environmental facts
ALDRIN AND DIELDRIN
DEFINITION AND USES
Aldrin and Dieldrin are persistent, broad-spectrum insecticides
in the chlorinated hydrocarbon group. Aldrin readily converts to
Dieldrin after application; however, Dieldrin is also marketed separately
Aldrin and Dieldrin have been two of the most widely used chemical
pesticides in the United States. In 1970 combined Aldrin and Dieldrin
consumption was 10.7 million pounds; in 1971 this total rose to 12.3
million pounds, and in 1973 it decreased to approximately 11 million
pounds. The major use of Aldrin has been for control of soil insects
that damage corn crops. Other uses of the pesticides include dipping
of plant roots, treatment of foundations for termite control, seed
treatments and fabric mothproofing.
REGULATORY ACTIONS
A. In early 1970, based on a concern to limit dispersal of
Aldrin and Dieldrin in the environment, the U.S. Department of
Agriculture (USDA) cancelled all registrations of these pesticides for
use in or on aquatic areas.
B. In December 1970,regulatory authority over pesticides was
transferred from USDA to the U.S. Environmental Protection Agency (EPA).
Shortly thereafter, the Environmental Defense Fund Inc.(EDF)filed a
petition with the Agency requesting immediate cancellation and suspension
of all Federal registrations of Aldrin and Dieldrin products on the
basis that these substances cause severe environmental damage and are
potential carcinogens (cancer-causing agents).
Under the Federal pesticides law, registration of a pesticide
product may be cancelled if there is a substantial question about the
pesticide's safety, or cancelled and suspended if the pesticide poses
an "imminent hazard" to man and the environment. A suspension order,
unlike a notice of intent to cancel, immediately halts production and
distribution of the pesticide product until all cancellation proceedings
have been completed and a final cancellation order has been issued.
C. In March 1971, the EPA Administrator issued a notice of
intent to cancel'all registrations of Aldrin and Dieldrin products.
However, he indicated that currently available evidence did not
support suspension.
D. In response to a request by 84 companies whose products were
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY • WASHINGTON. D.C. 20460
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affected by che^cancellation order, a scientific advisory committee
reviewed the matter and issued a report in March 1972 recommending that
the following uses be disallowed: all applications by aircraft; all
foliar spraying or dusting? mothproofing by any methods in which residues
are discharged into waterways or settling ponds; all use on turf except
as controlled by individuals trained or licensed in pest-control; any
use involving application in aquatic environments.
E. In May 1971, EDF again filed suit in the D.C. Court-of Appeals
to challenge EPA's refusal to suspend registrations. In its ruling
of May 1972,'the Court remanded the matter to EPA for further considera-
tion in light'of the advisory committee"report.
F. In June 1972, an EPA order withdrew cancellation notices for
Aldrin and Dieldrin uses in deep ground insertions for termite control,
nursery dipping of roots and tops of non-food plants, and fabric
mothproofing when there is no wastewater discharge. (These are the
only registrations currently being accepted). Notices of intent to
cancel all other major uses of these chemicals were reaffirmed.
G. In December'1972, EPA issued an order which elaborated on
its action of,June 1972, announcing that the Agency would continue to
permit use of Aldrin and Dieldrin for the protection of corn, citrus
and certain other crops pending the outcome of a public hearing scheduled
to begin in April 1973. This order followed the voluntary withdrawal
by industry of such controversial registered uses as those involving
aerial applications, dust formulations, products for fire ant control,
and granules for termite control.
CANCELLATION HEARING
The cancellation hearing on the benefits and risks of Aldrin
and Dieldrin began on August 7, 1973 with Administrative Law Judge
Herbert L. Perlman presiding. Primary participants in the hearing are
the Shell Chemical Company, sole manufacturer of Aldrin and Dieldrin;
USDA; EDF; and EPA.
Major hearing issues include the acute and chronic toxicity of
Aldrin and Dieldrin to man and other organisms, the environmental and
human health risks caused by bioaccumulation in the environment, and
the degree and manner of transport from the point of application.
The economic and social costs, and the existence of effective alter-
native controls are also under consideration.
SUSPENSION
On- August 2, 1974, EPA issued a notice of intent to suspend
registrations-of those uses of Aldrin and Dieldrin under investigation
in the cancellation hearing. The Agency issued the suspension notice
based primarily on evidence that the pesticides are potential carcinogens
and thus pose an "-imminent hazard" to human health. The cancellation
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hearing was temporarily, adjourned when Shell appealed the suspension and
requested an expedited hearing on the question- of "imminent hazard."
The expedited hearing was concluded on September 12, 1974.
On October 1, 1974, following the recommendation of the
Administrative Law Judge at the close of the hearing, the EPA Administrator
reaffirmed his earlier notice of intent to suspend and prohibited the
further production for use of all Aldrin and Dieldrin products not
specifically'exempted in the June 25, 1974 order. The October order,
however, permits continued sale and use of the very limited existing
stocks of the pesticides formulated prior to issuance of the notice
of intent to suspend. The suspension order has been appealed in the
U.S. Court of Appeals by Shell and USDA. EOF, which supports
suspension*has appealed the Administrator's decision to permit the use
of existing stocks of the pesticides. Unless the order is reversed,
it will remain in effect until a final decision is reached in the
cancellation proceeding, which will resume early in 1975.
FINAL EPA DISPOSITION
At the close of the cancellation hearing, the Administrative Law
Judge Herbert L. Perlman, will issue an initial decision based on
evidence which has been presented to him. This decision will become
the Agency's final action regarding Aldrin and Dieldrin registrations
unless appeals are filed, or the EPA Administrator independently indi-
cates an intent to review that decision. If such a review is undertaken,
the final administrative order on whether to cancel or amend any of the
Federal registrations of the two pesticides must be issued by the
Administrator within 90 days of the official close of the hearing.
January 1975
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