably the u.'c o:
chlordnne and hcplnchlor on feed crops
like corn  and al''-.lfa.
  The n.ost Important aspect  of  the
movement of heptachlor and  chloi\i;,nc
in the '.-nvironmcnt Is the presence of the
metabolites of tbe&e pesticides in man.
Humiin monitorirtr studies conducted in
this  country  found concentrations  of
hep" ichlor cpoxide  in the adipose tissue
In 96 percent of the 3451 hospital patients
studied in 1970  (mean concentration:
O.OS npm); {!" percent of  the 37(j" pntl-vitE
studied in 1971  (mean concentration:
0.08 ppm); and 93 percent of the -J.151
pruiants studied In  1972 (mean concen-
tration: 0.09 ppm).  (Level of detections
0.0)  ppm). Oxychlordane residues  \\arc
detected In the adipose  tissue of 97 per-
cent  of 3359 patients sampled  In  1!'71
(mean concentration: 0.10 ppm), and 97
percent of 2707  patients sampled In liWJ
(mean concentration: 0.11 ppm). m. Recent  studies Indicate that  an
additional chlordane metabolite, trans-

noiiccUor. inny also be primal iu a very
l:i"h );rrC'."U:>~C c.' huili;-lli.
  Ciu.r T.truticut of licpi::clHi~r epoxlde
reslcli' .3 :irc found not o:ily i'.i .'^'.'-at?, but
In stillborn Uifjiits   :  v.'ell. Tlie orn.ans
of 10  stillborn infants obtoire-:! in  two
Atb'.ii;'.  li'.':.:ii!"-ls \veiT  K'viil to ro:ilaln
an avrrasc 01 O.hS ppm hci>'. ehlui -.rox-
ld.'.  The  l)l.:hPst  levels v <'.< fouii.-i ill
tbc hrart, :id;cnal pl.uvi.  nnd \.\i-\: The
findi .  of t.-.Idi.c-s  In  M::loorii imV.nts
dei.ioii'.i'':1.!'S lir.it hi-p'^-M.;!' cp:i .;clc is
transferred  from the mmhor  to  the
In.'anl a'.-rjsi t:>e plnceu-.n. jn  r.ddiiion,
53  lit"*>an  milk  rnni.)!c d'llcc'.ed  111
Phihulrlphi'i, and Center County,  i'cnn-
SJiV'i  i:.,h:>.c.' :.'i ^ivei'liiTi.1 r,i. i-fiii.'';>Uou of
htvt::;'!:lo.- t;j'.y.d- of (>..".' ]*:<:r   .n milk
(:ii i In  f tvdy reported in ': "7.'. Three of
the .-tffii.'.'va v.evc In  (he n.-'O ppm l."1 0-49
ppn. r.-.r^o.
  Tills"1  fl'u'jiss  nre  c':  l-'H'!'..;; since
o:r:.;i!..ius that  ?vc  CT  -:'  fi-<-.ri  Ihe
time  of  conception aur!  tiur.  for  the
toltivxc  o! I'lClr life IMC T",>t  10 be more
responsive llr-u  thon- v nose  o.i.osure
bci;ir,^  nrt<".-  v.crn.'n;.  t'-r  'liis icason
e\i''l'.'iicc that hurin!) folvj.. .TO expo-ed
arrc;s the p'ac  'itix  i- continued
nfii-r \v?r:!i']<;. Qt:~:itific:.iior- nf Lho risk
ta ir;"n '! l!N basis  o!' 11 co:;i'i:T.r;on bc-
twrcn  th" !t vc-ls of a  c in-;..o-:c:i to v.-bich
liifin I  oi-ta-S M>d l!.r- icvdi v hlrh pro-
du'.'.a  c:.:-:cv Jr.  e>:rci'iiA"mril r.iiinals is
extremely difficult IJCCPV-J of t'-c iiuin-
lier of Jpt.'o:-s \vhlcli nvi'l  he CO:T irtered.
In Uie i:"^u of h.'jjljichicr (':-.'-:ic'e.  cr-
perini?nt"l riiimiils  \vcie  C .'..d  only by
U'.o  oro.l  ror.te  \vhere;:s   mnn  may  be
       d  by Inhalation of oir s- v (!:. Tlio
       to v hich  anlmnlr. arc c>;5o.:ed nrfi
often iu ti--:-iiu of confciitiMtions in the
feed (10 ppm and 0.5 \i\r.\\ in experiments
reijorlcd r.bovc). For a C!M :>( < -.mpnrison
of orr.l doi.ntc .. tlw cone'.r.:I'.s'ion in feed
(or i.inn's fo.'icli  must  be nu.Hi|;'.;ed by
the \olume of feed  'or ;cod)  roivniincd
per <\ny to fcive  the cinily intalT  of the
carcinopen. This must be further  ad-
justed cither for weight  or sUe of the
animal or nan.  Even  such  r.n adjust-
ment  is  Incomplete  v.ithoul some com-
pens.ii.uji ior differences i:i  rr.'Jubultc
rates. Hoth lenglh of exp-."=tire (probubly
in tiTms  of perccn'.nse of  n-'vmnl  life
spam  and llic PKC ^-t ui.ic-h expo-lire is
initiated .pui.it l>c eonniciered. Addition-
ally, nn  ussiimptton mil:.', be made r.bout
the rolhtive :.(.':\!.itivilics  of the  experi-
mental nnlnvils and i:v.m  lo tho cruclno-
Ecn in (iucjliji\. In  the rsiblc. he-
cause  of nil of the unquunilftcd factors
di.scns.'.c.d  above,  to  n.-^ipn o  ivuncrlcal
probnbility to the risk that  hciitnchlor
expoxide may produce cancer In hmriHiis,
some ecn?rdllzed  conclusions are  pos-
sih!..'. Tl.c pieseutcd evi;ip;ice of measiir-
o'.ile qu i:.t;-ies L-nt-.rinir nun's body and
further lie-ing transfcrrc-d to fcluf.es in
ll:i:  i:'.;n,.-;. indicates tl-.n:  htimai-s  are
c>. 10 --ed to hep'-acliior ipoxi'Jf fm:n t!ve
i.iii!:u;~i! ol  co!K-c,)tiou  Oil  li.ioiit>h.-ut
l.ft  This ir. .-.uir-cltnt basis for trave con-
CPi'n !uf Uie posjuljiliiy thsit tainans. HUc-
thv pyj'"rn.ii\l:ii mice, pnd rnL-. in::vre-
h(^lo:-.,.-:i c\pi.  uiv by prodtu'.liif mrvii;-
lu.nt '.-.inort.
  On t'.ie  tar-!s of present Infonmtion,
natiu'.-.ul miiuroucouomlc effects from t. -
r.'.iict-'.i-itiou  of  c.hloi tiuiie rr.,-1  hepta-
c'..l-j:-  r.re  c^'.imalrd  i   be  nc!e.
OvciT'i  nation, il product inn,  cost i.cd
piioe cJerLs vlJl  be minor for nil vsei>.
Hov.tvtr, sonic inlcroeconomlc ifTeci-- la
f.;i-cl'':  rer.ioual  mid locr.l areas  ivsy
oc-ur i.ir COIT, I'nrtlcnlnrly on land sub-
ject to !)lr;-k  cul\vo:-m infestation. Some
micro1 ro;ionilc efTect.'.  an  po:-5ililt? for
citnis   ami   fclrawbcrry  '.i.JC3.  Cc-.'.aln
sp-c::ilty trcps may pi'^  be  imp; .:'od
b;J lii.s v ill  need to be- u. sf-.-i-ed in the
Jieorlr.g. For LI 11 remaining uses lucludinc
hay :.:'.'i foivise.  tobacco, peanuts, ve^e-
li''>lfr.. hvfsiock. :;o\|j,v.ni, cr.rton. i:dla-
tci'js, crape"! and  other frutUs :md vecc-
ta'uK-.-. \l-.i-rc  is no indication of sltfnifl-
cani n.?ciu- or micro-economic  Impacts
or cii: V.cntions.
  ror  ti.o :nii7)oses of the fulk-vivi; ':i;s-
etii''.'"'  fiivjlncs v.'ilh rcrrr.i'd to  \'.T-' ri';':'.
of  hi;i'.r,clilcr must apply  to  r-'-^i  tercd
ch!o:<>. :io jirot'ucts since chlordane rs
r<-;.i L-'.-d  r.Md   ned  always  im Ivdes
he; '.-'ch'mr in su'j'.l".ntial amounts.
  A (ii'cit 'ion of  the  rlr!:1!  a:..=oi-nted
with r> pcstk-ide under questir/.i as posing
rnvlvor.irienf.l or  human  hc-.-.H'.i  con-
cerns mu: t Le based upon Rsst:>5incni of
two int'.-n. Ir.lecl factors: the toxicolocl-
cal cVav-'Ctrnxtics of the comi^ound. and
(he rvr-'.Vibllity of Uie compound in en-
vironn-en1 il  compartments  which  lends
to  expo.- Mru of man or  of  olh'.-r oj-gan-
isms. hi-itlicr fuctor taken alone is suf-
ficient  t determine  or estimate  total
risk. Kvidoncc concerning I'isk will, thf-n.
be  summarized in two parts:  I'.rst.  the
efl'onus  of chtordane  and heptarhlor on
mnn c.r other orcnnlMno; and second the
levels of exposure \\liich have been found
to  occur as a consequence of  'he use of
the.".-' two procluets.
  r-jr.cerning toxicity. heplachlor epox-
ide h:u; Ivcn demonstrated  to be  car-
cinogenic ih two specie; of  laboratory
niniriil*: mice and rats at IcveU as low ns
10  prut  the orp:.ns of 5U11-
boin fetuses.  Aiv.ilysls of  ai't-ip :>  pii'l
biop'.y samples fho\vs chlo:vl:ine. hcpta-
chlor.  nnd, or Uiclr met;Ujolit'.-s  :.t  sis-
nlflcaut  levels in humr-i aUiijoun ti. r.ue,
further indicat!:!-: intake r.n'.i b'otonci n-
traUon by man.
  Air.il:ibic evidence of the costs of  dl--
conllnuinu the  use  of lu-pU".'i]or  n:id
cliloiu.u;c caii be Kuminnrix'jd &s ro:io\.'s:
Economic ccrvl": of pe:t cont-Tl mny  r: ,e
but Uls expected lf;.;i Uie lux: ...' nltcrna-
Uve mean-, of pv:,t roi trol v:i!l ul!o-.v con-
tinued control at c?t,iR whtcti liulirrtc no
sltniific.ini ad1 er/o  inocruecoi.vimc <-
fects. In certain KO graphlrsl an-n" or
for eel lain crops, inicrocconomic dislo-
cations ".t the farm or coun'.y U-c-1 m!;;ht
occur. Tiie extent or this impact. If  any.
v.lll need  to  be  asj.cs-cd farther In tho
            IX.  C
  Wcifrhintr the risks presented by   ie
continued u^e of hopt.'rhlor :"ij  chl'jr-
diuie r;':'!r,'i  tlielr  btnciiU, it i.,)pears
that  tlK'V po^e an unreasonable risk  to
rnrn.   /.Itliourh  tliose   it.Ks   .xiuirc
furth-T dcAnliion, a notii R of  Intent  to
cancel  Ihe.;? pioductj should be i"-u^d in
order tnnt l^tli ihe i'i-k-5 ?;K;. U. ^ !, --ofUs
mav be moie fulX-  Ccvelopcci u.:o'r,h Uie
pub'.r  hear'.iR rrr.ievi. PL..; c !._'a-i^^s
should L'low  c!l pe' tiiK-ut r-. iJvnce  !o
be  brow ht forth an:' c\nmn.d r  that
a  fully mfcrmco.  Irdepfh :;!M!y>.3  of
rlfks ii'ic! bsiip'"-'.-; ni.-y be :r -i'   r.nd ap-
propriate reirccilcr. Ja;h!onc'.l.  Iic-.u-rc'ies
to  be considered at the he.irin?s sli-j^ld
Include ttrcnt'lhi-.Mng use restrictions,
should any be appro;n:ate. a? v.cl'. as re-
uovnl  of these products from Ihe market
for some or all usts.
  Keen use heptachlor   and.  clilordane
h.-'ve n very lurpc number of  u>ts. the
Aeer..y re;;c .ve the  oppoilunltv f,o pre-
sent  evidence on any re  .istcn-d tire af-
fected  by UiU order rcpardless of n lu-'.i.er
or  not a  heari.i!; has br>.>n  rcqveytc^  on
that  u>.o,  or  whether or  not su- h -j?e i^
to  I oetlvcly defended in tho l.c.'.rin.-.s.
  T.le  only exceptions to  the notirp uf n\-
.cnt  to cancel are  Uie u'.? of c-ciiordunc
and  ncptachlor  for sub ivfuco >; round
in.'.ortions for tennj'.c c.'/iurol anil for tni
d!p:>ini{ of nonfood  plains. Tm-.-t  u. cs
n;-li!evc the  derind  c-.-Krcil  of Lisects
v.Hl.'j'it apparent utj-> ^o;:-.:.le envlron-
mentu conlamiiiulioii.
  A  draft cnvironr.-.cnlnt i;npprt state-
ment concerning this intent  lo  cancel
certain products containing heptnchlor
nnd chlo'-uanc Is b:-ii'.r. prepare. I and will
be  available in approximate^1 CO da vs.
  Aa Order corieerniii-; liitr.1 ,uite prod-
ucts  containing  heptachlor -i'.d  chlor-
dane Is also being issued today.
  Dated: November 18, 1374.
                           . E. Tn.MW,
                                                Doc.74-27546 riled ll-5-74;B:45 am]

                                  APPENDIX 2


                           CHLORDANE             HEPTACHLOR

                           %   Ib*               %   Ib*

Agriculture Use            28  6,005,000         59  1,187,000

Termite Control            35  7,342,000         26    551,000

Other**                    37  7,826,000         15    312,000

Total                     100 21,173,000        100  2,000,000

 * Active Ingredient

** Including use inside houses and other buildings, on home
   gardens, on lawns and turf, on ornamentals and shade trees,
   on forestry plantations, on agricultural premises, in
   nurseries, in sewage treatment plants, in mosqu:'.to control
   and in seed treatment.

Source:  EPA extrapolation of industry data

                               APPENDIX 3



                        CHLORDANE AND HEPTACHLOR


     Climbing Cutworms






     Japanese Beetle

     June Beetles

     Mole Crickets

     Root Maggots


     Rose Chafer

-  Carbaryl

-  Methoxychlor, Methyl Parathion,
   Carbaryl, Malathion, Diazinon,

-  Methyl Parathion, Toxaphene

-  Carbaryl, Trichlorfon, Toxaphene

-  Methyl Parathion, Carbaryl, Diazinon,
   Trichlorfon, Toxaphene, Dylox

-  Carbaryl

-  Methoxychlor, Methyl Parathion,
   Carbaryl, Malathion, Diazinon,
   OMPA, Toxaphene

-  Mevinphos, Methoxychlor, Methyl,
   Parathion, Carbaryl, Malathion,
   Diazinon, Endosulfan, Toxaphene

-  Methoxychlor, Carbaryl, Malathion,
   OMPA, Toxaphene

-  Carbaryl

-  Diazinon

-  Diazinon

-  Methyl Parathion, Phorate, Malathion,
   Diazinon, Dlsulfaton, Bux, Dasanit,
   Furadan, Dyfonate Mocap

-  Methoxychlor

-  Metaldehyde

                         APPENDIX 3  (continued)




   Lindane, DD Mixture, Diazinon,  EDB,
   Dasanit, Dyfonate, Furadan,  Mocap,

     Cabbage Looper

     Climbing Cutworms



     Darklin Beetle


     False Chinch Bug

     Field Crickets

     Flea Beetles
     Fuller's Rose

     Japanese Beetle

     Leaf Miners
-  Carbaryl, Methyl Bromide, Chlorpicrin

-  Mevinphos, Carbaryl, Malathion

-  Toxaphene

-  Lindane, Methoxychlor, Carbaryl,
   Malathion, Toxaphene

-  Carbaryl, Malathion, Lindane,

-  Carbaryl

-  Carbaryl, Lindane

-  Methyl Parathion

-  Methoxychlor, Carbaryl, Malathion,

-  Methoxychlor, Carbaryl, Malathion,

-  Guthion

-  Lindane, Mevinphos, Naled, Endrin,
   Carbaryl, Toxahpene

-  Methoxychlor, Carbaryl, Malathion

-  Diazinon

                         APPENDIX 3 (continued)

     Lygus Bugs

     Mole Crickets

     Pill Bugs

     Rose Chafer



     Stink Bugs

      Crown Borer

      Root Weevil

     Strawberry Weevil


     White Grubs

-  Endosulfan, Mevinphos, Methoxychlor,
   Carbaryl, Malathion

-  Diazinon

-  Lindane, Methoxychlor, Naled, Carbaryl,
   Malathion, Diazinon, Endosulfan

-  Methoxychlor, Carbaryl

-  Methaldehyde, Carbaryl

-  Metaldehyde

-  Mevinphos, Carbaryl, Guthion

-  Toxaphene

-  Malathion, Methoxychlor, Endosulfan

-  Lindane, Perthane, Methoxychlor,
   Naled, Carbaryl, Malathion, Toxaphene

-  Endosulfan, Naled, Methyl Parathion,
   Carbaryl, Malathion, Guthion, Mevinphos,
   Methoxychlor, Diazinon

-  Chlorpicrin, Lindane, Methyl Bromide

-  DD Mixture, Chlorpicrin, EDB Methyl Bromide
PREMISES (indoor)



     Brown Dog Tick
-  Lindane, Methoxychlor, Lethane
   Malathion, Ronnel, DDVP, Pyrethrins,
   Baygon, Diazinon

-  Pyrethrins

-  Naled, DDVP, Baygon, Carbaryl,
   Malathion, Diazinon, Chlorpyrifos, DDVP

                         APPENDIX 3 (continued)
PREMISES (indoor)






     Granary Weevil



     Rice Weevil




 -  Methoxychlor,  Ethylendichloride,
   Pyrethrins,  EDB, Methyl Bromide

 -  Diazinon,  Ronnel,  DDVP, Baygon, Lindane,
   Fenthion,  Malathion,  Trichlorfon,
   Pyrethrins,  Chlorpyrifos

 -  Baygon,  Ronnel Pyrethrins

 -  Thanite, Diazinon, Chlorpyrifos, Ronnel,
   Rotenone,  DDVP, Compound 4072, Pyrethrins,
   Naled, Dioxithon,  Carbaryl,  Resemthrin,
   Lindane, Lethane,  Methoxychlor, Baygon,

 -  Lindane, Malathion, Trichlorfon, Ronnel,
   DDVP, Pyrethrins,  Lethane  384, Methoxychlor,
   Carbaryl,  Diazinon, Fenthion, Resemthrin

 -  Pyrethrins,  DDVP,  Methoxychlor, Malathion,

 -  Lindane, Methoxychlor, Malathion,
   Pyrethrins,  Ethylene Dichlordie,
   Methyl Bromide

 -  Pyrethrins,  DDVP,  Resemthrin

 -  Lindane, Malathion, Ronnel,  DDVP,
   Pyrethrins,  Lethane 384, Methoxychlor,
   Carbaryl,  Fenthion, Diazinon, Rseemthrin

 -  Lindane, Methoxychlor, Malathion,
   Pyrethrin, EDB, Ethylene Dichloride,
   Methyl Bromide, Trichlorethylene

 -  Ronnel,  DDVP,  Pyrethrins,  Baygon,
   Lindane, Methoxychlor, Malathion,

 -  Lethane  384, Methoxychlor, Malathion,
   Ronnel,  DDVP,  Baygon, Pyrethrins

--  Naled, Dioxithon,  Carbaryl,  Baygon,
   Malathion, Compound 4072,  Lindane,
   Methoxychlor,  Pyrethrins,  DDVP

 -  Ronnel,  Pyrethrirs, DDVP,  Fenthion, Resemthrin

                                                  APPENDIX 4


                                                                 ESTIMATED AMOUNTS USED (1974 BASIS)
      No Cancellation
      Cancel All Uses
      Cancel All But
      Termites & Dips

      Cancel Food &
      Feed Uses
Agri., Termites,
 & Other*

Agri., and Other*

Agri., Termites
 & Other*

Termites & Other*
 %  Ib (mil)

100  21.0
 35   7.3
 72  15.2
  %  Ib (mil)

100    2.0

  0      0

 26     .5

 41     .9
                                 "Other"  includes  use  inside  homes  and  other  buildings,  on  home
                                 gardens,  on lawns and turf,  on ornamentals and  shade  trees,  on
                                 forestry plantation,  on  agricultural premises,  in  nurseries,  in
                                 sewage treatment  plants,  in  mosquito control and in seed treatment.

                                                 APPENDIX 5
                                                             NATURE OF EFFECT
                 Short-term*   Long-term**
                               Short-term*     Long-term**
      ALTERNATIVE jii   No Cancellation

        Environmental                   Moderate
        Human Health                    Minor
        Economic & Social*               Moderate

      ALTERNATIVE #2:   Cancel All Uses***
        Human Health
        Economic & Social
Cancel All But Termite
Control & Dips
        Human Health
        Economic & Social

Cancel Food & Feed Uses
Human Health
Economic & Social
        *  One year or less after action taken  (and cancelled uses terminate).
       **  One to ten years after action taken  (and cancelled uses terminate).
      ***  Assumes unavailability of aldrin and dieldrin for termite control uses,
       1.  Nationally
       2.  Limited geographic area, user group, or industry sector.

                                 APPENDIX 6

1.  U. S. Environmental Protection Agency.  Pesticidal Aspects of
    Chlordane and Heptachlor in Relation to Man and the Environment
    A Further Review, 1972 - 1975.

2.  U. S. Environmental Protection Agency.  EPA Actions to Cancel
    and Suspend Used of Chlordane and Heptachlor as Pesticides:
    Economic and Social Implications.  1975.

3.  U. S. Environmental Protection Agency.  Heptachlor - A Review
    of Its Uses, Chemistry, Environmental Hazards and Toxicology.

4.  U. S. Environmental Protection Agency.  Pesticidal Aspects of
    Chlordane in Relation to Man and The Environment.  1972.
NOTE:  For single copies of reference documents 1 and 2 and for
       information on the availability of documents 3 and 4 write:

                  Federal Register Section
                  Technical Services Division (WH-569)
                  Office of Pesticide Programs
                  Environmental Protection Agency
                  Room 401, East Tower
                  401 M Street, S. W.
                  Washington, D. C.  20460