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Case 1:05-cv-01020-MMS

Document 39-24

Filed 01/05/2007

Page 1 of 51

EPA Index to Pesticide Chemicals

CHLORDANE, TECHNICAL
Site and Pest

Dosages and
Formulations)

Tolerance, Use,

0.0 A /^ * ^^-^^ / Limitations-

^\

^

Terrestrial Structures (including construction sites) (continued)
Subterranean termites (continued)
emulsion) per 10 linear feet per foot of depth from grade to bottom of foundations. Application may be made by rodding, low pressure spray, and/or trenching. Treat both sides of foundation and around all piers and

pipes*
a*.

Rod holes should be spaced

b.

.'

(about 1 foot) to provide a continuous chemical barrierTrench need not be wider than 6 inches nor belgw the foundation. The emulsion should be mixed with the soil as 'it is 1?eing replaced in the trench. Cover the treated soil with a layer

of untreated soil* Do not apply chlordane io any manner to an area intended as a plenum air space. All holes drilled in construction elements for treatment should be securely plugged.
c.

POSTCONSTRUCTION TREATMENTS Use 1 percent emulsion for subterranean termites and 2 percent for Coptotermes species. Postconstruction applications shall be made by injection, rodding, low pressure spray, and/or trenching. Do not apply emulsion until location of heat or air conditioning ducts, vents, water and sewer lines, or electrical conduits are known and identified. Extreme caution must be taken to avoid contamination of these structural elements and airways. Do not apply chlordane in any manner to an area intended as a ple~ num air space,
Use pattern continued on the next page.-

Issued:

12-01-80

III-058201-11

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EPA Index to Pesticide Chemicals

CHLORDANE. TECHNICAL
Sice and Pest

Dosages and Tolerance, Use, Limi tat ions Formu1 a t ion(s)

Terrestrial Structures (including construction sites) (continued)
Subterranean termites (continued)
poured over soil the same day it has been treated, a waterproof cover, such as polyethylene sheeting, should be placed over the

2.

soil. This is not necessary if foundation walls have been installed around the treated soil. To produce a vertical barrier, apply the emulsion at the rate of 4 gallons of 1 percent emulsion (2'gallons of 2 percent emulsion) per 10 linear feet per foot of depth. a Rodding and/or trenching applications should not be made below the top of the

footing.
b.
Trench need not be wider than 6 inches.

3.

4.

Rod holes should extend from the base of the trench to the top of the footing, and should be spaced (about 1 foot) to provide a continuous barrier. d. Emulsion should be mixed with the soil as it is being replaced in the trench. Cover treated soil with a layer of untreated soil. Hollow block foundations or voids of masonry should be treated to make a continuous chemical barrier in voids. Apply at the rate of 2 gallons of 1 percent emulsion (1 gallon of 2 percent emulsion) per 10 linear feet so it will reach the footing. For crawl spaces apply at the rate of 4 gallons of 1 percent emulsion (2 gallons of 2 percent
c
next

Use pattern continued on the
Issued:

page.

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I1I-058201-10

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EPA Index to Pesticide Chemicals

Site and Pest

Dosage s^nd

Tolerance, Use, Limitations

Formulation(s)
Terrestrial Structures (including construction sites) (continued)

Subterranean termites (continued)
current

control practices for specific local conditions, consult resources in structural pest control.
PRECONSTRUCTION SUBTERRANEAN TERMITE

TREATMENT
Effective preconstruction subterranean termite control requires the establishment of an unbroken vertical and/or horizontal chemical barrier between wood in the structure and the termite colonies in the soil. To meet F.H.A. termite proofing requirements, follow the latest edition of the Housing and Urban Development (H.U.D.) Minimum Property Standards. After grading is completed and prior to the pouring of the slab, slab supported/constructed porches, or entrance platforms, make

following treatments. Applications shall be made by a low pressure spray for horizontal barriers over areas intended for covering floors, porches, and other critical areas. Establish a vertical barrier in areas such as around the base of foundations, plumbing, back-filled soil against foundation walls, and other critical areas. 1. Where it is necessary to produce a horizontal barrier, apply the emulsion at the rate of 1 gallon of I percent emulsion (0.5 gallon of 2 percent emulsion) per 10 square feet to dirt fill. If fill is washed gravel or other coarse material, apply at 1.5 gallons of I percent emulsion (0.75 gallon of 2 percent emulsion) per 10 square feet. It is important that the emulsion reaches the soil substrate. a. If concrete slabs cannot be
the

Use pattern continued on the next page.

Issued:

12-01-80

III-058201-9

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EPA Index to Pesticide Chemicals

CHLORDANE.
Site and Pest

TECHNICAL
Tolerance, Use, Limitations

Dosages and
Formulation(s)

Terrestrial Structures (including construction sites) (continued)

Subterranean termites (continued)

F &020.0005

(202 P/T)

Soil contact non fumigation treatment. Refer Co label for specific information and directions on car-

tridge injection.. Formulated with petroleum distillate.

F
&040.0006

0.5-22
emu 1 s ion

Soil contact nonfumigation treatment.

&104.0012
&108.0012

&108.3312
&244.0012 &245.0012

&246.7012 172.0012

|73.0012
^74.0012 &274.3512
&275.0012

&105.0015

(402 WP) (4 Ib/gal) (8 Ib/gal EC) (8.33 Ib/gal EC) (442 EC) (452 EC) (46.72 EC) (722 EC) (732 EC) (742 EC) (74.352 EC) (752 EC) (1.5 Ib/gal SC/L)

DIRECTIONS FOR PROFESSIONAL APPLICATION Chemicals for soil teatment are used to establish a barrier which is repellant to termites. The chemical emulsion must be adequately dispersed in the soil to provide a barrier between the wood in the structure and the termite colonies in the soil.

It is.necessary for the effective of chlordane that the service technician be familiar with current control practices including trenching, rodding, subslab injection, and low pressure spray applications. These techniques must be correctly employed to prevent or control infestations by subterranean termite species of Reticulitermes, Zooterroopsis, Heterotermes, and CoptoChoice of appropriate protermes. cedures includes consideration of such variable factors as the design of the structure, water table, soil type, soil compaction, grade conditions, and domestic water supplies, location, and type. The biology and behavior of the involved termite species are important factors to be known as well as suspected location of the colony and severity of the infestation within the structure to be protected. For advice concerning
use

Use pattern continued on the next page.

Issued:

12-01-80

III-058201-8
/7.5"

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EPA Index to Pesticide Chemicals

CHLORDANE. TECHNICAL
Site and Pest

HFJsites) (continued)

Dosages and
Formulation(s)

Tolerance, Use, Limitations

Terrestrial Structures (including

construction

Subterranean termites (continued)

slabs, drill holes at 1 foot intervals, 6 inches from the foundation,, and pour one-half gallon of solution into each hole. Retill holes. Slabs with heat ducts or radiating heat pipes should be treated by professional pest control
entrance

operators.

The object is to establish a treated soil barrier which will prevent termite entry. Other critical areas may also require treatment, particularly if there are inaccessible areas, basements, or slabtype construction. It is suggested that you
contact the Agricultural Cooperative Extension Service for advice or consult a Professional Pest Control Service.

Avoid contamination of public and private water supplies by following these precautions: Use antibackflow siphonage equipment. Refer to federal (Federal Housing Administration), state, and local specifications-for safe distances of treatment areas from wells. Soil in the vicinity of wells should not be treated if it is water saturated, or by injecting the solution under pressure. Soil should be removed
from well contaminaand returned to the trench which has been lined with
to an area safe

tion, treated,

plastic sheeting.

May be formulated with aromatic petroleum derivative solvent; aromatic petroleum distillate; heavy aromatic naphtha; heavy aromatic naphtha and petroleum distillate; kerosene; petroleum distillate;
xylene; or xylene range aromatic solvent.
Issued:

12-01-80

III-058201-7

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EPA Index to Pesticide Chemicals

CHLORDANE, TECHNICAL
Site and Pest

Dosages and Tolerance, Use, Limitations Formulation(s)

/6400000

Terrestrial Structures (including
construction sites)

Treatment shall not be made when the soil or fill is excessively wet
or immediately after heavy rains, to avoid surface flow of the toxicant from application site. Unless the treated areas are to be im-

mediately covered, precautions shall be taken to prevent disturbance of the treatment by human or animal contact with the treated soil.

@IMGDAGA
$6400085 F &104.0012 &107.6012
&108. 0012 &210. 0012

Subterranean termites

0.5-IX
emulsion

Soil contact; nonfumigation treatment.

5.

0012

0. 0012 &242. 2912 &242. 3712 6244. 0012 6245. 0012 6246. 0012 &248. 0012

&250. 0012 &262. 5012 6272. 0012 6273. 0512 6273. 5012 6274. 0012 6274. 3512
6275. 0012

(4 Ib/gal EC) (7.6 Ib/gal EC) (8 Ib/gal EC) (102 EC) (25% EC) (40% EC) (42.292 EC) (42.37X EC) (44X EC) (45Z EC) (46X EC) (48X EC) (502 EC) (62.52 EC) (722 EC) (73.052 EC) (73.52 EC) (742 EC) (74.352 EC) (752 EC)

DIRECTIONS FOR NON-PROFESSIONAL USE Subterranean Termite Control-in Existing Structures Buildings ^jith Baseroents^gr" Crawl Spaces Around piers, pipes, chimney bases, and along foundations of poured concrete dig a trench 6 inches wide and 4 inches deep. For brick and block foundations dig the trench about 12 inches deep. If footing. is more than 12 inches deep, make holes with a crowbar, pipe, or rod about 1 foot apart that extend from the trench bottom to the footing. Make holes closer in hard-packed clay soils. Never dig below the top of the footing. Apply the solution in the trench at a rate of 4 gallons of 1 percent emulsion (8 gallons of 0.5 percent emulsion) per 10 linear feet per foot of depth. Apply half of this to the back-fill. Likewise, treat along the inside of foundations of crawl space buildings. Cover treated soil with a thin layer of untreated soil, and take care to avoid contaminating water supplies.

For raised porches, terraces, and
Use pattern continued on the next page,

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I1I-058201-6

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EPA Index

Pesticide Chemicals

CHLORDANE, TECHNICAL
Site and Pest

^'^Tj^ ^"&

Dosages and Tolerance, Use, Limitations Formulation(s)

STRUCTURES, MOOD PRODUCTS AND WOOD COMMODITIES
(Terrestrial Structures (structural pest control and wood

protection))

General Warnings and Limitations: Chlordane may be applied by nonprofessionals (honieowners) or professional pest control operators. The instructions listed below are based on a concentration of 1 percent emulsion. Concentrations other than 1 percent also apply to the instructions below; however, their dosages should be adjusted to conform to the directions intended for 1 percent emulsion. The recommended concentration should not exceed 1 percent emulsion for non-professional and 2 percent emulsion for professional us.e. Remove all nonessential wood and cellulose containing materials, including scrap wood and formboards, from around foundation walls, crawl spaces, and porches. Avoid contamination of public and private water supplies by following these precautions. Use anti-backflow equipment or procedures Co prevent siphonage of pesticide back into water supplies. Do oot treat struc~ tures that contain cisterns or wells. Do not treat soil that is water saturated or frozen. Consult state and local specifications for recommended distances of treatment areas from wells, and refer to Federal Housing Administration Specifications for further guidance,

Issued:

12-01-80

III-058201-5
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EPA Index to Pesticide Chemicals
CHLORDANE. TECHNICAL
Site and Pest

Dosages and
Formulaeion(s)

Tolerance, Use, Limitations

Uncultivated Agricultural Areas (continued)
Imported fire ants (continued)

F

&040.0006 &104.0012 &108.0012

Distribution and use limited to AL, GA, LA, MS, NC, SC, and TX. (40Z Wp) Mound treatment. Thoroughly satu(4 Ib/gal EC) rate each mound using up to 5 gal(8 Ib/gal EC) lons of finished spray for larger mounds. Examine areas 14 to 21 days after treatment for surviving colonies and repeat as neededMay be formulated with aromatic petroleum derivative solvent; kerosene; petroleum distillate; xylene; or xylene range aromatic solvent.
mound

0.07-0.2 lb/

AR. FL.

FOREST,. CHAPARRAL, NONAGRICULTURAL AND WASTELANDS
General Warnings and Limitations: Restricted use pattern. Use is restricted to land not presently used or not to be used for food or feed production or grazing for a period of 2 years following treatment.

/6700000

Uncultivated Non-Agricultural Areas

Use to be cancelled December 31, 1980. Broadcast or aerial applications are prohibited. Distribution and use limited to AL, AR, FL, GA, LA, MS, NC, SC. and TX.
(3ISASBDA

Imported fire

ants

$6700000

F &1040012
&108.0012

0.16-0.21 lb/'Distribution and use limited to AL, mound AR, FL, GA, LA. MS, NC, SC, and TX. (4 Ib/gal EC) Mound treatment. Thoroughly satu(8 Ib/gal EC) rate each mound using up to 5 gallons of finished spray for larger mounds. Examine areas 14 to 21 days after treatment for surviving colonies and repeat as needed. Formulated with 'kerosene; or petroleum distillate.

Issued:

12-01-80

III-058201-4
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EPA Index to Pesticide Chemicals

CHLORDANE, TECHNICAL
Site and Pest

Dosages and

Tolerance, Use,Limitations

Forinulation(s)
Grapes (continued)
Cutworms (continued)

$0101415 &040.0006

2.5-4 Ib/A (40X WP)

Use limited to CA. Dormant or delayed dormant application. Use in sufficient water to thoroughly cover area to be treated. To prevent damage where cutworm populations are known to exist, apply at base of vines and surrounding soil surface. Use the higher dosage on muck or highly organic soil.
When cutworm damage is evident at

time buds begin to swell, apply directly to.trunk and arms of vine.
AGRICULTURAL PREMISES AND EQUIPMENT

(Uncultivated and/or Uncropped Agricultural Areas (outdoor))

General Warnings and Limitations: Restricted use pattern. Use is restricted to land not presently used or not to be used for food or feed production or grazing for a period of 2 years following treatment.

/6600000

Uncultivated Agricultural Areas
Use to be cancelled December 31, 1980, Broadcast or aerial applications are prohibited. Distribution and use limited to AL, AR, FL, GA, LA, MS, NC, SC, and TX.

@ISASBDA
$6600000 F &005.0003 6010.0003 6010.0004 &020.0004 &025.0004

Imported fire ants

0.07-0.15 lb/ Distribution and use limited to AL, mound AR, FL. GA, LA, MS, NC, SC, and TX. (5Z D) Mound treatment. Apply directly to (102 D) each mound or nest entrance and an (10% G) area 3 feet around the mound. Exam(20S; G) ine areas 14 Co 21 days after treat(252 G) ment for surviving colonies and repeat as needed*

May be formulated with petroleum
distillate.

Issued:

12-01-80

III-058201-3

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EPA Index to Pesticide Chemicals

CHLORDANE, TECHNICAL
GENERAL WARNINGS AND LIMITATIONS (continued)

DRAFT

Pineapples Plums (Fresh Prunes) Potatoes

Quinces Radishes (with or without tops) or Radish Tops Raspberries Rutabagas (with or without tops) or Rutabaga Tops Squash
Strawberries Summer Squash Sweet Potatoes

Tomatoes Turnip (with or without tops) or Turnip Greens Youngberries.
Bee Caution: This product is toxic to bees exposed to direct treatment or residues on crops, and should not be applied when bees are actively visiting the area.

Site and Pest

Dosages and
Formulation(s)

Tolerance, Use, Limitations

AGRICULTURAL CROPS
General Warnings a-ad Lijnitatig-ns:

Restricted use pattern.

/010UOO

Grapes

0.3 ppm
Use to be cancelled July I, 1980. Use limited to CA. Use only ac~ cording to the provisions of the appropriate state permit and prescription use programs. Use by

ground equipment only,

@ITBCABA
$0101402 &005.0004

Cutworms

2.5-4 Ib/A (5X G)

Use limited to CA. Soil application. To prevent damage where cutworm populations are known to exist, apply at base of vines and incorporate into soil immediately.

Issued:

12-01-80

III-058201-2

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EPA Index to Pesticide Chemicals

-./r-y/^jr
c058201

CHLORDANE. TECHNICAL*
TYPE PESTICIDE:
Insecticide

^/VA KT I* |

^)f^

FORMULATIONS: Tech (1002); FI (4 Ib/gal. 8 Ib/gal, 40%, 502. 732); D C 52, 102)7 G (52, 102. 202, 252); P/T (202); WP (402); EC (4 Ib/gal. 7.6 Ib/gal, 8 Ib/gal. 8.33 Ib/gal. 102, 252, 402. 42.292. 42.372. 442.

452. 462. 46.72. 482. 502. 62.52. 722. 732, 73.052, 73.52. 742, 74.352,
752); SC/L (1.5 Ib/gal)
GENERAL WARNINGS AND LIMITATIONS:
Raw Agricultural Commodity Tolerances: 0.3 ppm for residues containing not more than 1 percent of the intermediate compound, hexachlorocyclopentadiene in or on each of the following raw agricultural commodities listed below< The occurrence of such residues may result from chlordane applied to croplands in previous years, Such use is no longer permitted, and in no case should chlordane he deliberately applied to growing crops or to soil where crops will be grown in the future.

Apples Apricots Beans Beets (with or without tops) or Beet Greens alone Blackberries Blueberries (Huckleberries) Boysenberries Broccoli Brussels Sprouts Cabbage
Carrots
Cauliflower

Celery Cherries Citrus Fruits
Collards Corn Cucumbers

Dewberries Eggplancs Kale
Kohlrabi Lettuce

Loganberries
Melons Nectarines
Okra

Onions Papayas
Peaches

Peanuts Pears Peas Peppers

*602 octachloro-4,7-methanotetrahydroindane and 402 related compounds.
Issued:

12-01-80

111-058201^1

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APPENDIX B:

EPA INDEX ENTRIES FOR CHLORDANE AND ALDRIN AND LABEL SUMMARIES FOR THE REMAINING REGISTERED COMPOUNDS

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renewal estimates for 1965-69 represents the total number of renewals
for 1970.

Total renewal costs were estimated by multiplying the total

number of renewals by the average renewal cost, $30.60 (1976 dollars),
obtained from Smythe and Williams.

Damage Costs

Smythe and Williams derived an estimate of $38.6 million for the
cost of damage repair done by someone other than the pest control

industry.

Their estimate assumes 70 percent of remedial treatments

required no repairs, 10 percent required repairs costing $196.00 per
treatment (adjusted for inflation, 1976 dollars), and the remainder
cost $500.00 for repair.

Applying the same assumptions to the

extrapolated treatment data, we obtained an estimated $107.6 million

(1976 dollars)

in costs of damage repair done by someone other than the

pest control industry.

Inflating to 1980 Dollars

Adding the above estimated costs results in a national estimate
for potential loss due to termites of $470.8 million per -annum.
This

loss estimate can be inflated to 1980 dollars using the Bureau of the

Census New One Family Houses Construction Index (Construction Review,

1981).

Inflating by this index results in a national potential loss

estimate in 1980 dollars of

$753.4 million per

annum.

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PLATE XXV.

Trend in numbers of treatments annually reported to regulatory offices in Alabama, Arkansas, Georgia, Louisiana, Oklahoma, and Tennessee during 1961-1976.

YEAR
Source:

Smythe and Williams,

1979,

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\

quarantees for a set fee on a

year by year basis.

Smythe and Williams

estimated renewal cost in 1970 on the basis of treatments performed in
the preceding 5 years because regulatory officials estimated that most
contracts were renewed for five consecutive years.

Total treatments

and treatment composition in each of the 11 states, were estimated for

1965-69 by the same procedures used for obtaining the 1970 estimate.

Regulatory officials estimated that 37 percent of the pretreatments and
67 percent of the remedial treatments are renewed, so Smythe and
Williams used these percentages to estimate the number of each type

renewed.

They then multiplied these estimates by the average cost per

renewal obtained from Arkansas and Tennessee data, tb determine the total renewal cost for 1970.

Smythe and Williams' renewal cost estimates include beetle
treatments, therefore they could not be used directly.
They had to be

purged of their beetle component.
treatment information from

Since we did not have the termite

1965-69 necessary to determine the total
we

number of renewals, for

1970,

developed 5-year renewal information
We estimated the number

based on our 1970 termite treatment estimates.

of 1970 treatments that would be renewed in the future using the Smythe and Williams* assumption that 37 percent of pretreatments and 67
percent of remedial treatments are renewed.

We then modified this

estimation to represent renewal data for the five years preceding 1970. This was achieved using the trend presented in Plate XXV,

The mean

number of treatments for each year, 1965-69, was taken as a proportion
of the mean for 1970.
The number of 1970 treatments to be renewed was

multiplied by each of these proportions to determine the renewal
estimates for each of the

preceding five years.

Summing the

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This procedure generated an annual percentage for each of the

regions.

The annual percentage determined for Region V was felt to he

too low for the states of Illinois, Indiana and Ohio.

Since these
the average of

three states lie directly between Regions III and

VII,

the treatment percentage of each of these two regions was substituted

as a proxy for the annual percentage for the three states.

The

percentages generated for California and Hawaii (both in Region X) were

similarly considered to be too low.
Williams (Williams, pers. eomm.

Based on discussion with Lonnie
it was determined that the

1981)

percentage in California should be similar to the average for Region IV

(2.93%), whereas for Hawaii, the annual percentage of houses treated
should be similar to Georgia

(3.652).

The total number of termite

treatments were then estimated by applying these

generated treatment

percentages to the number of houses in each state, as reported by the

1970 Census of Population and Housing.
The type of treatments (remedial or

pretreatment)

were determined

for each state using the Smythe and Williams assumption that 74 percent
of total treatments should be considered remedial treatments and the

remaining 26, percent pretreatments (Smythe and Williams, 1979).

Treatment costs (1976 dollars) were calculated using the Smythe and

Williams' estiamates of $246.00 per typical remedial treatment and

$120.00 per typical

pre'treatment.

Renewal Costs

Most termite treatments include a one-year service and (future)
damage repair guarantee.

Subsequently the homeowners can renew the

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percentages of these eight states results In 2.93 percent of the houses

being treated in Region IV annually.
The map

(Plate XXIV) obtained from the EPA National Household

Usage Study presents estimated total percent of households ever treated
for termites in each EPA Region*

It was assumed that the ratio of the

annual percentage (2.93) to the total percentage (54.5) in Region IV
was the same for all regions-

In order to derive the annual percent of

houses treated for the other regions, the total percent of houses

treated in each region was indexed to the total percent of houses treated in Region IV; i.e. the total perentage of households treated for each region was taken as a proportion of the total percentage for
Region IV<
This proportion was then multiplied by the annual treatment

percentage for Region IV.

Formulated mathematically:

Annual % Region i Total % Region i

Annual

X Region IV

Total

Z

Region IV

Annual % Region I

fTotal

X Region i

I Total % Region

\ IV/

Annual

X Region IV

i

I, II, III. V through X

Given:

Annual

X Region IV

Total X Region IV Total % Region i

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CO

r-1
(0 l-l

^1
a u
(3
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Appendix A

ESTIMATION OF NATIONAL COST OF TERMITE PROTECTION AND DAMAGE

Treatment Costs

A national estimate of the potential costs of termite damage va.s
constructed using the data for 11 southern states presented in a report

by Richard Smythe and Lonnie Williams (Smythe and Williams, 1979).

The

first step in this estimation was to determine treatment costs for all
states.

Smythe and Williams estimated the number of termite treatments

during 1970 and the cost of these treatments in 1976 dollars, for the
11 southern states.

Data concerning the number of treatments for the
presented in Table XXIII.
Column 4 of the table

11 southern

states are

indicates the percent of houses treated in each state in 1970.

These

percentages were extrapolated by means of data from an EPA National

Household Pesticide Usage Study 1976-77 (EPA, 1979) which indicated the
total percentage of households ever treated in the remaining 39
states
Since

EPA Region IV had the most available information, it

wa.8

used to estimate percentages of houses treated in the remaining nine

regions.

The percent of houses treated in Region IV was determined

using Smythe and Williams' data.

Seven of the 11 states in their
The only state in Region IV not
The percent of houses

report are located in this region.

included in the original 11 states is Kentucky.
treated tn Kentucky was assumed to be

2.73, the average percentage of
Averaging the

houses treated determined by Smythe and Williams.

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APPENDIX A:
ESTIMATION OF NATIONAL COST OF TEEMITE PROTECTION AND DAMAGE'

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D.

Summary

The most likely cancellation scenario would seem to involve
cancellation of all four cyelodiene termiticides since it is hard to

imagine cancelling chlordane without also cancelling heptachlor, aldrin

and dieldrin.
be sizeable.

The economic impact of such a cancellation action would

Cancelling all the cyclodienes would result in an

increase in the social costs associated with termite control and damage

of $706.6 million to $1.0 billion per annum for the forseeable future.

These estimates can be considered low since they exclude potential losses in multifamily dwellings, commercial establishments and public
buildings,^as well as the massive growth in residential housing during

the 1970*s.

They also do not account for changes in chemical prices,

contract renewal fees and costs of damage repair that could be expected
to

result from such a regulatory action*
Since it appears that most of the exposure problems are a result

of a specific type of application to specific structures (i structures with ducting in or under

slabs), it would

seem more

appropriate to consider regulatory options short of cancellation that

focus directly on this exposure problem. be:

Some of these options might

restricting the use of these chemicals so that they can only be

applied by certified applicators, Traprnvj_r^ t-raining of applicators so /---.---^----^ they are aware of the specific potential problem areas, modification of
label information to indicate potential hazards of treating structures

with slabs containing duct work, or even proscribing the injection of
termiticides through such slabs.

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will be less than the cost of retreatment.

If this is the case, the

total treatment expense borne by the homeowner would be less and

consequently the total cost of cancelling the cyclodienes would be
less.

However,

this decreased cost may in part, or totally, be offset

by increased damage costs caused by unchecked termite infestations and

consequent damage-

The scenario likely to result from a cancellation of the

cyclodienes would probably result in a significant increase in use of
boh chlorpyrifos and lindane.
This implies increases in social costs

associated with termite control and damage lying within the range of

$706.6 million to $1.0 billion, in the short run.
scenario is likely to be different.

The longer run

Most certainly, the disappearance

of the cyclodienes from the termite control arsenal would stimulate

Q

research and development of new methods for controlling subterranean
termites.

^^

i^

As was stated before, so long as the cheap and effective

cyclodienes are available there is little economic incentive for such

research and development to take place.

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termite treatment is estimated to rise to $913.5 million.

Inflating

this figure using the Bureau of the Census New one Family Houses

Construction Cost Index (Construction Review,
termite treatment cost estimate in

1981) produces

a national

1980 dollars of almost $1.46

billion, a

net increase of

$7066 million above the original $753.4

million estimate

(Chapter I-Section C).

Lindane has been used in limited quantities for soil applications,

but it is also less persistant than the cyclodienes,
to Table

Referring again

XXII of

Section

A, we see that

in order to get equivalent

protection, the cost of using lindane ($16.40) is more than 3 times

(3.28) greater than the cyclodienes ($5.00).

Applying this relative

cost differential to the original treatment cost estimate,

$260,3

million, results in treatment costs of $853.8 million (1976 dollars)
using lindane.

Once again, we can only trace the change in treatment
This gives us a

costs, thus we assume other costs remain unchanged.

national termite treatment cost estimate of $1.1 billion*

Inflated to

1980 dollars using the same Construction Cost Index as before, raises
the cost estimate to $1.76 billion.
This is a net increase of more

than $1*0 billion above the original $753.4 million estimate.

These termite treatment cost estimates associated with using

chlorpyrlfos and lindane, are based on the assumption that more

frequent applications of these compounds are necessary to achieve
protection equivalent to the cyclodienes.
treat as

However, homeowners may

not

frequently if they anticipate that expected cost of damage loss

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v. Cancel All Cyclodlene Termiticides Only

Cancelling the cyclodiene termiticides will result in the loss of

the primary tools of subterranean termite control*
alternatives available are chlorpyrlfos and lindane.

The only viable
Both of these
f

chemicals are effective initially as controls, but do not persist nearly

yr

as long as the cyclodienes (see Section A of this chapter).

Non-chemical

(passive) controls, if properly used reduce the probability of infestation
but are incapable of controlling one that exists*
Other chemical or

biological control techniques, to date, have not been1sufficiently

developed to be considered viable alternatives.

Chlorpyrifos, being a new product, has yet to gain the confidence
of the pest control industry.

Currently, chlorpyrifos

is

4 times as

expensive as the cyclodienes and is only 1/2 as persistant (requiring
retreatment twice as often to maintain its effectiveness)-

Thus, the

cost of getting equivalent protection with chlorpyrifos is much higher

than with the cyclodienes (see Table XXII,

pg'y)*

The analysis presented

earlier in Section A on Table XXII showed that chlorpyrifos was more than

2 1/2 times (2.68) more expensive to use, when one considers all of the
costs involved in the necessary retreatment.
treatment cost of

Multiplying the estimated

$260.3 million (1976 dollars) derived in Chapter I,

Section

C by

this relative cost differential results in a treatment cost
Since we are only able to trace the treatment costs,

of $697.6 million.

the other costs (contract renewal and damage repair) included in the
national potential loss estimate are assumed to remain unchanged.

On this

basis, if chlorpyrifos is substituted for cyclodienes the total cost of

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ill. Cancel Lindane Only

Only limited quantities of lindane are currently used for
subterranean termite control, and this is primarily in southern
California.

Any effects that result from its cancellation would be
No significant economic impacts are expected

focused in this region.
with

chlordane, heptachlor and aldrin available for subterranean termite
These chemicals have been proven to be more persistant in there

control.

effectiveness (see Section A of this

chapter).

There is some indication

that lindane is preferable to the cyclodienes for use in certain soils found in southern California, however, no hard evidence has been produced
to support this contention*

iv Cancel

Pentaehlorophenol Only

Pest control operators report no soil applications of

pentachlorophenol for subterranean termite control.
use as a termiticide

Pentachlorophenal

appears to be limited to treating specific termite

control problems, e.g. where termites are immediately associated with
decay or for direct application to infested wood structures.
Cancelling

penta for subterranean termite soil treatments would, therefore, result
in no significant economic impact.

/o3