REPORT
       of  the
      M I R E X
   ADVISORY
  COMMITTEE
Revised March 1, 1972

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            REPORT  OF THE MIREX ADVISORY COMMITTEE*

                             TO

             WILLIAM D.  RUCKELSHAUS, ADMINISTRATOR
                ENVIRONMENTAL PROTECTION AGENCY
                     Revised  March  1,  1972**
 *Established Under Provisions of Section 4.c.  of the Federal
  Insecticide, Fungicide, and Rodenticide Act.

**0riginal  report dated February 4, 1972.

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                               CONTENTS


                                                                    Page

  Letter of Transmittal                                                v

  Membership of the Advisory Committee                               vi

  Introduction                                                        1

  I.   Nature and Extent  of Problems                                   5
       A.   Imported Fire Ant                                          5
       B.   Other Pests Controlled by Mi rex                            9
           1.   Western Harvester Ant                                  9
           2.   Texas Leaf-Cutting Ant                                 9
           3.   Other Ants                                            10
           4.   Yellow Jackets                                        11

 II.   Present Control Methods and Alternatives                       12
       A.   Present Methods                                           12
       B.   Alternative Methods                                       17
           1.   Current Insecticidal                                  17
           2.   Possible  Future Non-Insecticidal                      19

III.   Benefit-Risk Evaluation                                        22

 IV.   Residue Estimates                                               27
       A.   Soil                                                      27
       B.   Water                                                     27
       C.   Natural Food  Chains                                       28
       D.   Edible Food                                               33
           1.   Plant                                                 33
           2.   Animal                                                34
           3.   Seafood                                               34
       E.   Man                                                       37
       F.   Projections of Expected Environmental Load                39

  V.   Toxicology                                                     42
       A.   Acute and Subacute Toxicity                               42
       B.   Reproductive Effects in Mammals                           43
       C.   Carcinogenicity and Mutagenicity                          44
       D.   Toxicity to Aquatic Life                                  46
       E.   Toxicity to Wildlife                                      49
       F.   Absorption, Metabolism and  Excretion                      50
       G.   Biochemical                                               51
                                 iii

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 VI.   Miscellaneous                                                     52
'       A.   Chemistry                                                   52
       B.   Tolerances                                                  52
       C.   Possible  Analytical  Interferences and Misinterpretations    52
       D.   Analytical Confirmation                                     53

  Conclusions                                                           54

  Recommendations                                                       61

  Appendices
       References                                                       63
       Persons Appearing Before the Committee                          69

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                        UNIVERSITY  OF  FLORIDA

                        INSTITUTE OF  FOOD AND AGRICULTURAL  SCIENCES
       UflCHIM; (USEAHCM IXHNSIOK
 DEPARTMENT OF FOOD SCIENCE
PESTICIDE RESEARCH LABORATORY
                                                                    GAINESVILLE. FLORIDA 326O1
March 1, 1972
          Mr. William D.  Ruckelshaus
          Administrator
          Environmental Protection Agency
          Washington, D.  C.  20460

          Dear  Mr.  Ruckelshaus:

               On behalf  of  the  membership  of  the Mirex Advisory Committee, I am
          pleased to  submit  the  attached revised  report of  March 1,  1972.   In order
          to meet the statutory  deadline, the  February 4 report inadvertently contained
          several statements and interpretations  that had not been approved by the
          entire committee^   Consequently,  a revision was considered necessary in
          order to  reflect the more significant changes.

               It is  the  opinion of the undersigned that the revision which begins
          with  the  last sentence on page 13 could be misinterpreted to mean that
          Lofgren et  al.  (1970)  concluded these trials were a failure since total
          eradication was not achieved. In reality, Lofgren and co-workers clearly
          stated that all of the problems encountered in the eradication trials were
          surmountable and concluded  from their data that elimination of the imported
          fire  ant  from very large isolated areas may be technically feasible.

               It was on  the evaluation of  the eradication  trials that the undersigned
          reached an  empasse with several members of this committee, thereby allowing
          no possibility  for both sides of  the controversy  to be equitably reflected
          in the revised  report. This difference of opinion on the Advisory Committee
          is certainly understandable since it reflects the same divergent views that
          exists within  the scientific community  most closely associated with this
          general subject.

               Please accept my apologies for  the delay these revisions have caused
          in having a final printing  of the Report  of the Mirex Advisory Committee.
          If we can be of any further assistance in clarifying any statements in the
          report, please  do not hesitate to contact any member of the committee.

                                                  Sincerely yours,
                                                  C. H. Van Mid del em
                                                  Chairman
                                                  Mirex Advisory Committee
          pts
          Attachment
     COU_EOE OF AGRICULTURE     SCHOOL. OK FOREST RESOURCES AND CONSERVATION     COOPERATIVE EXTENSION SERVICE

                     AGRICULTURAL. EXPERIMENT STATIONS     CENTER FOR TROPICAL. AGRICULTURE

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MEMBERSHIP OF MIREX ADVISORY COMMITTEE
    C. H. Van Middelem, Ph.D., Chairman
    Pesticide Research Laboratory
    Food Science Department
    University of Florida
    Gainesville, Florida

    Gerald J. Bakus, Ph.D.
    Department of Biological Sciences
    University of Southern California
    Los Angeles, California

    J. R. M. Innes, Ph.D.
    Bionetics Research Labs., Inc.
    Bethesda, Maryland

    Charles Lincoln, Ph.D.
    Department of Entomology
    University of Arkansas
    Fayetteville, Arkansas

    Leo D. Newsom, Ph.D.
    Head, Department of Entomology
    Louisiana State University
    Baton Rouge, Louisiana

    Jack L. Radomski, Ph.D.
    Pharmacology Department
    School of Medicine
    University of Miami
    Miami, Florida

      *************

    David L. Bowen
    Secretariat to Committee
    Environmental Protection Agency
                 VI

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                        INTRODUCTION
     Mirex (Dodecachlorooctahydro-1,3,4-metheno-2H cyclobuta[cd]-
pentalene) has been used extensively  during  the  past decade  in
the southeastern states  for the  control  of the imported  fire ant,
Solenopsis saevissima  richteri Fore!.  A suit filed by the
Environmental  Defense  Fund in August  1970 in the U.S. District
Court for the  District of Columbia  sought an injunction  and
declaratory judgement  to restrain the Department of Agriculture
in its efforts to eradicate the  imported fire ant.
     In a separate case, involving  DDT,  this same court  held on
January 7, 1971, that  the Federal Insecticide, Fungicide, and
Rodenticide Act (FIFRA)  requires the  Environmental Protection
Agency (EPA) to initiate the administrative  process for  cancelling
the registration of a  pesticide  whenever there is a substantial
question about its safety.
     On March  18, 1971, EPA sent a  notice to the Allied  Chemical
Corporation to cancel  the registration of products  containing
Mirex.  This action was based on a  substantial question  about
the safety of use of this chemical.  Rather than accept the
cancellation,  the firm requested that the matter be referred
to an advisory committee as is  its  right under the FIFRA.  This
committee consisting of six scientists was  appointed on September
24, 1971, by the Administrator of EPA from a list of names  furnished

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                          - 2 -
by the National Academy of Sciences.  The following Charge was

given to the Mi rex Advisory Committee:
     The Environmental Protection Agency is presently eval-
     uating the use of the pesticide Mi rex.  The Agency's
     decision concerning the continued registration of Mirex
     will involve balancing its benefits against its dangers.
     Thus, the Agency must determine and weigh (1)  the nature
     of the benefit conferred by the use of Mirex or, put
     another away, the magnitude of the social cost of fore-
     going the use of Mirex, against; (2) the nature and mag-
     nitude of the foreseeable hazards associated with the use
     of Mirex.

     In order to assist the Agency's determination, the
     Committee is charged to consider and evaluate  all relevant
     scientific evidence concerning the use of Mirex, partic-
     ularly, for fire ant control and to prepare a  report  and
     recommendations concerning the scientific issues raised
     by such use.  More specifically, the Committee is charged
     to consider the scientific evidence and, based thereon,
     express its opinion and recommendations concerning, inter
     a!ia, (1) the nature and extent of the problem posed~~5y
     the fire ant and the other insects  at issue; (2) the
     effectiveness of the several types  of control  measures
     which utilize Mirex (e.g., localized use to control
     local infestations of fire ants; area-wide use to con-
     trol the spread of fire ants; and a multi-state program
     to achieve the eradication of the fire ant); (3) the
     benefits expected to be achieved by each such  control
     program, measured against the damage which will occur
     if no control were undertaken; and  (4) the availability
     and effectiveness of, and the hazards connected with,
     alternative control  measures.

     With respect to the hazards associated with the several
     uses of Mirex, the Committee is charged to consider
     the scientific evidence and, based  thereon, express its
     opinion and recommendations concerning, inter  alia, the
     nature, scope-, and possibility of occurrence of any (1)
     direct hazard to the user and to the general public;  (2)
     hazard to vegetation; (3) hazard to non-target verte-
     brate and invertebrate animals; and (4) hazard to the
     environment generally.

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                            - 3 -
     This report follows an outline which  was  designed  to comply
with all aspects of the Committee charge.   It  is  divided  into two
primary sections, the first covers advantages  and disadvantages
associated with the use of Mirex for the control  of the imported
fire ant and other insects as well as possible present  and future
alternative means of control.  The second  section deals primarily
with possible hazards associated with Mi rex uses.
     Initial evaluation included the nature and extent  of the problem
involving not only the imported fire ant but other insects controlled
effectively with Mirex.  The advantages and disadvantages of the
various present control measures are covered.   Currently available
alternative insecticidal control measures  as well as possible future
non-insecticidal control techniques presently  under investigation
are discussed.  The benefits expected to be achieved by the various
control procedures are evaluated against the possible risks to
man and his environment from the continued use of Mirex.
     The second section of the report is devoted to an evaluation
of the possible hazards to man and his environment as a result
of past, present and future use of Mirex for the control of the
imported fire ant and other insects.  This section includes an
evaluation of the significance of Mirex residues found in soils,
water, natural food chains, human food  and man himself as a result
of past Mirex applications. Projections of expected environmental
load are made as a result  of past applications and future use  of
this toxicant on a more restricted  basis.  Various aspects  of  the

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                             - 4 -
very limited available toxicological  information on Mi rex are  discussed
t
including acute and subacute toxicology, reproductive effects,

carcinogenicity, mutagenicity, absorption, metabolism and excretion.

A brief section is devoted to the chemistry of Mirex, established

tolerances, possible analytical interferences and suggested confirmation

techniques.

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                          - 5 -
I.  NATURE AND EXTENT OF  PROBLEMS  POSED  BY THE  IMPORTED  FIRE ANT
    AND OTHER PESTS THAT  ARE  CONTROLLED  BY THE  USE OF MI REX
    A.   Imported Fire Ant.
        The identity of the imported  fire ant,  presently known
as Solenopsis saevissima  richteri,  is in a state  of flux.  Some
authorities consider that two species have been introduced into
the United States: others think  that  only color forms are involved,
All agree that a "dark form"  first noticed near Mobile,  Alabama
about 1920 never dispersed widely  and now is  known to be the
dominant form in only a restricted area  of northeast Mississiopi.
It is similarly agreed that a different  ant,  smaller and more
aggressive, the so-called "red form"  appeared during the late
1930's or early 1940's.  It spread quickly across the Gulf Coast
states and now occurs throughout much of the  9-state area from
Texas to North Carolina (Markin 1970).
     The pest status of the  imported  fire ant is  controversial.
Claims have ranged from its  being  of  no  importance as a  pest to
its being the most dangerous  and destructive  of all  pests in the
infested area.  Early statements emphasized  injury to  crops,
particularly potatoes, seeds  and young seedlings of a  variety of
crops  (Wilson and Eads 1949,  Wilson 1951,  Culpepper 1953).   It is
now considered to be more important as a pest of humans than of
agriculture.  Previous claims about the destructive nature of the
species as a pest of crops, livestock, and wildlife were greatly
exaggerated.  During the last decade, a considerable change has
occurred in views on the pest status  of the  species.

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                             -  6 -
      Clearly,  the  imported  fire  ant  is  an  important nuisance pests.
 It stings  viciously when  disturbed and  its presence in areas used
 extensively, such  as lawns, playgrounds, school grounds, parks,
 cemeteries  and gardens, interferes with normal human activity
 (Mills  1967).   Its presence in areas  heavily used by small children
 is especially  undesirable and dangerous.
      The true  significance  of the imported fire ant to human health
 has probably not been  evaluated  properly in the past.  A medical
 survey  in  Alabama, Georgia  and Mississippi was recently completed
 involving  almost 2500  medical doctors  (Triplett 1971).  This survey
 shows that  for each year  in the  period  1969-71, over 10,000 patients
 were  treated as a  result  of imported  fire ant stings.  Over 50% of
 the patients reported  in  this survey  required medical treatment
 for secondary  infections.   A significant number of the patients
 were  reported  to have  experienced some degree of allergic response,
 with  a  small percentage suffering such severe reactions that they
 progressed  into a  state of  anaphylactic shock.  These reactions
 are considered to  be at least on a par with anaohylaxis caused
 by  stings of other venomous  Hymenoptera.
      Information accumulated during the last 15 to 20 years shows
 that the imported  fire ant  is of virtually no importance as a
 direct pest of crops,  livestock or wildlife.  Occasionally, it
may attack seedling plants  such as potatoes, corn, and cabbage
and the flowers and fruit of okra.  Indirectly, the imported fire
ant is more important as an agricultural pest.   Because of its
sting, it causes serious problems for hand laborers harvesting

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                           - 7 -

crops such as strawberry,  pecan and  tuna  nuts.   Baled hay
is especially attractive to the ants  and  larqe  numbers may  con-
gregate under bales that are left  in  the  field  for  several  days.
Workers handling the infested bales  may be  stung severely.   Farm
operations such as mowing  improved pastures with sickle  type
mowers, mowing hay meadows and combine harvesting of crops  are
made more difficult and expensive  by the  presence of imported fire
ant mounds.  On heavy clay soils especially,  the mounds  may be  so
large and durable that wear and tear on equipment is excessive.
In addition, time is lost  in attempting to  avoid the mounds and
in cleaning and repairing  equipment.
     The ecological status of the  imported  fire ant in  the  United
States has not been sufficiently assessed.   It  is a general predator
and scavenger, relying heavily for food upon  insects  and related
arthropods that comprise more than 95 percent of its  diet (Hays
1958, Hays and Hays 1959,  Wilson  and Oliver 1969, Markin 1970).
It appears to have competitively  displaced the ant  species
Solenopsis xyloni, S_. geminata  and Pogonomyrmex badius, (Wilson
1951).  It has also displaced the  Argentine ant, Iridomyrmex
humilis, from some areas.   Less is known  about its  effect on
populations of other species of ants.
     Its role in agricultural ecosystems  is difficult to establish
as is the case with most species of general predators.  It is an
effective predator of the sugarcane borer, Diatraea saccharalis,
(Hensley et^ al_.  1961) and the  lone star  tick,  Ambylomma americanum,
(Harris 1971).   It preys heavily  upon the eastern  subterranean
termite, Reticulitermes flavipes, and many species of  leafhopoers

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                            - 8 -
 (Wilson and Oliver 1969).  On the other hand,  it preys  on  pre-
f daceous insects to the extent that some entomologists believe
 that it seriously upsets the ecology of an area (Markin 1970).
 It also tends some species of aphids and protects them  from
 attack by predators and parasites.  Thus, its  presence  may be
 desirable in some situations and undesirable in others.
       Acreage infested by the imported fire ant has  continued to
 expand each year as illustrated in the following table:

    Rate of spread of the imported fire ant (Markin 1970, USDA 1971d)
      	Year	Infested Acres (est.)	
              1932                     200,000
              1947                   2,000,000
              1959                  26,000,000
              1963                  31,000,000
              1967                 106,000,000
              1971                 126,500,000

       These data show that there was a 13-fold increase in number
 of acres infested during the 12-year period 1947-59.  During the
 period 1959-71  an additional 5-fold increase occurred despite the
 conduct of large-scale control  and eradication programs and the
 imposition of Federal  and State quarantine and regulatory  action
 that restricted the movement of infested material, especially
 nursery stock.   Efforts to prevent movement into new areas have
 been notably unsuccessful.   There are indications that  the pest
 may be approaching the northern limits of its  range  but the extent
 of the area  that it may eventually infest in the United States
 cannot be  predicted on the basis of present knowledge.

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                            - 9 -
    B.  Other Pests  in  the  United States that are Controlled
        Effectively  by  Use  of  Ml rex.
        In addition  to  the  imported fire ant, the following
species of locally important pests are controlled effectively
by the use of Mirex  applied as bait formulations.
        1.  Western  harvester  ant.
            The western harvester ant, Pogonomyrmex occidentalis,
infests millions of  acres of rangeland of  the western states.
It annoys man and animals by its painful sting, denudes areas
of vegetation an average of more than 80 square feet around
its mounds, collects seeds, cuts off seedling grass as it
emerges, and damages the shoulders of highways.  The unsightly
appearance of the mounds and ability of the  species to inflict
a painful sting on humans make undesirable its presence  in parks,
playgrounds, lawns,  and other  areas heavily  used by people
(Crowell 1963, Lavigne  1966,  Race  1966).
        2.  Texas leaf-cutting ant.
            The Texas leaf-cutting  ant, Atta texana,  is  a  serious
pest of pine seedlings, hardwood trees  and cereal  and  forage
crops in some areas  of east Texas  and west-central  Louisiana.
In heavily infested  areas,  damage to  buds, needles and bark of
all species of pine  makes  it impossible to establish  natural
reproduction.  Seedling pines are often destroyed in such areas
within a few days of planting.  Foliage from a wide variety of
plants is used by the ants as the substrate upon which they
culture a fungus that provides their only known food.  Nest

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                           - 10 -
areas of this species are characterized by numerous crescent-
shaped mounds about one foot in diameter and from 5 to -14
inches in height.  The mounds are confined to areas ranging
from about 100 square feet to more than an acre.   Huge colonies
develop and foraging ants may range for hundreds  of feet to
obtain suitable foliage.  These ants are often particularly
destructive to gardens and shrubbery in rural and suburban areas.
In the American tropics leaf-cutting ants are the most destruc-
tive pest of subsistence, "slash and burn" agriculture (Bennett
1958, Echols 1966, Cherrett 1969).
          3.  Other ants.
              Other ants of several species tend  and protect aphids,
scales and mealybugs and thus aggravate the injury-producing
capacity of such pests.  It has long been recognized that control
of these pests is often best accomplished by controlling the ants.
A classic example is control  of the mealybug wilt of pineapple in
Hawaii by the control of ants, especially Pheidole megacephala.
It provides transportation and protection for the pineapple
mealybug, Dysmicoccus brevipes, which is responsible for this
serious disease of pineapple.  Spread of mealybug wilt in the
pineapple plantations of Hawaii during the late 1920's was so
rapid that it appeared probable the industry could no longer
exist there.   The industry was saved by discovery of the rela-
tionship between the disease  and ants and the development of
effective control  measures for the latter (Smith  1971).

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                          -  11  -

        4.  Yellow jackets.
            Yellow jackets,  Vespula  spp.,  are  ground-nesting
social wasps characterized by aggressive behavior  and  a  painful
sting.  Allergic reactions to their  stings,  similar  to those  of
many other Hymenoptera including  the imported  fire ant,  are not
uncommon.  Populations of these wasps appear to  have increased
significantly during the last few decades  around parks and picnic
areas in many sections of the United States.  The  availability of
an abundance of food left by picnickers  and  campers  appears to be
a major cause of the increase in  population.  Their  occurrence in
large numbers in heavily used recreational  areas is  especially
undesirable because of their aggressive  behavior and the fact that
a small percentage of the human population is  hypersensitive to
their venom (Parrish 1963, Keh et al. 1968).

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                            - 12 -
II.   PRESENT CONTROL METHODS AND ALTERNATIVES
     A.   Present methods
         Technical  Mi rex,  dissolved  in  soybean oil and sprayed
 onto corncob grits produces a bait  consisting of 0.3 percent
 Mi rex,  14.7 percent soybean oil  and 85 percent  corncob grits.
 This bait, used for control of the  imported fire ant since 1962,
 rapidly replaced other insecticides used  in cooperative  Federal/
 State programs.  Currently Mi rex is used  exclusively in  these
 programs except for nurseries  and other highly  specialized situ-
 ations  that demand use of long-residual,  persistent insecticides
 such as heptachlor or dieldrin.
      Mirex bait is applied at  the rate of 1.25  pounds per acre
 containing only 1.7 grams of the toxicant.  This represents the
 application of an  almost  unbelievably  small amount of insecti-
 cide on a per acre basis  in comparison with the rates of
 application of other  insecticides.   Few of these are effective
 for  control  of agricultural  pests at rates less than 100 times
 the  amount of Mirex applied for  control of the  imported  fire
 ant.  Only some insecticidal seed dressings for control  of
 seedling pests  approach its  effectiveness  (Hays and Arant 1960,
 Bartlett and  Lofgren  1961,  1964).
     The development  of such a highly  effective and comparatively
 selective  method of pest  control  is  considered an outstanding
 achievement in  applied entomology.   "Mirex approaches many of
 the requirements for  an ideal control  chemical for the ant.  It
 is relatively specific as formulated,  rather than a broad-spectrum

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                          -  13 -

toxicant.  It is comparatively nontoxic  to vertebrates and to many
other animals.  It is a highly toxic  and advantageously  slow-
acting stomach poison for the ants, and  can be  formulated as an
attractive bait with potential for  low-dosage broadcast  in granular
form.  The chemical itself is exceedingly stable  and  of  low vola-
tility, although present bait formulations do lose  their attrac-
tiveness and effectiveness in a  relatively short  period  of time"
(Mills 1967).
    Mi rex bait is highly attractive to the foraging workers and
readily accepted by the ant.  Its delayed toxic effects  allow  the
workers to return to the colony  with  it where it  enters  the complex
trophallactic food chain and eventually destroys  the  colony.
    Mi rex bait can be used effectively for control  of the  imported
fire ant on acreage ranging in  size from individual mounds  in  home
lawns to the total infested area of the United  States.  Its  most
effective use from the standpoint of  control  of the ant would  be
for treatment of the entire infested  area and the least effective
method would be individual mound treatment (Markin 1971 a).   Three
properly timed applications of Mi rex  bait, applied at aporooriate
intervals during a period of 1  year to 18 months at the rate of
1.25 pounds per acre per application, a total of 5.1  grams of
Mi rex per acre, to the entire infested area would almost eliminate
the imported fire ant from  the United States.
    Results of three large-scale eradication trials  (Lofgren et al.
1970) showed Mirex bait to  be highly  effective for control of the

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                          -  14 -
 imported  fire  ant  but eradicaton was not acheived.  They also
 demonstrate  the occurrence of a number of important operational
 and  technical  problems.  One of the most important of these is
 the  inadequacy of  available survey and detection methods to
 monitor their  effectiveness.
     An eradication program for the approximate 126 million infested
 acres has been considered and rejected by the USDA (USDA 1971c).
 The  current  position of the USDA is that, although it may be techni-
 cally feasible, eradication is no longer an objective of the Federal-
 State Cooperative  Control program because of financial and logistical
 limitations.   Moreover, they were concerned about the possible adverse
 environmental  effects resulting from such large-scale use of Mirex
 bait.
     Next to treatment of the entire infested area in the country,
 large-scale  programs would give the best results.  The residual
 activity of  Mirex  bait is so short that reinvasion of treated
 areas occurs rapidly.  It appears that the imported fire ant,
 unassisted by  man, may spread at the rate of about 5 to 10 miles
 per year.  Clearly, the smaller the area treated, the more
 rapidly reinvasion may occur.  The individual homeowner, farmer,
 cattleman, or a municipality, for example, might have to apply
one application of-the bait per year to suppress populations of
the imported fire ant to acceptable levels.

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                          -  15 -

     Two or three applications  of  the bait over  large areas might
accomplish the same objective  for  a period of several years.
There would be substantially less  of the bait per unit area in
such a program than where  applications were made by  the  indivi-
dual.  Individuals, having less efficient means  of applying
extremely small quantities of  bait, tend to overtreat.   However,
individuals would treat only those areas where the presence of
the fire ant constitutes a problem whereas areawide  treatments
would be made to substantial areas where the presence of the
fire ant does not constitute a problem.  Thus, the relative
amount of Mi rex used by the  two methods of treatment might not
differ widely when the total amount applied to an area  is
considered.
     The present program proposed by  the  U.S.  Department of Agri-
culture (USDA 1971c) for future use  in  control of  the  imported
fire ant has been described  as follows:
     "...After thorough consideration of all  relevant factors,
the Department's position on imported fire ant control  is as
follows:
        1.  Mi rex bait will  be applied aerially to those
     areas where the ant  is  causing trouble,  where the property
     owners have expressed  concern, and where the State and
     local governmental agencies have requested Federal co-
     operation in a control  program.   Under the plan, forested
     areas which are not  prime fire ant habitat and sensitive
     areas such  as estuarine areas, and State and Federal game
     refuges will not be  treated.  Application  pilots will be
     briefed with respect to all sensitive areas, including
     water, and  instructed  to  avoid application to  those
     areas.   Compliance will be closely monitored by ground
     personnel and aerial supervision.

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                           - 16 -
        2.  The Federal Quarantine will be continued to
    minimize further spread of infestations.  In support
    of regulatory activities, outlying isolated infesta-
    tions and extensions of peripheral areas beyond the
    regulated areas will be treated...  .

    The above program is designed to provide relief to those
people most seriously affected by the imported fire ant.  The
proposed cooperative program would be carried out in those
States where there is an interest and funds are available for
State and/or local participation."

    The U.S. Department of Agriculture clarified this proposal

by answering the following three questions posed by the Com-

mittee:

    "1.  How do we define prime wildlife habitat?

        With respect to the imported fire ant control program,
        prime wildlife habitat is described as Federal  and
        State game refuges, estuary and marsh areas, wooded
        areas bordering streams, rivers, and other bodies of
        water.  Heavily wooded areas are not treated because
        they do not support imported fire ant populations.

    2.  What is the largest contiguous block that would be treated
        under this one treatment concept?

        In open general  fanning areas without streams or heavily
        wooded areas, 50,000 or more contiguous acres may be
        treated.  As a general guideline, if 75 percent or more
        of the area is open, an electronic guidance system is
        employed.   Cutouts such as rivers, heavily forested
        areas, and game refuges are marked on the pilot's map,
        and the recording tape in the aircraft marks these areas
        that are cut out.  When less than 75 percent of the total
        area is to be treated, small aircraft are used due to the
        many cutoffs required.

    3.  What do we plan to do along the peripheral areas?

        Treatments are planned in peripheral areas when
        there is threat of spread to uninfested States
        or to a new area of an infested State.  These
        treatments are to be made in support of the
        Federal  quarantine."

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                        - 17 -
     Economic thresholds,  more  properly  tolerable or  comfort  thres-
holds, have not been established.   For instance, the  current  position
of the USDA states in part:   "Mirex bait will  be applied  aerially  to
those areas where the ant  is  causing trouble,  where the property
owners have expressed concern,  and  where the State and local  govern-
mental agencies have requested  Federal cooperation in a control
program" (USDA 1971c).   Obviously,  these are not objectively  deter-
mined thresholds.  In an eradication or  suppression program the
presence of any imported fire ant may be critical, but in a control
program, treatment thresholds become critical.
     Control of other species of ants is normally obtained by indivi-
dual nest treatment or by  broadcasting Mi rex bait by  hand or  ground
equipment with treated areas  being  from  several  square feet to a
few acres.  An exception would  be treatment of crops  where ants  are
part of an agricultural problem, such as the ant-mealybug complex
on pineapples.  Here the entire crop acreage might  be treated as
well as adjacent unpopulated  dry areas.
     Yellow jacket treatment  with Mi rex  bait  is an  area  treatment
not an individual nest treatment.   However, the bait is  dispensed in
containers visited by the insects  and not  released into the environ-
ment.  The baited areas would not  exceed a square mile or  so.
     B.  Alternative Methods.
         1.  Current insecticidal
             Chlordane, dieldrin,  heptachlor  and related  compounds
are quite effective  for control of  the  imported fire ant,  are con-
venient to  apply  as  granules, and  give  incidental control  of ticks,

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                            - 18 -
 chiggers,  and some other pests  (Blake e_t al_.  1959,  Lofgren  et  al_.
 1961, Lofgren ejt a]_.  1964).   These alternative materials  are inex-
 pensive and available.   Risk of acute toxicity to people  is nil with
 formulations and dosages used.
     These  same insecticides  are also  quite effective  in controlling
 many other ant problems  in outdoor situations.   However,  some  leaf-
 cutting ants are not  readily controlled  by these insecticides  and
 fumigation is required.   Fumigation with either methyl bromide or
 carbon bisulphide or  use of  arsenic and  sulphur dioxide introduces
 an  acute toxicity hazard to  humans.
     Baits  have a unique  advantage  for yellow  jacket control because
 the insects seek it out.   Chlordane is reported to be an  effective
 alternative for Mirex in yellow jacket bait (Grant ejt ^1_. 1968).
 Nest control  with alternative insecticides  is  easy if the nest can
 be  found,  but this  is often  difficult.
     The  choice between Mirex bait  and granular  heptachlor and  re-
 lated  materials  for control  of  the imported fire ant and most  other
 pest species  of ants  in  outdoor situations should be made on the
 basis  of environmental hazards  associated with  the two types of
 uses.  The  effective  dosage  rates  of  these alternative chemicals
 far  exceed  that  used  in  Mirex bait.   Mirex bait was developed
 for  use  in  imported fire  ant programs because of its relatively
 low  environmental hazard.  Adverse  environmental impact of hepta-
chlor, dieldrin  and chlordane would be so much  greater than that
of Mirex bait  that their  use would  be precluded except in very
restricted  situations. Moreover, these alternative insecticides

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                          -  19  -

are currently registered only for application  to  limited  sites
that are not devoted to the  production  of  food and  feed crops.
        2.  Possible future  non-insecticidal
            Research, until  relatively  recent  time,  has emphasized
chemical control  of the imported  fire ant  since this is the  only
practical and effective means of  control.   Possible  alternative
methods to insecticidal control are  currently  receiving increased
attention primarily by the USDA and  also through  its cooperative
research grants with various universities.   Possible alternatives
to chemical control include  biological  control with  parasites,
pathogens and predators, sterilization, insect hormones,  pheromones
and genetic manipulations.  The imported fire  ant is a remarkably
successful species in the southeastern  United  States when compared
to other members of the same genus.  This  phenomenon, not uncommon
with introduced pests, strongly suggests that  the imported fire ant
has escaped from biological  control  agents which  are effective
in South America.
     Control of the imported fire ant  through  the possible use
of parasites, pathogens and  predators  probably offers the best
potential for a successful biological  control  method.  At pre-
sent, there are no known biological  agents that are effective
in limiting the imported fire ant infestations in the U.S.
Recent taxonomic studies  (Buren 1972)  have shown that the most
abundant form of the imported fire ant in the U.S.  (red  form)
is located only in the  interior part of Brazil and  possibly
in sections of Paraguay and Bolivia.  These areas are remote

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                           - 20 -
and not easily accessible.  A parasitic ant associated with
the black forms of the fire ant was located in Argentina and
Uruguay but its usefulness in the control of the imported fire
ant is doubtful.  Natural parasites of the imported fire ant
in the U.S. have been studied for a number of years in an
attempt to find some whose effectiveness could be increased
by either mass rearing or environmental modifications.  This
research is currently being expanded to include pathogens of
the imported fire ant.
     Considerable research has already been conducted on ant
pheromones but more should be done.  Some research has been
initiated on insect hormones but much more remains to be
done before this technique can be properly evaluated as a
possible future control technique.  A more thorough under-
standing of the chemical and physical communication system
of the ant colony could possibly lead to new control
approaches.
     Because research on the genetics of ants in general is highly
complex, insufficient information is available to assess the practi-
cality of genetic manipulations as a means of controlling the imported
fire ant.  For example, attempts to develop basic techniques for
inducing mating or artifically inseminating ants in the laboratory
have not been successful.  These techniques are a prerequisite to
laboratory and field studies.
     Sterilization is probably an impractical  technique for
imported fire ant control for several reasons.  There are no
current methods available for mating or rearing large numbers

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                          -  21  -

of males in the laboratory.   Mating  of  the  imported  fire  ant
occurs during flights  throughout  the summer months.   These
flights usually are localized and not readily  predictable.
Consequently, proper timing  of sterile  male release  to  coin-
cide with mating flights would be extremely difficult.  The
long lifetime of imported fire ant colonies would  also  com-
plicate the procedure because releases  of sterile  males would
have to be made over a long  period of time. Applications of
chemical sten'1 ants directly in the field with a bait would
also be impractical because  they are not species specific,
therefore, other invertebrates and vertebrates would be ex-
posed to the sterilant.
    It should be emphasized that at the present time there
are no biological control measures that could  be successfully
employed in the near future for the control of the imported
fire ant.  Increased research on these  non-chemical  control
measures is underway and even further expansion is encouraged.
One must be tempered, however, by the reality that a future
successful biological agent might also pose significant
potential hazards to man and his environment.

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                             - 22 -
III.   BENEFIT-RISK EVALUATION
      The nuisance effects, public health  importance  and  indirect
  effects on agriculture of the imported fire ant are of  such mag-
  nitude that effective control measures must be made available
  for treatment of areas where the need for control exists.  The
  hazard to human life alone that is  posed by hypersensitivity of
  a small percentage of the population due to the sting of this pest
  requires the availability of effective control  measures.  Con-
  trol  of the pest in home lawns, parks, playgrounds, schoolyards
  and other recreational areas is imperative if  use of these areas
  is  not to be denied to many individuals.   It is generally agreed
  that the imported fire ant is a species  that the United States
  would be much better off without.
       Recent findings indicated that Mi rex residues  have been found
  in  varying concentrations in a wide variety of organisms and natural
  food  chains (Markin 1970, Duggan 1971, USDI 1971, Wilson, N.L. 1971),
  Evidence of delayed toxic effects on some species of crustaceans
  (Lowe et_a\_.  1971,  Ludke eŁ aj_.  1971)  and general paucity of infor-
  mation on  ecological  effects of large-scale application of Mi rex
  call  for reduction  in use of this chemical  until additional data
  are available on  the significance of this information.
       Consideration  of the environmental  impact  of Mirex applications
  plus  the technical  and operational  difficulties  encountered in
  treating  large  areas  have caused the USDA to reject an eradication

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                          - 23 -
program for the entire  infested area of the Unites States.  The
1971  USDA program using Mirex bait for the control of the imported
fire ant avoided treating areas such as heavy woodland, water,
estuaries and other poor ant habitats (USDA 1971c).  However,
the proposed Federal-State  Cooperative Control program for
1972 would still involve the treatment of very large areas
other than estuarine, heavily forested areas and State and
Federal game refuges.   Lack of  information on such points
as the metabolic fate of Mirex  in plants and animals and the eco-
logical effects of accumulation of substantial residues of the
chemical by non-target  species  does  not permit a final, unequivocal
evaluation of the benefit-risk  ratio  involved in  its continued use.
It seems worthwhile, therefore, to evaluate the available options
for future control of the  imported fire ant in the United States
on the basis of the information that is available.
     Clearly, some level of control  of the pest must be provided
and use of Mirex bait can  provide control at  far  less  demonstrated
adverse effect on the environment  than any of the other available
insecticides.
     Treatment of the total infested area with  three  properly timed
applications of Mirex bait at the  rate of  1.25  pounds  of  bait per
acre per application (a total  of  3.75 pounds  of bait per  acre con-
taining only 5.1 grams  of Mirex)  would  be by far the most effective
method for suppressing  imported fire ant populations.   However, it
would  involve treatment of large acreages where the presence of the
imported fire ant does not constitute a problem.  The environ-

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                           - 24 -

 mental  impact of such treatment is  too  poorly understood and the
 expense too great to justify a program  of such magnitude.  The
 USDA is to be commended for changing  its  position and instituting
 programs involving control  on more  limited acreage.
      Large-scale treatments for suppression and prevention of
 additional spread would be  much more  effective for control of
 the ant than treatment of limited areas.   Treatment by this
 method  would be  by skilled, experienced personnel with sophisti-
 cated equipment  so that the amount  of insecticide applied per
 unit area would  be minimal.   The problem  of re-infestation from
 adjacent untreated areas  would be reduced depending upon the size
 of  the  area treated.   Further spread  of the pest would be slowed.
 The disadvantages of this method are  the  same, on a reduced scale,
 as  for  treatment of the total  area  infested in an attempt to
 achieve eradication.
      Treatment according  to  the proposal  described in the USDA
 position  on  imported  fire ant control would  result in adequate
 control  of the pest and in  a  substantial  reduction in further pol-
 lution  of especially  sensitive areas with  Mirex.  However, the
 method  of control  described would still result in the treatment
 of  large  areas of rangeland,  unimproved pastures, land in soil
 bank and  conservation reserve, and cropland where the imported
 fire ant may be abundant but  does not pose a problem to people
or interfere with agricultural operations.   If the USDA were to
amend its position and  consider such areas the same as heavily
forested areas, estuarine areas, and State and Federal game refuges,

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                           -  25 -
the program would then  be  one aimed at controlling the species  in
all areas where it is a pest  rather than attempting to suppress
populations over large  areas.
     Treatment of individual  properties is the least effective
method and would require up to one application per year because of
the high rate of reinfestation from untreated areas.  This method
of treatment would allow the  ant to infest the total area to which
it is adapted in a relatively short time.  It would result in a
considerable amount of  overtreatment  per unit area because of the
lack of proper equipment for  applying the bait and the lack of
training and skill in use  of  the bait by the property owner.  The
advantages of this method  would be to confine treatment to those
areas only where the imported fire ant is a problem and to place
the cost of controlling the pest on the  individual  involved.   Ef-
fectiveness and safety  of  individual  property treatments  could  be
enhanced by an increased educational  program through  the  responsible
state and local agricultural  agencies.   Because  of emphasis  on
large-scale suppression programs  in  the  past, proper  instructions
at the local level for  small-scale  treatment may not  have re-
ceived adequate attention.
     Treatment by trained  personnel  in  an  organized program would
avoid the problems of overtreatment and direct  exposure of un-
trained persons to the Mi rex bait.    If such treatments were
limited to specific locations where there was  a demonstrated
need, environmental disturbance would probably be less than
from treatment by individuals and control  would be much better.

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                             - 26 -

     It would appear that a method of control combining the best
features of the USDA proposal with treatment confined to the mini-
mum area of demonstrated need would have the most favorable benefit-
risk ratio.
     Benefits from use of Mi rex bait to control the western harvester
ant, the Texas leaf-cutting ant, the ant-mealybug complex on pineapple
and yellow jackets far outweight the possible risks.
     In summary, the Committee is unanimous in concluding that the
benefits from the continued use of Mi rex for the control of the im-
ported fire ant and certain other pest soecies of ants and yellow
jackets outweight considerably the possible risks, assuming that the
recommendations in this report are implemented.  The benefits to
man and his environment are clear, but the risks are largely unknown
at the present time.

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                         - 27 -
IV.  RESIDUE ESTIMATES

     A.  Soil (Including Sediments,  etc.)
         Following an application  of Mirex  bait (1.7  grams  per acre)
the theoretical  amount of Mirex in a standard  3-inch  soil  sample
would be approximately 4 ppb.   Mirex residues  in  soils  from open
pastures following normal Mirex aerial  treatments,  have generally
ranged from 0.1  to 10 ppb (Collins and  Davis  1971,  Markin  et al.
1971 a).  Mud samples taken from pond bottoms  and  drainage  ditches
have yielded Mirex residues in about the same  range as  has  been
reported for soils (Collins and Davis 1971).   Sediment  samples
from freshwater ponds pretreated with Mirex contained residues
ranging from 0.01 to 21 ppb (Markin eŁ al_.  1971 a).   An  exception
to these rather low concentrations would be the analysis of mud
from four ponds pretreated with 0.1  ppm Mirex which resulted in
reported residues from 0.09 ppm, 7 days after treatment to as  high
as 32.7 ppm in one pond 112 days after application (Van Valin
et^ a\_. 1968).  From these studies, it was concluded that residues
of Mirex are very stable in mud, water and aquatic vegetation.
     B.  Water
         Mirex is essentially  insoluble in water,  therefore,  its
residues reported in fresh or  sea water were  probably  adsorbed
on particulate matter  suspended in  the water.  Most  analyses  of

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                          - 28 -

both fresh and salt water samples indicated Mi rex residues at
below the limit of detection  (0.01 ppb).  Residues of 0.5 to
1.0 ppb were found in water samples taken from ponds pretreated
with 0.1 and 1.0 ppm Mirex, respectively (Van Valin et_ a\_. 1968,
Collins and Davis 1971, Duke  1971, Markin ejt al_. 1971a, Markin
1971b, Maxwell et al.. 1971).
     C.  Natural Food Chains
         Following a single application, most of the Mirex bait
on the ground is promptly picked up by the foraging fire ants and
carried into their mound for  transfer to other ants in the colony.
The ants do not consume all of the Mirex, some remains inside the
discarded grit and is returned to the soil surface.  Among ter-
restrial communities, unused  Mirex grits may be consumed directly
by various insect scavengers  (e.g., certain ants, crickets, wood
roaches, ground beetles).  These scavengers are in turn preyed on
by certain spiders, reptiles, amphibians and insectivorous birds
and mammals.  The toxicant may be leached from the bait, washed
or occasionally blown directly into aquatic habitats or carried
there via food chains by immigrating organisms (Ludke et al.
1971, Markin 1971b, USDI 1971).  Mirex bait is apparently
resistant to leaching in seawater (Lowe e_t aj_. 1971)  but
is easily leached out by fresh water (Ludke e_t al_. 1971).
Preliminary information indicates that Mirex is not readily
degraded by biological systems and organisms.  Since Mirex is

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                           -  29 -
essentially insoluble in water,  it probably becomes  adsorbed to
organic detritus and to sediments  (Odum je_t a\_.  1969, Maxwell
ejt al_. 1971).   Species of freshwater and estuarine communities
(e.g., crayfish, river shrimps,  penaeid shrimps, fiddler crabs
and blue, crabs) are general  scavengers  and accumulate Mi rex by
consuming detritus and sediments (Darnell  1958, Miller 1961,
Tagatz 1968).   Under laboratory  conditions some of these soecies
appear to assimilate Mirex as efficiently as would be expected
of their natural food sources (calculated from data in Lowe
e_t a]_. 1971).   The levels of Mirex residues that are lethal to
certain aquatic crustaceans are  far below those for fish,
amphibian, avian and mammalian species  (Baker 1964, Dewitt
et al_. 1964, Naber and Ware 1965,  Tucker and Crabtree 1970,
Allied Chemical Exhibit No. 21,  1971, Lowe et al_. 1971,
Ludke et^ jil_. 1971, USDI 1971).  These curstaceans are eaten by
fishes and by birds and mammals  that consume both crustaceans
and fishes.
     Certain aquatic algae have been found to contain relatively
high values of Mirex compared to residues  in surrounding bottom
sediment and water  (Markin et^ al_.  1971a).  Mirex  residues  can usually
be detected in most fish taken from waters near treated areas,
including edible species such as bass, bream,  catfish and
mullet.  Bass and bream usually contain less than 0.5 ppm  in
their edible portions.  Wild  catfish and  mullet have been
found to contain residues as  high as 1.0  to  5.0 ppm (Baetcke
et al. 1971, Markin  1971b).   Catfish residues, in general,

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                          - 30 -

 have  been  found  to  decrease  rapidly  following  a  period of time
 since Mirex was  applied,  but wild  freshwater catfish have been
 reported to contain up  to 0.65 ppm Mirex  six months after
 treatment  (Collins  and  Davis 1971).   Commercially  raised catfish
 from  artificial  ponds in  areas that  had received a countywide
 coverage of Mirex bait  contained no  Mirex in 50  samples
 taken from 25  separate  pond  sites  (Hawthorne jB_t  a]_. 1971).
      Mirex residues have  been detected in a significant per-
 centage of marine-estuarine  animals  monitored  in treated areas
 including  oysters,  whelks, brachyuran and anomuran crabs and
 shrimps.   Residue levels  in  these  marine  species are usually
 less  than  1.0  ppm.   Organisms that are believed  to feed directly
 on Mirex bait  and the predators of these  organisms appear to show
 a rapid loss of  Mirex residues 12  months  after the original
 treatment.   Most of these  invertebrates exhibited  a 90% or greater
 decrease in  Mirex residues during  this period.   However, a slower
 decrease was noted  for  some  vertebrates (Allied  Chemical Exhibit
 21, 1971b, Markin 1971b).
      Mirex residue  levels are extremely low (<0.05 ppm) or
 nondetectable  in  terrestrial  plants  and in phytophagous animals
 selected from  Mirex-treated  areas.   Most  terrestrial inverte-
 brates have been  found  to contain  less than 0.1  ppm but general
scavengers such  as  crickets and wood roaches may consume Mirex
bait directly and have  been reported to contain  Mirex residues

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                          -  31  -
ranging from 10 to 30 ppm.   However, within a year after  treat-
ment, formerly depleted species  are still present but  contain
Mi rex residues that have decreased considerably.  Predaceous
arthropods, such as spiders, have been  found to  contain higher
residues than general invertebrate populations.  Spiders  may
contain in excess of 1.0 ppm Mirex one  year after treatment.
Predaceous amphibians and reptiles that have been monitored
usually contain relatively high  levels  of Mirex  (1.0 to 5.0 ppm).
Several toads have been found with residues of 10 ppm  or  higher.
     Birds, as a group, appear to contain relatively high levels
of Mirex.  Most insect-eating birds collected in or near  a treated
area contained Mirex residues in excess of  1.0 ppm, with  a few
having as high as 10.0 ppm or even higher.  The  only wild bird
egg samples that have been analyzed are from  cattle egrets,  five
of which averaged approximately  13 ppm.  It is not  known  what
adverse effect, if any, residues of this level in  eggs might have
on reproduction.  Much higher levels  fed to chickens,  mallard ducks
and bobwhite quail resulted in no  apparent  adverse  reproductive
effects  (Naber and Ware 1965, Heath  1971).   Mirex is  a very stable
compound chemically and residues in  certain species are remarkably
persistent.  For example, adult snowy egrets contained up to 0.64 ppm
and nestlings were analyzed to have  up to 3.5 ppm Mirex one year after
treatment.  Insectivorous land birds  have been  reported  to contain
from 0.22 to 9.1 ppm Mirex six to twelve months after treatment
(Markin  1971 a).

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                           - 32 -

     Mi rex  residues can be detected in most small mammals following
bait treatment, but are quite variable and apoarently depend upon
the feeding habits of the species.  Most mammals contain less than
1.0 ppm Mirex.  An apparent exception is the shrew, which is an
insect  feeder.  Two specimens were found to have residues of 6.6
and 41.3 ppm.   In one study involving a large number of monitored
samples, most raccoons were found to contain residues well below
1.0 ppm, but a  small percentage was observed to have values in the
range of 2  to 5 ppm.  Raccoons have been noted to contain as high
as 1 ppm Mirex  one year after final treatment (USDI 1971).
     Mirex  residue levels, as well as rates and direction of
transfer in the natural food chain, are difficult to interpret
or predict  for  several reasons:  (1)  Numerous organisms (e.g.,
omnivores,  detritus feeders, filter feeders) cannot be classified
into traditional trophic levels, their feeding habits change from
larval  stage(s) to adult and many are opportunistic feeders as
adults  (Bakus 1969).  (2) Certain species may move considerable
distances (e.g., marsh birds, raccoons, blue crabs) and carry
residues with them.  (3) Tidal flushing, storms and hurricanes
can suspend sediments in fresh water lotic and lentic systems
and in estuaries.  Spring turnover in lakes (upmixing of nutrients
from bottom sediments) may also cause resusoension of Mi rex-
bearing sediments.  (4) Mirex residues measured in the past may

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                           - 33 -
be partially confused  with  the  polychlorinated biphenyl, Aroclor
1260, and/or Dechlorane, which  is chemically identical to Mirex.
     From the data currently  available,  it  is evident that Mirex
is reaching some non-target organisms as a  result of previous
large-scale application for the control  of  the imported fire
ant.  It is also apparent  that  Mirex can be transferred through
simple two-level food  chains  (Lowe Łt al_. 1971) as well as further
up certain food chains. Current and future restrictions on
applications of Mirex  to sensitive areas plus the possible reduc-
tion in dosage rates should result in a  significant decrease  in
future Mirex residues  at various levels  of  natural food chains.
     D.  Edible Food
         1.  Plant
             In considering all types of biological  samples  for
Mirex residues, the smallest  amounts  appear to  be  found  in  plants
(Markin et. aj_. 1971a).  Earlier work  by Allied  Chemical  Corporation
indicated that no Mirex residues could  be found in a large selection
of field and vegetable crops  (Allied  Chemical  Corporation 1971a).
There is some indication that extremely low levels of Mirex may
be translocated from the soil into growing plants such as
bahiagrass roots and foliage.  These were reported to contain
from 0.3 to 17 ppb Mirex (Markin et al_. 1971a).

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                           - 34 -

         2.  Animal
            Milk from cows fed 3 weeks on a daily ration with
 0.01  ppm Mirex contained  no detectable Mirex, whereas from 0.02
 to  0.08  ppm was detected  in the raw whole milk from cows fed 3
 weeks on a diet containing 1.0 ppm Mirex (USDA 1971b).  Milk
 from  cows that had grazed in previously treated areas contained
 from  2 to 8 ppb.  An average of 0.01 ppm Mirex was reported in
 the fat  of raw milk selected from 12 cows grazed in previously
 treated  areas (Baetcke ejt al_. 1971).  No detectable Mirex residues
 (sensitivity 0.3 ppb) were found in 60 milk samples selected from
 5 different states involved in the use of Mirex for fire ant
 control.
    Fat  samples taken from 63 of 75 beef cattle raised in areas
 in  Mississippi and Georgia, where Mirex has been used to control
 the imported fire ant, contained very low levels of Mirex (from
 0.001 to 0.126 ppm).  In general, the Mirex residues detected in
 these samples comprised a very small fraction of the total organo-
 chlorine residue detected (Ford et al_. 1971).  Mirex residues
 ranging  from 0.05 to 1.6 ppm were found in adipose tissues of
 deer, quail, wild turkey and beef cattle (Baetcke e_t al_. 1971).
         3.  Seafood
            A recent sampling by the Food and Drug Administration
 of commercial  fishes in Louisiana waters resulted in the detection
of Mirex residues in 10 out of 21 total samples.  These residues
 ranged from 0.01  to 0.18 ppm on an edible portion basis.  The
FDA has not encountered any Mirex residues in other foods

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                           -  35 -
tested, including its Total  Diet Studies  (Duggan  1971).  Mirex
residues can usually be detected in  most  fish  from treated areas
including edible species such as bass,  bream and  catfish.  Usually
less than 0.5 ppm Mirex is  found in  bass  and bream.   Catfish  and
mullet have been found to contain 1  to  2  pom Mirex immediatelv
following treatment, although subsequent  monitoring  indicated that
within 24 to 48 hours the residues drooped  to  below  the  0.5 pom
level (Markin e_t a\_. 1971a).  This raoid  decrease in Mirex residues,
suggests that these bottom-feeding fish had ingested individual
Mirex grits just prior to the time of analysis.
     In marine estuaries, marshes and bays  which  have been treated,
Mirex residues have been found in almost  all marine  animals
including oysters, shrimps, crabs, bottom-feeding and swimminq
fishes.  Three days after a third aerial  anolication of 0.3%  Mirex
bait to an entire area, Mirex residues of from 0.32  to 2.59  pnm
were detected in oysters, shrimps, crabs, catfish and mullet
(Markin 1970).
     The buildup of Mirex residues in uncaqed channel catfish
has been reported  (Collins and Davis 1971), whereas  caged catfish
acquired almost no Mirex.  One plausible explanation is that uncaged
fish obtain their Mirex through  the food chain, whereas the  caged
fish did not have access to  the  natural energy sources.  Buildup
of Mirex in uncaged  channel  catfish increased from  no residues
detected 10 days after  an aerial  application  (0.3%  bait) to  the

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                           -  36  -
pond and surrounding drainage area, to 0.65 ppm Mirex six months
after application.  On the other hand, only 0.03 ppm was detected
in the caged fish six months after application (Collins and Davis
1971).
    No detectable Mirex residues were found in 50 samples of
commercially raised catfish  in Mississippi (limit of sensitivity
0.01 ppm)  (Hawthorne e_t al_.  1971).  The lack of detectable Mirex
residues in this study would indicate that the claim of wide-
spread contamination by Mirex appears to be unfounded.  It is also
doubtful that Mirex residues could be responsible for the deformation
or death of fishes (Hawthorne e_t al_. 1971).
    The edible portion of  bluegill fish was found to contain
from 0.12  to 0.39 ppm Mirex, whereas largemouth bass contained
0.44 to 0.76 ppm in their  edible tissue (USDA 1971a).  Catfish
caught in  the mouth of two rivers in Georgia contained 0.008
to 0.030 ppm Mirex (Curley 1971).  Oysters from Savannah, Georgia,
contained  from 0.004 to 0.036 ppm Mirex, whereas oysters from the
Gulf Breeze, Florida and Charleston, South Carolina areas contained
no detectable Mirex.
    Very low Mirex residues were found in a variety of marine
life from  the Savannah, Georgia area where Mirex bait had been
applied several times (Markin et al_. 1971c).  The monitoring
program, in general, failed to indicate that detectable Mirex
residues were accumulating in marine life throughout the remainder

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                           - 37 -
of the southeastern United States, even though Mirex residues could
have reached the sampled marine environment via streams and rivers
draining previously treated areas.
     In general, it would appear that Mirex residue concentrations
currently found in soils, water, vegetables and field crops as well
as in meat and milk selected from areas previously treated with
Mirex, are so low as to be insignificant as far as any possible
hazard to humans.  If there is  any possible hazard in certain
seafoods, it would appear to be restricted to several bottom-
feeding fishes in areas that had recently been treated several
times with Mirex.
     E.  Man
         Very little data are available on possible residues of
Mirex in human beings as a result of treatments for the control
of the imported fire ant.  Only since April 15, 1971, have the
contracting laboratories, Human Monitoring Survey  of  the  States
Services Branch of the Division of Pesticide  Community  Studies
in the Environmental Protection Agency,  been  looking  at possible
residues of Mirex in the human samples which  they  collect and
analyze.  Prior to that time, analyses would  not have revealed  the
presence of Mirex, if indeed any were present.   Since that time,
contract laboratories have reported  the  results  of more than 700
adipose tissue analyses.  These were collected by  55 pathologists
in 23 states, including Macon and Atlanta, Georgia; and Pensacola,

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                          - 38 -
 Florida; areas where Mirex has been used for the control of the
 imported fire ant.  In only 12 of these samples have peaks been
 observed in  the area where Mirex elutes on the gas chromatograph.
 Two  of  these were in Louisville, Kentucky; one in Little Rock,
 Arkansas; one in Atlanta, Georgia; two in Macon, Georgia; and
 three in Togus, Maine.  The highest value observed was 1.03
 ppm  in  the adipose tissue of one of the specimens from Macon,
 Georgia  (Yobs 1971).  It must be emphasized that identification
 of Mirex by  gas chromatography in these samples is tentative at
 best.   Considerable doubt is placed on this identification by
 the  presence of significant concentrations of polychlorinated
 biphenyls (PCBs), several of which are known to elute in the
 same area on the gas chromatograph.  Confirmatory identification
 of these samples is currently underway but the final results are
 not  available.  Further doubt, on the validity of these analytical
 identifications, is cast by the consideration that half of the
 12 samples were reported from three cities which are a considerable
 distance from areas previously treated with Mirex for the control  of
 the  imported fire ant.  It should also be noted that the same
 chemical substance has been widely used as a fire retardant under
 the  trade name Dechlorane.  There is the possibility that these
 human tissue levels, suspected to be Mirex, may be due to exposure
 to Dechlorane.  Actually, it would be extremely surprising if
Mirex were found in human tissue at this time, considering the
 relatively modest quantites of the insecticide used for the control
of the imported fire ant and the fact that very little or no
Mirex has been found in the human food chain.

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                           -  39  -

     F.  Projections of Expected Environmental  Load
         Trends in the accretion,  if  any,  of  Mi rex in  the
environment cannot be projected  with  any degree of confidence
at the present time.  Additional comprehensive  studies need  to
be conducted in order to effectively  evaluate the result of  past
and current applications of Mirex.  As  in  the case of  most other
similar persistent pesticides found in  the environment, the  routes
of movement of Mirex have not been well documented.  Improved
sampling methods are essential  for valid censusing of  key natural
populations of terrestrial  and aquatic  organisms.  Current data
from monitoring and total diet studies  by  the Food and Drug
Administration indicate that very little or no  Mirex residues
were found in man's food supplies (Duggan  1971).
     Many of the key environmental species in the  areas treated
by Mirex for the imported fire ant have been monitored in  the
past.  These monitoring studies are continuously being improved
for the future projections of the environmental impact by the
continued use of Mirex.  Currently available monitoring information
clearly indicates that residues of Mirex are appearing in most
invertebrate and vertebrate animals that are in close  proximity
to treated areas.  Some  invertebrate species that may  feed
directly on Mirex bait  in treated areas suffer  significant
population declines for  a period of time  following  treatment.
However, after a year of no  further Mirex treatment,  these

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                            - 40 -
invertebrate populations appear to recover in the previously
treated areas.  There is no available information to indicate
that any vertebrate populations have been adversely affected
despite rather high Mirex residues in certain terrestrial  animals
such as toads, lizards and insect-eating birds.  Vertebrates
exposed to Mirex in the field generally contain considerably
less of the chemical than that required to affect laboratory
animals in controlled studies.
     Most monitoring studies in the past few years have been
conducted in areas that had been subjected to eradication tests,
where three closely spaced applications of Mirex were applied
more or less indiscriminately to all parts of the environment
including estuaries, marshes and other sensitive areas.
     Current and future control programs will attempt to avoid all
sensitive areas in the environment and will involve only one appli-
cation per year versus the previous three-application treatment.
Continuous improvement in the Mirex-latex bait should assure
that less Mirex will be available to non-target organisms.
There is also a very good possibility that a lower dosage level
of active toxicant will  be utilized to control the imported fire
ant.  It is projected, therefore, that future Mirex residues
encountered in the treated areas of the environment should
show a continuous decline.

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                          - 41  -

     Since Mirex is a very persistent pesticide and  apparently
is not readily metabolized in nature, its residues,  however
minute, are expected to remain in the environment for the fore-
seeable future.  However, because of the extremely small  quantity
used and the restrictions that have been and will  be enforced,
the environmental load of Mirex is not considered to be alarming
in comparision with other persistent pesticides currently in the
environment.

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                           - 42 -
 V.   TOXICOLOGY

     A.   Acute and  Subacute Toxicit.v
        Very little data are available on the acute and subacute
 toxicity of Mirex  to  experimental animals and none on its chronic
 toxicity.   One  single study reports that Mirex has an acute LD5Q
 of  365  mg/kg in female Sherman rats (Gaines and Kimbrough 1970).
 This figure is  somewhat lower than that reported previously in
 Sherman strain  rats which was 740 mg/kg in males and 600 mg/kg in
 females (Gaines 1969).  In addition, the chronicity factor of
 Mirex was  determined  by the technique described by Hayes (1969).
 The chronicity  factor is defined as the single dose LD5Q in mg/kg
 divided by the  90-dose LD5Q in mg/kg per day.  The 90-dose oral
 LD^Q of Mirex was  found to be 6 mg/kg per day giving a chronicity
 factor  of  60.8  (Gaines and Kimbrough 1970).  This chronicity factor
 is  by far  the highest observed of any pesticide to date.  It may be
 compared  to  a chronicity factor of less than 5.6 for DDT and of
 12.8 for Dieldrin,  both of which are considered to be highly per-
 sistent compounds.  Male and female rats were also fed Mirex at 0,
 1,  5 and 25  ppm in  the diet (10 animals per group) for 166 days.
 The  livers of these animals were examined by light microscopy in
 both males and  females.  At the 5 ppm feeding level, approximately
 one-half of  the rats  developed significant, but minimal, pathologic
 changes.  They  exhibited slightly enlarged liver cells, vacuolated
 cytoplasm and occasional  inclusions.   At the 25 ppm feeding level,
most  of the  rats had  definitely enlarged liver cells which were
multinucleated with smooth or vacuolated cytoplasm, which showed

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                          -  43  -
cytoplasmlc inclusions  and  biliary stasis.  Examination of these
livers by electron microscopy  showed an increase in smooth
endoplasmlc reticulum,  free ribosomes, lipid vacuoles, myelin
figures and osmophilie-dense bodies.
    In other subacute toxicity experiments, M1rex was fed to rats
in the diet for 13 weeks  at concentrations of 0, 5, 20, 80, 320
and 1280 ppm (Larson 1968). Deaths were observed at the highest
dose level and growth suppression at 320 ppm.  Enlarged livers and
pathologic changes including swelling and vacuolatlon of liver
cells were found at 80  ppm. The same investigator also fed Mi rex
to dogs daily at concentrations of 0, 4, 20 and 100 ppm.  Deaths
were observed at the 100  ppm feeding level, but at 20 ppm no effects
were observed.  Further studies demonstrated that Mirex was absorbed
through skin of rabbits producing toxic effects.  Two of 10 rabbits
died when a 5% Mirex 1n corn oil solution was applied at a rate of
10 mill1l1ters per kilo.
    B.  Reproductive Effects In Mammals
        Very few experiments have been conducted on  the  reproductive
effects of Mirex on experimental mammals.   Female  Sherman  rats  were
fed 25 ppm of Mirex in  the diet  for  45 and  102  days  (Gaines  and Kim-
brough 1970).  The males to which  these  females were bred  were exposed
to Mirex  in their diet only during  the seven-day breeding  period.  In
these animals, significantly fewer  offspring were born alive and
fewer survived to weaning  than the control  rats.  Furthermore, 33
to 46% of the offspring of  these breedings developed cataracts,
whereas none were  observed  1n the control animals.  At the

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                             44 -
 5  ppm  feeding  level, however, no reproductive effects were observed.
 Further  experiments indicated that the pathologic effects of Mirex
 on the eyes  of newborn  rats  is primarily due to the ingestion of
 Mirex  during the suckling period.
     Another  study  involved large scale feeding of two strains of
 mice to  measure the effect of 5 ppm Mirex fed in the daily diet
 (Ware  and  Good 1967).   With  one strain, Mirex produced a signifi-
 cant increase  in parent mortality, whereas parent mortality was
 not affected in the other strain of mice.  In both strains of
 mice,  the  Mirex diet resulted in reduced litter size and number
 of offspring produced per day.
     C.   Carcinogenicity and  Mutagenicity
         Only one experimental evaluation has been reported on the
 possible carcinogenicity of  Mirex (Innes eŁ ^1_. 1969) but none on
 its  mutagenicity.  Mirex was selected as one of the pesticides
 to  be  tested at the Bionetics Research Laboratory in a unique
 massive  screening  program for tumorigenicity.  In this study, a
 total  of 130 compounds  was evaluated of which 104 were pesticides.
 Seven  known  carcinogens were included as positive controls as well
 as  19  industrial chemicals.  The compounds to be studied were selected
 on  the basis of widespread usage, suggestive chemical structure and
 evidence of  toxicity described in the literature suggesting a potential
 hazard to man.
     Each compound was tested by two routes of administration, oral
and subcutaneous,  in two hybrid strains of mice.  Eighteen male and
 18 female mice  of  each  strain were utilized for each test procedure.

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                           - 45 -
In the subcutaneous test, Mi rex was  administered  in  a maximally
tolerated single dose of 1000 mg/kg.   In  the  oral  experiments, a
dose of 10 mg/kg per day was given from the 7th to the  28th
day.  The mice were then fed for the duration of  the experiments
at the level of 26 ppm in the diet.   All  mice in  both experiments
were sacrificed approximately 18 months after the beginning  of the
experiment.
    In the subcutaneous experiment,  almost all of the 72 mice sur-
vived the 18-month test period to sacrifice.   The primary tumors
observed in these animals were reticulum  cell sarcomas  Type  I (10/72),
pulmonary adenomas (3/72) and hepatomas (7/72).   Of  the 72 mice  to
which Mi rex had been administered, a total of 20  were found  to bear
tumors.  The incidence of mice developing reticulum  cell sarcomas
and hepatomas as well as the total tumor-bearing  mice  fed Mi rex
was significantly different from the controls at  the 99% level.
    In the oral administration tests, all mice died  prior to the
completion of the experiment at 18 months.  Twenty-nine of 72 mice
developed hepatomas, compared to 14 of 338 control mice (99% signi-
ficance).
    The significance of  this bioassay  is enhanced by the demon-
stration that the seven  known carcinogens were found clearly to be
tumorigenic by this testing procedure.  Mirex by  oral  admini-
stration in this bioassay procedure was judged to have a  relative
risk of 0.945 by comparison with  an average  of the  seven  known car-
cinogens.  This would mean that by  this bioassay procedure  Mirex  is
very close  to being equal in  carcinogenic potency to the seven  known
carci nogenic compounds.

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                           - 46 -
      From the  results  of  this  testinq  procedure in which Mirex,
 fed  at  relatively  high dosaqes, was  found  to be tumorigenic in
 two  strains  of mice  of both  sexes, it  was  concluded that this
 substance is tumorigenic  for this soecies.  These results, however,
 could certainly not  be translated to man.  No satisfactory testing
 procedure for  orally ingested  carcinoqens  to which man may be ex-
 posed in  his diet  has  been developed.   In  lieu of this, reliance
 must be placed on  the  concept  that man is  but one species of
 animal  and that testing must be carried out in as many species
 as possible.   If a consistent  result is obtained in a number of
 species,  this  result probably  has significance for man.  Therefore,
 it is urgently desired that  Mirex be tested for carcinogenicity in
 other species  so that  conclusions about its possible carcinogenic
 potential  for  humans can  be  reached.
      D.   Toxicity  to Aquatic Life
          Exposure  to Mirex under laboratory conditions affects certain
 estuarine crustaceans  by  causing irritability, loss of equilibrium,
 paralysis  and  even death.  The most  susceotible soecies were found
 to be juvenile  brown and  pink  shrimp and juvenile blue crabs, whereas
 pinfish apparently were not  affected by the Mirex treatments (Lowe
 et_ al_.  1971).   The toxicity  of Mirex bait  is directly related to
 temperature, that  is,  there  is a greater manifestation of lethal
 effects at higher  temperatures (McKenzie 1970).  Studies on juve-
 nile brown shrimp verify  the phenomenon of delayed toxicity
exhibited by Mirex which  has been previously reported in several
other aquatic and terrestrial species  (Mahood e_t aj_. 1970,

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                         - 47 -
Markin 1970, Ludke ejt al_. 1971, Markin et al_.  1971a, and W.  E.  Martin,
written communication 1971).
     Under controlled laboratory conditions, decreases in popu-
lation density were observed to occur in ciliate protozoa when
placed in a suspension of 1  ppb Mirex (Duke 1971).   Two species
of freshwater crayfish (Procambarus blandingi  and P_. hayi) were
found to be extremely sensitive to Mirex under laboratory con-
ditions (Ludke et^al_. 1971).   An earlier study of adults of another
species of crayfish  (P_. clarki) indicated that they were not
sensitive to Mirex (Muncy and Oliver 1963).  This was confirmed
by a recent study of P_. clarki in south-central Louisiana which
indicates that Mirex is not an important threat to the crayfish
industry (Markin ert  al_. 1971b).  Such discrepancies in results
between laboratory experiments and field studies emphasize the
species specific effects of Mirex on animal populations.
     Mortality of adult crabs and shrimps was observed in a
small pond on Cat Island after exposure to higher than normal
dosages of Mirex  (Markin 1971b).  Similar mortalities were not
noted in other ponds or a bay on the same island.
     In 1969 a cooperative USDA and USDI experiment was  initiated
at Charleston, South Carolina to study  the  effects  of Mirex  on
crab and shrimp populations  (Duke  1971).  Mirex was applied  to
a 2-square mile area of marshland  and estuaries.   Samples of
crabs and shrimps within the  treated  areas  were collected at

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                           - 48 -

biweekly intervals during the three-bait application and for
10 weeks afterwards and analyzed for Mirex residues.  Mirex
residues in crabs averaged 0.02 ppm during the experiment.
There was  no observed mortality and crabs and shrimps could
be caught  at all times following the Mirex bait applications.
    Paralysis or death of fiddler crabs may occur within one
to several weeks following the ingestion of a single Mirex
bait granule under controlled laboratory conditions (Lowe
ejt al_. 1971).  However, in the Cat Island experiment (Markin
1971b), fiddler crab populations were observed to be high at
the time of the third Mirex application.  No population decline
was observed at varying lengths of time following the last of
the three  applications.
    It has been reported that wild catfish in Mirex-treated areas
may feed directly upon the bait or obtain Mirex through the food
chain.  Commercial catfish in 25 ponds in Mississippi from areas
where Mirex was used contained no detectable Mirex at 0.01 ppm
limit of sensitivity of the method (Hawthorne et a]_. 1971).
Another study (Maxwell 1971) reported no adverse effects or
mortality  to catfish fed 10 and 15 ppm Mirex in their diet for
6 weeks.
    There  is little evidence to corroborate the lethal  effects
of Mirex found under controlled laboratory conditions with
those in natural aquatic communities.  Based on all available
monitoring data, there is also little evidence at this time of
any serious hazards to populations of fish and crustaceans as a

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                         -  49  -

result of standard Mi rex bait  applications for the control of
the imported fire ant.   However,  previous sampling methods
usually have not been adequate for valid censusing of these
natural populations.   Additional  and  much more comprehensive
studies should be conducted on population densities of Mirex-
sensitive aquatic organisms in their  natural habitats.
     E.  Toxicity to  Wildlife
         Although a decline in populations attributed to Mi rex
has been reported for crickets, oil-loving ants,  and ground
beetles (Wilson, N.L.  1971), there is no evidence available to
indicate that these populations are permanently affected.  A number
of 1050 values nas been established for Mi rex and these values
indicated that this pesticide  is  rather low  in its toxicity to
rats and a few species  of adult birds (Larson 1968, Gaines 1969,
Gaines and Kimbrough  1970,  Baetcke e_t a^. 1971).
     Despite the fact that significant Mi rex residues are  being
found in numerous key environmental species  being monitored  in
areas previously treated with  multiple aerial applications,
there is no evidence  to date of any significant  adverse effects
on natural populations of fishes, amphibians, reptiles, birds
and mammals.  Investigations are  still required  to  evaluate any
possible latent effects of Mirex  residues  on key vertebrate
species in the field  to determine possible adverse effects on
their behavior, brood size and survivorship.  There is always
the possibility of subtle adverse effects on certain wildlife
species subjected to long-term,  sublethal  residues of Mirex
in treated areas.

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                         -  50 -

     F.  Absorption, Metabolism and Excretion
         Even less data are available on the absorption rate
and excretion of Mi rex in experimental animals than on the bio-
logical effects.  A single unpublished and incomplete report is
available on the administration of carbon-14 labeled Mirex
(Matthews 1971).  Following a single dose to rats, the radio-
activity of various tissues and excreta were determined.  As
might be expected, Mirex was found to be stored in adipose
tissue.  Data from this report indicate that Mirex has a half-
life of at least 25 days, which is considerably longer than the
half-life values cited for other persistent pesticides.  This
half-life value for Mirex probably constitutes an underestimation
of the extrapolated data (Matthews 1971).  Thin-layer chromatog-
raphy of extracts of the tissues and excreta revealed the presence
of no metabolites.  Mirex was incubated with homogenized liver
fractions of rats, mice and rabbits for a period of up to 36
hours.  These studies indicate that there is no evidence of any
metabolites of Mirex.  Very preliminary information from the U.S.
Forest Laboratory at the Research Triangle indicated that Mirex
at the concentrations used exhibited no effect on populations
of soil microorganisms, and that Mirex was not found to be
degraded by the microorganisms under the conditions of the
experiment (Matthews 1971).

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                           - 51  -

    G.  Biochemical
        Fragmentary evidence is  available which  indicates  that
Mirex is a stimulator of the liver microsomal  oxidative metabolism
pathway (Baetcke et al_.  1971).   Proliferation  of the endoplasmic
reticulum and an increase in oxidative metabolism has been
observed.

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                           -  52 -

VI.  MISCELLANEOUS
     A.   Chemistry
     The  chemical name for Mirex is dodecachlorooctahydro-1,3,4-
metheno-2H cyclobuta[cd]pentalene and the empirical formula is
C10C112-  Mirex has a closed  10-carbon structure, with all valence
points chlorinated.  It is nonflammable and insoluble in water.
Since Mirex is totally chlorinated and has no free reactive groups
readily available for chemical attack, it is a very stable compound
chemically (Markin 1970).
     B.   Tolerances
     Established tolerances for residues of Mirex in or on raw
agricultural commodities were published in the Federal Register (36
FR 3965 March 3, 1971) as follows:  0.1 ppm (negligible residue) in
the fat of meat of cattle, goats, hogs, horses, poultry, and sheep;
0.1 ppm (negligible residue)  in milk fat and eggs; and 0.01 ppm
(negligible residue) in or on all other raw agricultural commodities.
     C.   Possible Analytical  Interferences and Misinterpretations
     It is quite possible that some earlier Mirex residues, particu-
larly in  aquatic samples, may have been partially misidentified.
As with many other chlorinated pesticides, Mirex can be confused
with PCBs eluting from a gas  chromatograph.  For example, Aroclor
1260 has  an almost identical  retention time with Mirex on many
commonly  used gas chromatographic columns.  Adequate techniques
for separating PCBs from organochlorine pesticides were not avail-
able until 1970 and were not developed and tested for Mirex until

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                           - 53 -

more recently.  In one particular study (Markin ejt al_.  1971c), the
first analyses of samples by a  standard cleanup method  indicated
that 40% contained Mi rex residues.  However, utilizing  a new
technique to separate Aroclor 1260 from Mi rex, it was determined
that the first analyses had been in error since part or all  of
the original gas chromatographic peak could be attributed to Aro-
clor 1260.
     Another possible source of analytical  misinterpretation
might result if a commercial fire retardant called Dechlorane
was present in environmental samples being analyzed for Mi rex
residues.  Since this contaminant is chemically identical to
Mi rex, it would be impossible to differentiate between  the two
compounds by gas chromatographic or any other usual means of
analyses.  Sales of Dechlorane in the past decade have  been
over four times those for Mi rex during the same period   (Com-
munication to Mi rex Advisory Committee by Allied Chemical
Company December 21, 1971).  The distribution of Dechlorane
in the environment is unknown.
     D.  Analytical Confirmation
     It is very important to employ adequate analytical  confir-
mation techniques before publishing pesticide or PCB residue
data obtained from environmental  samples.   Even the use of  two
gas chromatographic columns of varying polarity may not be
adequate.   Further confirmation should be  made  by  thin layer

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                            - 54 -
                        CONCLUSIONS

 In compliance with  its charge to consider and evaluate all relevant
 scientific evidence concerning the use of Mirex, particularly for
 fire ant control, the Mirex Advisory Committee has reached the fol-
 lowing conclusions  based on careful evaluation of all available data.
 A.   Problems Posed by the Imported Fire Ant
     1.  The imported fire ant currently infests more than 126,000,000
 acres in nine southern states and continues to expand its range.
     2.  The imported fire ant is a major nuisance pest because of its
 sting.  Its presence restricts the use of recreational and other
 public areas as well as private property.
     3.  The imported fire ant is a health hazard because of the
 development of secondary infection and allergic reactions to its
 venom.  A small percentage of its victims are hypersensitive to the
 venom and may suffer anaphylactic shock.
     4.  The imported fire ant is of relatively minor importance as
 an agricultural pest.  The threat of being stung interferes with
 hand labor involved in the cultivation and harvest of some crops and
 the mounds may damage mowing machines and combine harvesters.
     5.  The imported fire ant is an aggressive predator of other
 arthropods including both pests and beneficial species.  Present infor-
mation Is not adequate for an evaluation of its impact on the popula-
tions of these organisms.  It is also a scavenger of undetermined
significance.
B.   Control  of the Imported Fire Ant
     1.   Mirex bait is effective for control  of the imported fire

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                            -  55
ant when applied in minute amounts of active  ingredient per  acre.
One application usually eliminates more than  90 percent of the
mounds in a treated area.   Three applications at about  six-month
intervals virtually eliminates all mounds  exposed to  treatment.
     2.  Mirex bait may be used on a scale ranging from a  single
application to one mound to multiple applications to  the entire
infested area of the southern states.  The degree of  control  of
the imported fire ant would be correlated  with the size of the
area treated and the number of applications.
         a.  Individual mound treatment is the least  effective of
all control programs.  Broadcast treatment of individual properties
would give adequate short-term control in  the areas treated.   Retreat-
ment on an annual basis would be required  in  such a program  because
of reinvasion from adjacent untreated areas.   Environmental  contam-
ination would be minimal.   Handling of bait by untrained people
would result in the possibility of excessive  application rates and
more direct human exposure than in other methods of control.
         b.  A publicly sponsored control  program involving appli-
cation of Mirex bait as needed, based on pest population assessment,
offers the greatest relief with minimal environmental  impact.  Such
a program would give satisfactory control  of the  pest  for a year
or more with one application.  Subsequent single  applications
would be made as needed.
         c.  Multiple  treatment of  large  contiguous  areas for
suppression of  imported fire  ant  populations  results in effective
control of the  pest  for several years and reduces reinvasion from

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                            - 56 -
untreated areas, but would do little more to alleviate the problem
than a control program such as that considered in the preceding
paragraph.  Large areas where the ant is not a pest would be treated
with Mirex resulting in the possibility of unnecessary environmental
contamination and greater initial costs.
         d.  A successful eradication program would yield the
greatest long-term benefits.  The possibility of adverse environmen-
tal impact is such that it could only be considered if success were
assured.  The possibility that eradication of the imported fire ant
could be achieved with current technology is still a controversial
issue.  However, eradication of the pest is no longer an objective
because of financial and logistical limitations and possible adverse
environmental effects.
     3.  A program involving multiple applications of Mirex bait
to the periphery of the infested areas has probably delayed, but
not prevented, continuing spread of the pest.  Lack of adequate
survey methods results in treatment of some uninfested areas and
failure to treat some infested areas.  Because of the size of the
infested area in the United States, effective treatment of the
peripheral areas would require repetitive application of Mirex
bait to a contiguous area that would involve millions of acres.
C.   Control of Miscellaneous Pests
     The Western harvester ant, the Texas leaf-cutting ant, and
other species of ant pests are controlled with Mirex bait applied
to individual nests or small areas.  The most effective way of
controlling some serious agricultural pests, particularly aphids,

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                           -  57  -

scale insects and mealybugs,  is  to control the ants that protect
and transport these pests.  Yellow jackets are nuisances in recre-
ational areas, and a small  percentage of  people  stung are hyper-
sensitive to the venom.   Mirex baits provide  highly effective and
comparatively selective  control  for all of these pests.  Compared
to effective alternative methods of control,  such baits are safe
and have little, if any, adverse environmental effects.
D.  Alternative Control  Measures
    1.  For the past several  years, the USDA  has conducted a
continuing screening program  for new,  less persistent  insecticides
to replace Mirex.  Although several compounds have shown promise  in
laboratory tests, none has proved  to  be an effective alternative  in
field experiments.
    2.  Aldrin, chlordane, dieldrin and heptachlor used  to control
the imported fire ant prior to the development of Mirex  remain  as
available alternatives.   However,  these compounds are  currently
registered for use only for limited  sites that are not devoted  to
production of food and feed crops  and could  not  be used for  broad-
cast applications over extensive areas.  The effective dosage rates
of these alternative chemicals far exceed that use in Mirex  bait
and, therefore, their substitution is considered inadvisable.
    3.  A search  is underway for an effective biological control
agent  to replace  chemical control  of the imported fire ant.   No
method of biological control presently under investgation shows
promise in  the  immediate future of effectively  supplementing or
replacting  chemical control.

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                            - 5R -
 E.    Potential Hazards Associated With the Use of Mi rex
      1.   No  instances of any acute intoxication to users have
 been  reported due to the handling or application of Mi rex bait in
 over  a decade of use.
      2.   There is no evidence of damage to vegetation from the use
 of Mirex  bait.  No significant absorption of Mirex by, or trans-
 location  of  residues from soil into, plants consumed by man or his
 domestic  animals has been reported.  Residues of Mirex in edible
 food  or feed are nonexistent or extremely low.  The significance,
 if any, of these minute residues to the health of man or his domestic
 animals is unknown.
      3.   Most investigations of the effects of Mirex on inverte-
 brates and vertebrates in the natural habitat have failed to demon-
 strate any significant changes in their populations.  Field studies
 have  shown significant population declines of several terrestrial
 invertebrate species, most but not all of which apparently feed
 directly  on  the Mirex bait.  Sampling methods have not been
 adequate  for censusing some natural populations of terrestrial
 and aquatic  organisms.  Laboratory experiments have shown toxic
 effects on juvenile crustaceans exposed to low concentrations of
 Mirex.  Monitoring studies have indicated considerable Mirex resi-
 dues  in some invertebrates and vertebrates, especially those that
 are preclaceous on ants and other insects.
     4.  Mirex residues in water appear to be non-detectable or
minimal as a result of normal Mirex treatments to control the
 imported fire ant.  Residues in soil occur where Mirex has been

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                            - 59 -
used and are minimal  in magnitude.   Mi rex  residues, although
occurring at low concentrations  in  aquatic sediments, may be
of some biological  importance  because of the  probable ingestion
of organic detritus and other  components by bottom-feeding crusta-
ceans.  Very preliminary studies indicate  that  Mirex residues
are not degraded by biological  systems  and organisms.
     5.  Monitoring of Mirex in  certain edible  food products
selected from treated areas indicates insignificant residues,  if
indeed they occur at all, presently in  the human  food chain de-
spite the widespread apolication of Mirex  during  the past decade
for the control of the imported  fire ant in the infested areas.
In preliminary studies, only a small percentage of human adipose
tissue samples analyzed showed the  presence of  suspected and
unconfirmed Mirex residues.
     6.  Insufficient data are available on most  mammals for  an
accurate evaluation of the acute toxicity  of  Mirex.   In rats, it
exhibits a low degree of acute toxicity, but  subacute  studies
indicate pathologic changes in the  liver at low feeding levels.
Subacute feeding experiments in dogs produced no  pathological
effects at low chronic feeding levels.
     7.  No data are available on the chronic toxicity of Mirex
for experimental animals.  Such data are urgently needed before
valid conclusions on the possible hazards  of Mirex to man can be
drawn.
     8.  Mirex caused significant reproductive effects in rats
when fed at relatively high levels  in  the  diet but no effects when

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                          - 60 -
fed at rates likely to occur on food or feed as a result of
applications made for control of the imported fire ant.   Mirex
produced no measurable reproductive effects in bobwhite  quail
or mallard ducks when fed at relatively high levels in the diet
in long-term studies.
     9.  Based on meager and preliminary data from a rat feeding
experiment, no metabolites of Mirex have been detected.   It is
stored in the fat depots of animals and appears to have  a bio-
logical half-life of at least 25 days.
     10.  Mirex has been demonstrated to be tumorigenic  to
two strains of mice when fed relatively high dosages.  However,
no conclusions can be reached concerning the carcinogenicity
of Mirex for man until it has been studied in other mammalian
species.
F.  Miscellaneous
     During the past decade, Dechlorane, which is chemically
identical to Mirex, has been used for numerous industrial
applications in amounts far greater than amounts of Mirex used
for imported fire ant control.   The degree of environmental
pollution from this source is unknown.

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                           -  61  -
                       RECOMMENDATIONS

1.  The registration of products  containing Mirex should be
    continued with labeling restrictions  to minimize environ-
    mental  contamination.
2.  Publicly supported control  programs should  be limited  to Mirex
    application, according to need  based  on pest population assess-
    ment, to infested areas where the imported  fire ant is a problem
    because of use by people or interference with agricultural
    operations.  Estuaries and other aquatic habitats, wildlife
    refuges, and heavily forested areas should  not be treated.
3.  Where publicly sponsored programs are unavailable, broadcast
    treatment of lawns, pastures, school grounds, parks, and similar
    areas by individuals is recommended  instead of mound treatment.
    Educational programs should instruct  infested property owners
    as to how Mirex can be applied  for the most effective  control
    of the imported fire ant with minimal environmental contamination.
4.  To implement control programs,  much more  information  is  needed to
    establish economic or nuisance  threshold  levels  requiring  Mirex
    treatment as well as on rates of reinfestation  and  population
    recovery in areas receiving a single bait treatment.
5.  Considerably more research on the possible hazards  of Mirex to
    man and his environment must be conducted before the role of
    Mirex, as a pesticide, can be accurately assessed.   Chronic
    toxicity, carcinogenicity, mutagenicity, teratogenicity and the
    metabolic fate of this compound  in multiple species should be

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                           - 62  -

further studied.  Additional  work on the biological  stability,
persistence and routes of movement of Mirex under field con-
ditions is needed.  Continued and expanded monitoring of key
environmental carriers and selected commercially important
species for Mirex residues should be carried out with emphasis
on the detection of any significant contamination of the human
food chain.  More thorough studies on the effects of Mirex on
aquatic crustaceans are needed,  especially the monitoring of
population densities in the field.  Greater effort should be
made to correlate laboratory and field research.  Increased
research is to be encouraged for the non-insecticidal control
of the imported fire ant.
Respectfully submitted,
C. H. Van Middelem, Ph.D., Chairman                   March 1, 1972

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                                   - 63 -
                                 REFERENCES
Allied Chemical Corporation:   Memorandum of Allied  Chemical  Corporation
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Allied Chemical Corporation:   Exhibits to Memorandum in  support  of  opposi-
  tion to cancellation of mirex registrations.   Exhibits 1-32  (1971b).

Baetcke, K. P., Cain, J. D.,  and Poe, W. E.:  Mirex and  DDT  residues  in
  wildlife in Mississippi.  MS submitted to Pest. Monit. J.  31pp.   Sched-
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Baker, M. F.:  Studies on possible effects of mirex bait on  the  bobwhite
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Bakus, G. J.:  Energetics and feeding in shallow marine  waters.   Intern.
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Bartlett, F. J. and Lofgren,  C. S.:  Field studies  with  baits  against
  Solenopsis saevissima v. rich ten', the imported fire ant.   J.  Econ.
  Entomol. 54:70-73  (T961 ) .

Bartlett, F. J. and Lofgren,  C. S.:  Control of native fire  ant, Solenopsis
  geminata, with mirex bait.   J. Econ. Entomol.  57:602  (1964).

Bennett, W. H.:  The Texas leaf-cutting ant.  USDA Forest Pest Leaflet 23
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Blake, G. H., Jr., Eden, W. G., Hays, K. L.:  Residual effectiveness of
  chlorinated hydrocarbons for control of the imported fire  ant.  J.  Econ.
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Buren, W. F. :  Revisionary studies on the taxonomic  identity and character-
  ization of the imported fire ant.  MS  submitted to J .  Ga .  Entomol . Soc .
Cherrett, J. M.:  Baits for control of leaf-cutting ants.  I-formulation.
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Collins, H. L. and Davis, J.:   Residues of the insecticide mirex in channel
  catfish and other aquatic organisms.  Unpubl . presentation. 9pp  3 table.
  Ann. Meet. Entomol. Soc. Amer.  (1971).

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                                   - 64 -
Crowell, N. N.:  Control of the western harvester ant Pogonomyrmex
  occidental is with poisoned bait.  J. Econ. Entomol.  56:525-532 (1963).

Culpepper, G. H.:  Status of the imported fire ant in the Southern States
  in July 1953.  USDA, Bur. Ent. PI. Quar. E-867, 8pp (1953).

Curley, A.:  Report to the Surgeon General's Office on mirex in seafood
  samples from Savannah, Georgia.  Special Rept. 3pp (1971).

Darnell, R. M.:  Food habits of fishes and invertebrates of Lake
  Pontchartrain.  Publ. Univ. Tex. Inst. Mar. Sci. 5:353-416 (1958).

DeWitt, J. B., Menzie, C. M., Spann, J. W., and Vance, C.:  Evaluation of
  chemicals.   In:  Pesticide-Wildlife Studies, 1963.   USDI Circ. 199:
  78-79, 97-112 (1964).

Duggan, R. E.:  Letter to Mirex Advisory Committee dated November 11,  1971.

Duke, T. W.:  Accumulation and movement of mirex in selected estuaries of
  South Carolina.  Unpubl.  MS 95pp (1971).

Echols, H. W.:  Texas leaf-cutting ant controlled with pelleted mirex  bait.
  J. Econ. Entomol. 59:628-631 (1966).

Ford, J. H., Hawthorne, J. C., and Markin, G. P.:  Monitoring for mirex and
  other organochlorine pesticides in beef cattle in the southeastern United
  States.  MS submitted to Pest. Monit. J.  25pp (1971).

Gaines, T. B.:  Acute toxicity of pesticides.  Toxicol.  Appl.  Pharmacol.
  14:515-534 (1969).

Gaines, T. B. and Kimbrough, R. D.:  Oral toxicity of mirex in adult and
  suckling rats.  Arch. Environm. Health 21:7-14 (1970).

Grant, C. D., Rogers, C. J., and Lauret, T. H.:  Control of ground-nesting
  yellow jackets with toxic baits--a five-year program.   J. Econ. Entomol.
  61(6):1653-1656 (1968).

Harris, W. G.:  The relationship of the imported fire ant, Solenopsis
  saevissima (F. Smith), to the populations of the lone star tick, Amblpyomma
  americanum (Linnaeus), and the effects of mirex on populations of arthropods
  Ph.D. dissertation on file Louisiana State Universtiy (1971).

Hawthorne, J. C., Ford, J. H., Collier, C. W., and Markin, G.  P.:  Residues
  of mirex a_nd other chlorinated pesticides in commercially raised catfish.
  MS submitted to Bull. Environm. Contam. Toxicol. 12pp, 1 map, 3 tabs.  (1971)

Hayes, W. J., Jr.:  The 90-dose LD5Q and a chronicity factor as measures of
  toxicity.  Toxicol. Appl. Pharmacol. 11:327-335 (1969).

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                                 -  65 -
Hays, K. L.:   The present status  of  the  imported fire ant in Argentina.
  J. Econ. Entomol.  51:111-112 (1958).

Hays, S. B. and Arant,  F. S.:   Insecticidal  baits for control of the
  imported fire ant Solenopsis saevissima  richteri.  J. Econ. Entomol.
  53:188-191  (1960).

Hays, S. B. and Hays, K.  L.:   Food habits  of Solenopsis saevissima richteri
  Forel.  J.  Econ. Entomol.   52:455-457  (1959JI

Heath, R. G.:  Preliminary report of mirex studies on avian reproduction.
  Report submitted to Advisory Committee.   3 pp  (1971).

Hensley, S. D., Long, W.  H.,  Roddy,  L. R., McCormick, W. J., and Concienne,
  E. J.:  Effects of insecticides on the predaceous arthropod fauna of
  Louisiana sugarcane fields.   J. Econ.  Entomol. 54:146-149 (1961)

Innes, J. R.  M., Ulland,  B.  M., Valerio, M.  G.,  Petrucelli, L., Fishbein, L.,
  Hart, E. R., Pallotta,  A.  J., Bates, P.  R., Falk, H. L., Gart, J. J.,
  Klein, M.,  Mitchell,  I., and Peters, J.:  Bioassay of pesticides and
  industrial  chemicals for tumorigenicity  in mice:  A preliminary note.
  J. Nat. Cancer Inst.  42:1101-1114  (1969).

Keh, B., Brownfield, N. T.,  and Person,  M. E.:   Experimental use of bait
  with mirex lethal  to both adult and immature Vespula pennsylvanica
  (Hymenoptera:  Vespidae).   Calif.  Vector Views 15:115-118 (1968).

Larson, P. S.:  Toxicologic studies  on the effects of adding mirex to the
  diet of albino rats for a period of three months.  Unpubl. Rept. furnished
  to Mirex Advisory Committee December 21, 1971, 12 pp (1968).

Lavigne, R. J.:  Individual  mound treatment for  control of the western
  harvester ant Pogonomyrmex occidental is  in Wyoming.  J. Econ. Entomol.
  59:525-532 (1966T

Lofgren, C. S., Adler, V. E., and Barthel, W. F.:  Effects of some variations
  in formulation or application procedure  on control of the imported  fire ant
  with granular heptachlor.   J. Econ. Entomol.  54:45-47  (1961).

Lofgren, C. S., Adler, V. E., Banks, W.  A., and  Pierce, N.:  Control  of
  imported fire ants with chlordane.  J. Econ. Entomol. 57:331-333  (1964).

Lofgren, C. S., Banks, W. A., Glancey,  B.  M., and  Weidhaas, D.  E.:   Interim
  report on imported fire ant trials.  Submitted December 1971  to Mirex
  Advisory Committee (1970).

Lowe, J.  I., Parrish, P.  R., Wilson, A.  J., Jr., Wilson,  P.  D.,  and Duke,
  T. W.:  Effects of mirex on selected estuarine organisms.   Unpubl.  MS
  25pp  (1971).

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                                - 66 -
Ludke, J. L., Finley, M. T., and Lusk, L.:  Toxicity of mirex  to crayfish,
  Procambarus blandingi.  Bull. Environm. Contam.  Toxicol.  6:89-96  (1971).

Mahood, R. K., McKenzie, M. D., Middaugh, D. P., Bollar, S.  J., Davis,'J. R.
  and Spitsbergen, D.:  A report on the cooperative blue crab  study.  South
  Atlantic States.  USD I 32pp (1970).

Markin, G. P.:  Affidavit of George P. Markin No.  1.  Filed  November 6,
  1970, in U.S. District Court for District of Columbia.  Civil No. 2319-70
  63pp (1970).

Markin, G. P.:  Methods of controlling the imported fire ant.  Special Rept.
  USDA, PPD, Gulfport, Miss.  8pp (1971 a).

Markin, G. P.:  Residues of the insecticide mirex following  treatment of
  Cat Island.  Unpubl.  MS 13pp (1971b).

Markin, G. P., Ford, J. H., Hawthorne, J. C., Spence, J. H., Davis, J., and
  Loftis, C. D.:  Environmental monitoring for the insecticide mirex.  MS to
  be submitted to Pest. Monit. J. (1971a).

Markin, G. P., Ford, J. H., and Hawthorne, J. C.:   Mirex residues  in wild
  populations of the edible red crayfish (Procambarus clarkii).  MS to be
  submitted to Bull. Environm. Contam. Toxicol. 15 pp (1971b).

Markin, G. P., Hawthorne, J. C., Collins, H. L., and Ford, J.  H.:   Levels
  of mirex and some other organochlorine residues in seafood from Atlantic
  and Gulf Coast States.  MS to be submitted to Pest. Monit. J. 28pp  (1971c),

Martin, W. E.:  Communication to Mirex Advisory Committee dated
  November 23, 1971.

Matthews, H. B.:  Mirex studies at NIEHS.  Presented to Mirex  Advisory
  Committee November 18, 1971.  8pp (1971).

Maxwell, F. G., Project Coordinator:  Levels of chlorinated hydrocarbons  in
  catfish in Alabama, Arkansas, Florida, Georgia, Louisiana, and Mississippi
  Final Rept.-Draft.  Miss. State University  61pp (1971).

McKenzie, M. D.:  Fluctuations in abundance of the blue crab and factors
  affecting mortalities.  S.C. Wildlife Resources Dept. Tech.  Rept. 1
  45pp (1970).

Miller, D. C.:  The feeding mechanism of fiddler crabs, with ecological
  considerations of feeding adaptations.  Zoologica 46:89-100  (1961).

Mills, H. B., Chairman:  Report of committee on the imported fire  ant
  to Administrator, Agricultural Research Service, U.S. Department of
  Agriculture Sept. 28, 1967.  National Academy of Sciences, National
  Research Counci1.  15pp (1967).

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                                 - 67 -
Muncy, R. J. and Oliver, A.  D.,  Jr.:   Toxicity  of  ten  insecticides to
  the red crayfish, Procambarus  clarki (Girard).   Trans. Amer. Fish. Soc.
  92(4):428-431  (1963).

Naber, E. C. and Ware, G. W.:  Effect of  kepone and mirex on reproductive
  performance in the laying  hen.  Poultry Sci.  44:875-880 (1965).

Odum, W. E., Woodwell, G. M.,  and Wurster,  C. F.:  DDT residues absorbed
  from organic detritus by fiddler crabs.   Science 164:576-577 (1969).

Parrish, H. M.:  Analysis of 460 fatalities from venomous animals in
  the United States.  Amer.  J. Med.  Sci.  245:129-141 (1963).

Race, S. R.:  Control  of western harvester ants on rangeland.  N. Mex.
  State Univ. Agr.  Exp. Sta. Bull. 502 21pp (1966).

Smith, J. B.:  Testimony of  Pineapple Growers Association of Hawaii
  before Mirex Advisory Commission.   Given before  the  Mirex Advisory
  Committee November 17, 1971.   llpp plus 5pp Attachm.   (1971).

Tagatz, M. E.:  Biology of the blue crab, Callinectes  sapidus Rathbun.
  in the St. Johns  River, Florida.  Fish. Bull. 67:17-33 (1968).

Triplett, R. F.:  Statement  presented to  the Mirex Advisory Committee on
  October 28, 1971.  17pp (1971).

Tucker, R. K. and Crabtree,  D. G.:  Handbook of Toxicity of Pesticides to
  Wildlife.  USDI Resource Publ. No.  84  131pp  (1970).

U. S. Department of Agriculture:  A plan  for a  pilot study to monitor mirex
  residues in terrestrial, amphibious, and aquatic organisms in the Dublin,
  Georgia, treatment area.  17pp (1971 a).

U. S. Department of Agriculture:  Feeding study to determine mirex residues
  in milk of dairy cows that may accumulate over  time.  2pp; Mirex residues
  in milk from cows fed the  insecticide in daily  rations.  Ip  (1971b).

U. S. Department of Agriculture:  USDA Statement  on  the  imported  fire ant
  and its control.   69pp (1971c).

U. S. Department of Agriculture, APHS:  Work Accomplishment  Summary   —
  Imported Fire Ant.  Unpubl.  (Dedember 1971d).

U. S. Department of Interior:  Mirex residues  in  birds and raccoons of
  South Carolina estuaries.   Special  Rept.  Pesticide  Field  Appraisal.
  35pp (1971).

Van Valin, C. C., Andrews, E.  K., and Eller, L. L.:   Some  effects of  mirex
  on two warm-water fishes.   Trans. Amer. Fish. Soc.  97:185-196 (1968).

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                                 - 68 -
Ware, G. W. and Good, E. E.:  Effects of insecticides  on  reproduction in
  the laboratory mouse.  II.  Mirex, Telodrin,  and DDT.   Toxicol. Appl.
  Pharmacol.  10:54-61  (1967).

Wilson, E. 0.:  Variation and adaptation in the imported  fire ant.
  Evolution 5:68-79  (1951).

Wilson, E. 0.:  Affidavit on the impact of mirex on the environment.
  2pp  (1971).

Wilson, E. 0. and Eads, J. H.:  A report on the imported  fire ant
  Solenopsis saevissima var. richteri  Forel  in Alabama.  Ala. Dept.
  Conserv. Special Rept.  53pp (1949).

Wilson, N. L.:  Effects of mirex bait on some nontarget arthropod popu-
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Wilson, N. L. and Oliver, A. D.:  Food habits of the imported fire ant
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  the Mirex Advisory Committee November 18, 1971.  Ip  (1971).

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                                - 69 -

                 PERSONS APPEARING BEFORE THE COMMITTEE
                             First Meeting
                         October 27 & 28, 1971
Mr. Harold G. Alford, Pesticides Regulation Division,  Environmental
  Protection Agency
Dr. W. G. Eden, University of Florida
Mr- Leo G. K. Iverson, Animal and Plant Health Service,  U.  S.  Department
  of Agriculture
Dr. William A. Knapp, Allied Chemical Corporation
Mr. Donald J. Mulvihill, Attorney for Allied Chemical  Corporation
Mr. George A. Robertson, Office of General Counsel, Environmental
  Protection Agency
Dr. R. Faser Triplett, Mississippi Allergy Clinic, Jackson, Mississippi
Dr. Robert J. Weir, Bionetics Research Labs., Inc.
                             Second Meeting
                         November 17 & 18, 1971
Dr. Karl Baetcke, Mississippi State University
Dr. R. R. Bates, National Cancer Institute, National Institutes of
  Health
Mr. J. Phil Campbell, Under Secretary, U. S. Department of Agriculture
Dr. Thomas W. Duke, Gulf Breeze Marine Laboratory, Environmental
  Protection Agency
Dr. 0. Garth Fitzhugh,  Office of Pesticides Programs,  Environmental
  Protection Agency
Mr. James 0. Lee, Jr.,  Animal and Plant  Health  Service, U. S.  Department
  of Agriculture
Dr. Robert J. Livingston,  Florida State  University

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                                - 70 -
Dr. George P. Markin, Animal and Plant Health Service, U. S.
  Department of Agriculture, Gulfport, Mississippi
Mr. William E. Martin, Fish and Wildlife Service, U. S. Department
  of the Interior
Dr. H. B. Matthews, National Institutes of Environmental Health
  Services
Dr. F. J. Mulhern, Animal and Plant Health Service, U. S. Department
  of Agriculture
Mr. M. T. Pender, Animal and Plant Health Service, U. S. Department
  of Agriculture
Mr. D. R. Shepherd, Animal and Plant Health Service, U. S. Department
  of Agriculture
Dr. James Smith, Pineapple Growers Association of Hawaii
Dr. D. Weidhaas, Entomology Research Division, U. S. Department of
  Agriculture, Gainesville, Florida
Dr. Anne Yobs, Division of Community Studies, Environmental Protection
  Agency
                             Third Meeting
                         December 21 & 22, 1971

Mr. Roy Bailey, Allied Chemical Corporation
Dr. Frederick Coulston, Albany Medical College of Union University
Dr. William A. Knapp, Allied Chemical Corporation
Mr. Donald J. Mulvihill, Attorney for Allied Chemical Corporation

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