EPA Reassess Lindane without consideration of medical uses

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Subject: DOCKET CONTROL NUMBER OPP-34239 - EPA Accepting comments on Lindane
Date: Tue, 18 Sep 2001 19:17:36 -0700
From: Safe2Use <info@safe2use.com>
Organization: Safe2Use
CC: howard.markt@epa.gov, opp-docket@epa.gov

Dear Subscribers, 

EPA has just released its Preliminary Risk Assessment for lindane and totally ignored the risks caused by lice and scabies use of  lindane. EPA is now accepting comments on its Risk Assessment and it is imperative that individuals who recognize these "medical" uses as intolerable must comment. 

Millions of doses of lindane are given for treatment of headlice, scabies and other parasites. Even ignoring the poisoning of so many men, women and children... this pesticide poison is rinsed down the drain after use and into the sewers and water tables.  Many sanitation districts report unacceptable levels of lindane moving into the drinking water. HOW COULD THIS BE
IGNORED? What is the magic that makes a deadly pesticide poison "different" when put in a bottle at a pharmacy? Why is it so many other countries have banned Lindane entirely because of the harm to their people and environment while the US EPA ponders added uses? 

Even the State of California has banned Lindane for personal use as of January, 2001 because of the effects on the environment. 

AGAIN... What is the magic that makes a deadly pesticide poison "different" when put in a bottle at a pharmacy? 

Thank you, 

Linda L. Jensen-Pascarella 
Editor, Safe2Use Newsletter 

More: http://www.epa.gov/fedrgstr/EPA-PEST/2001/August/Day-29/p21569.htm 


Suggested sample letter to EPA authored by Ann Heil of the Los Angeles County Sanitation District: 

Public Information and Records Integrity Branch (PIRIB) 
Information Resources and Services Division (7502C) 
Office of Pesticide Programs (OPP) 
Environmental Protection Agency 
1200 Pennsylvania Avenue, NW 
Washington, DC 20460 

SUBJECT: DOCKET CONTROL NUMBER OPP-34239 

The purpose of this letter is to comment on the preliminary risk assessment for lindane. The risk assessment is incomplete because it does not consider the cumulative effects on risk from the use of lindane for head lice and scabies treatment. 

As background, <put a description of your organization here. If you are a private citizen, state why you are writing. For example you can state, “I am a mother who is very concerned about the health of our nation’s children and about our
environment.”

Head lice and scabies treatments make a significant contribution to both the human health and environmental risk of using lindane. When lindane is used for lice and scabies treatment, it is applied directly to the skin where it is readily absorbed. The amount of lindane absorbed through the skin from a single lice or scabies treatment represents over seven times the amount of lindane that can be safely absorbed over a lifetime. 

When lindane is rinsed off, it does down sewers, passes through wastewater treatment plants, and enters rivers, creeks, lakes, and oceans. A single lice or scabies contains enough lindane to pollute six million gallons of water to the acceptable level for drinking water sources of 19 parts per trillion. 

If risks due to head lice and scabies treatments are neglected in EPA’s risk assessment for lindane, the risk assessment will be meaningless. Therefore, we <or I> request that EPA consider head lice and scabies treatments when performing its risk assessment for lindane. We <or I> understand that EPA currently does not regulate head lice or scabies treatments, but these uses are indeed pesticide uses and must be considered when assessing the cumulative risk of using lindane. 

Thank-you for your consideration of these comments. 


Sincerely, 

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