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VELSICOL CHEMICAL CORPORATION CHICAGO. ILLINOIS 60611
CHLORDANE:
AIR CONCENTRATIONS IN TREATED HOTCS
ASSESSIW AND SIGNIFICANCE
A.M. KHASAWINAH
MARCH
23, 1981
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CHLORDANE:
AIR CONCENTRATIONS IN TREATED HOMES
ASSESSMENT AND SIGNIFICANCE
A.M. Khasawinah April 1, 1981
INTRODUCTION
Currently, chlordane is the chemical of choice for termite It is generally applied to the soil control in human dwellings. outside and inside the house foundation and where termite infestations are suspected. When it is applied properly and carefully according to label directions, the potential exposure of inhabitants to chlordane should not be significant. When high concentrations of chlordane appear in treated homes, it is a good indication that accepted practices of application have not been followed or an accident had occured. In any case, such unwarranted exposures can be avoided.
The U.S. General Accounting Office (GAO) has recently petitioned the U.S. Environmental Protection Agency (EPA) to reevaluate the termiticide use of chlordane on the basis of data reported by the U.S. Air Force (USAF) indicating a high potential exposure resulting from use of chlordane (GAO letter to EPA, The GAO letter also referred to the August 5, 1980, Exhibit 1). To understand the GAO health implications of such exposure. and to determine if they are warranted, this review will concerns,
discuss:
the Air Force reports cited in the GAO letter the plenum housing treatment EPA response to the GAO letter
potential chlordane exposure under normal situations the significance of human exposure epidemiological findings
U.S. AIR FORCE REPORTS
There are three reports that were cited in the GAO letter. An account of each report is given below:
1.
Webb AFB
Texas, 1970 Chlordane Contamination
This incident was reported in detail in Melvin's 1974 review (Melvin, 1974, USAF Kelly AFB, Texas, Exhibit 2). In the course of treating concrete slab houses at Webb AFB by sub-slab injection, it became apparent some hours later that the chlordane emulsion had been injected into one or more heating ducts in two houses. These ducts were embedded in the concrete slab. A few hours later when the thermostat-controlled furnaces "came on", the odor of the vehicle became very intense, and the
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Analysis of surface and air demonstrated the presence of samples in these homes chlordane in high concentrations. Air concentrations as high as 1,140 ^-ig/M3 (micrograms per cubic meter) and surface residues as high as 25,900 ^ug/sq. ft. were
quarters were evacuated.
reported.
2.
Wright-Patterson Air Force Base, Dayton, Ohio 1972-1974 Contamination^ A detailed account is given in USAF May 13, 1975 Report. (Exhibit 3)
During the construction of some 800 military family housing units at Wright-Patterson AF Base in the Fall of 1971, water emulsion chlordane solutions were applied on top of the granular fill of the foundation prior to pouring the concrete slab. The application rate was approximately 0.035 Ib active ingredient (A.I.) chlordane/sq. ft. of slab area. The granular fill contained the heating and air conditioning distribution These sub-slab ducts ducts to the ground level rooms. constructed of six and eight inch diameter vitreous were clay pipe wrapped in visqueen, were not water proofed After and were often below exterior grade elevation. application, the granular fill was covered by chlordane a polyvinyl moisture barrier before the slab was poured.
The chlordane contamination was first noticed
immediately after initial occupancy in September-October, 1972 in one of the houses. states:
The USAF
"A review of the housing construction and chlordane application of almost a year ealier indicated the possibility that chlordane had entered the heating ducts, was being volatalized by 130-140 degee F. furnace, and was being distributed into the house to cause
the odors."
Additional complaints of odor by occupants particularly at the start of the heating season prompted the USAF to conduct comprehensive analysis of samples from these housing units in September 1974. Contamination was very common in these housing units reaching 34.0 ^g/M3 in These the air and 39 jjg/sq. ft. on the surface. report, confirmed that: findings, according to the USAF
"The source of the chlordane within the houses was from the sub-slab pretreatment for termite
control and that the mode of entry into the houses was via the sub-slab heating/air conditioning ducts".
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This conclusion was further substantiated by comparison of the airborne levels in the Wright-Patterson AFB to chlordane levels in other comparably constructed and fcermiticide treated Air Force housing units. In those units where the air ducts were completely encased in concrete beneath the slab, chlordane air concentrations were non-detectable at a detection limit of 0,2 ^.ig/M3.
Furthermore, in two story houses at the Wright-Patterson AFB, chlordane contamination was limited to the lower story since it was served by the sub-slab air ducts.
According to the GAO letter, the Air Force reducted these houses above ground in 1979 after sealing the original sub-slab ducts. This apparently alleviated the problem.
3.
Scott AFB, Belleville, Illinois, Fall 1978
This incident involved housing units that had been recently treated (1978) for termites by high pressure sub-slab injection of chlordane (Exhibit 4). The problem was detected during the first heating season following the treatment. Sampling of these houses revealed the presence of chlordane from less that 1 ^ug/M3 to 630 ,ug/M3, In contrast, in 43 randomly selected houses that were similarly treated prior to 1978, (between 1964-1977) air concentrations of chlordane were less than 5 /ag/M3, when sampled and analyzed in the same way. Consequently, the AF
concluded that:
"From these data, it appears that something occured in 1978 that was different from A possible explanation is previous years.
that practices used to avoid insertion of chlordane into heating ducts were not adhered
to".
In summary it is evident from the three accounts given above that the chlordane contamination in the described houses was the result of misapplications such as:
accidental injection of chlordane solutions directly into the house air ducts, sub-slab pretreatment with chlordane solutions in the zone where unencased air ducts were laid, or high pressure sub-slab injections of chlordane solutions' where air-ducts are also laid.
Furthermore, these applications were performed by inexperienced Air Force personnel and not by professional applicators.
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PLENUM HOUSING TREATMENT
In plenum constructed houses, the area under the subfloor (crawl space) is used as a heat-cooling duct. This type of housing is not common and according to the GAO letter, the National Pest Control Association estimates that only 12,000 plenum houses were built in 1978. (Exhibit 1)
The GAO expressed concern about potential house contamination upon treatment of subsoil of plenum houses with chlordane. In response to this, it must be emphasized that both the manufacturer of chlordane and the National Pest Control Association recommend In fact, current against the treatment of plenum housing. Velsicol chlordane labels strictly forbid treatment of plenum housing. Thus, theoretically, the concern from plenum housing treatments is justified, however, in reality such concern is not warranted.
EPA RESPONSE TO GAP LETTER
The GAO, in its August 5, 1980 letter to the EPA, (Exhibit 3), concluded on the basis of the above accounts that a Rebuttable Presumption Against Registration (RPAR) of chlordane should be initiated by EPA to determine whether the pesticides registered for subsurface termite uses should be limited or canceled.
In its October 6, 1980 response to the GAO letter, EPA pointed out that (Exhibit 5):
"The exposure problem that the report describes seems to pertain to specific types of structures and treatment practices."
This confirms the conslusions stated earlier about the exposure problem in the Military Air Force housing units in that it does not represent a general situation.
Furthermore, EPA indicated that potential exposure problems are not just limited to chlordane, but that other registered termiticides may pose similar problems. Consequently, EPA did not agree that the RPAR is the right approach to handle chlordane, but it proposes:
"to undertake a comparative risk/benefit analysis of the registered termiticide chemicals as a group."
This "cluster" approach, according to the EPA, "is a more efficient use of Agency resources than chemical RPAR processing, and it will lead to a regulatory position which addresses the EPA proposed problem in its full scope rather than piecemeal". to initiate this project and gather all the needed data during
1981.
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It is expected that EPA, in its proposed approach, will make a comprehensive review of the subject and differentiate between exaggerated exposure resulting from improper practices and actual potential exposure that may result from approved practices.
POTENTIAL CHLORDANE EXPOSURE UNDER NORMAL SITUATIONS
When proper practices are employed, detectable chlordane residues in air of treated homes were not found six months after chlordane treatment (Malina et.al, 1959, Exhibit 6). In this case five homes commercially treated with chlordane were studied. These homes were located in Georgia, South Carolina and Arkansas and were of two basic types of construction:
slab-on-ground type of construction. Water emulsion of 1% chlordane was applied on soil surface prior to pouring the slab. Although not specified in the article, it was implied that no air ducts were either in the concrete slab or None of the air samples in these houses contained sub-slab. detectable chlordane residues.
Crawl space homes, where chlordane emulsions were applied along the foundation walls and around piers. It is not certain if air ducts were located in the crawl space. Two air samples, out of seven samples taken at intervals of 48-126 days in these houses, showed 6 and 40 ^ig
chlordane/M3.
Recently, a study was conducted jointly by Velsicol Chemical Corp. and California Department of Food and Agriculture to determine potential inhabitants' exposure to chlordane in two types of houses (Cahill, 1979; Maddy et.al. 1979, Exhibits 7 & The treatments were conducted by commercial pest control 8).
operators.
1.
Crawl space houses were sprayed on the inside perimeter, and injected to a 10-inch depth on the outside perimeter.
2.
Slab construction houses were injected along the outside perimeter and the inside perimeter of the garage to a depth of 10-inches.
According to the California monitoring results (Maddy et.al. ), no detectable chlordane air residues were found in either type of homes after 30 days of application, in spite of some residues in some samples at earlier intervals (the highest was 13^ug/M3 for The Velsicol results (Cahill, 1979) slab house treatment). showed less than 2.3 /ig of chlordane/M3 in the slab treated houses one day after treatment. In the crawl space houses the chlordane airborne residues were slightly higher. The maximum concentration reported was 4.9 ^ig/M3.
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THE SIGNIFICANCE OF HUMAN EXPOSURE
As a result of its review of the Air Force studies, the National Academy of Sciences recommended to the Air Force
(Exhibit 9) that:
"epidemiological data be collected on the inhabitants of the Air Force housing units from the 1970, 1974, and 1978 episodes of chlordane exposure, focusing on both acute and chronic health effects".
In the meantime, We believe this is an excellent recommendation. however, there are epidemiological studies of potentially chlordane exposed populations which indicate no long term health effects in the exposed groups. These are:
1.
Harvard School of Public Health Study on Mortality of Pesticide Applicators (Wang and MacMahon 1979a, Exhibit 10). A nationwide cohort group consisting of 16,126 males employed for 3 months or more between 1967 and 1976, was the subject of this study. These applicators had been using a broad spectrum of pesticides including fumigants, botanicals, carbamates, chlorinated hydrocarbons and organophosphates.
Particular interest was focused on applicators potentially exposed to chlordane and heptachlor. The investigators reported that analysis of mortalities due to various causes, and due to intensity of exposure, revealed no significant differences between observed and expected mortalities in the termite control operators. This cohort group is being followed prospectively.
2.
Harvard School of Public Health Epidemeological Study of Workers Employed in the Manufacture of Chlordane and Heptachlor (Wang and MacMahon, 1979b, Exhibit 11). This was a retrospective mortality study on 1,403 workers (white males) employed in the manufacture of chlordane and heptachlor between 1946 and 1976, at the two Velsicol plants (Marshall, Illinois and Memphis, Tennessee) for periods ranging from 3 months to more The impetus for the study was a search than 30 years. for evidence of carcinogenicity of these compounds to man. According to the investigators, "none has been There was no overall excess of deaths from found".
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cancer, even among workers followed twenty or more years after entry into the occupation. An excess of deaths from lung cancer (12 observed, 9.0 expected) was not statistically significant and was not distributed by duration of exposure or of latency in any pattern heptachlor suggesting an etiologic role for chlordane experience. It was also found that although diseases of the circulatory system as a whole showed fewer deaths than expected, there was a statistically significant excess of deaths from cerebrovascular disease. The investigators emphasize that this excess was not related to duration of exposure or latency and occured exclusively after termination of employment.
3.
Shindell and Associates Epidemiologic Study of the Employees of Velsicol Chemical Corporation Plant, This Marshall, Illinois (Shindell, 1980, Exhibit 12). study evaluated the overall mortality of all employees with three months or more employment at the Marshall plant between 1946 when manufacturing of chlordane began and the study cut-off date of 30 June, 1976 (a total of 716 emioyees). Mortality data on the plant employees were compared to the overall mortality experience of like segments (by age and sex) of the The study found that there U.S. population at large. were no significant differences between the Marshall plant employees and the overall U.S. population in regard to mortality. It was concluded that:
"employment at the Marshall plant has no effect upon the employees with respect to either the causes of death or the overall longevity of such employees."
The Shindell Study was updated recently to extend coverage to include persons completing the minimum three months employment at any time between 1946 and January 1, 1980. The primary focus of this updated study which included a cohort of 783 current and former employees was to discern the long-term effects of exposure to. potentially hazardous materials. The investigators stated that:
"Since Velsicol's Marshall Plant studies cover the entire time span of commercial production of synthetic chlorinated hydrocarbon insecticides in the United States, we have maximum possible confidence that any latent effects, if present, will have manifested themselves."
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The findings of the study are:
"The overall mortality was significantly lower in the male employees than that expected in the comparable segment of the population as a whole, 'probably* as a result of the life style of the community in which the plant is located."
"Deaths from heart disease are not significantly different from the U.S. population and are consistent with overall mortality patterns."
"Morbidity data were comparable to expectations in a work force of the age composition present in the Marshall Plant and amongthose no longer employed and surviving at the time of the termination of the study."
The causes of death that were considered in this study were:
all causes
malignant neoplasms (brains, colon, kidney, liver, lung, mediastinum, mesothelioma, pancreas, stomach, and unspecified)
diseases of the heart and circulatory system
cerebrovascular diseases all trauma (accident, suicide, homicide) other and unknown
Dr. Shindell concluded:
thus, no evidence of any long-term latent effect on health related in any way to employment at the Velsicol Plant in Marshall, Illinois, for the thirty-four year period in which it has been engaged in the production of
"There is,
chlorinated hydrocarbon insecticides."
In addition to the above studies, there are three earlier relevant studies on small numbers of workers involved in the manufacture of chlorinated pesticides which found no harmful effects from the occupational exposure to these pesticides:
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1.
Princi and Spurbeck (1951, Exhibit 13) made a clinical laboratory investigation (physical examination, complete urinalysis, complete blood analysis, and complete neurological examination) on 22 workers involved in the manufacture and formulation of chlordane, aldrin and dieldrin. These persons were occupationally exposed to at least 5,000^ug air concentrations of these pesticides per cubic meter for 1 to 3 years. There were no health problems among these workers that were related to their occupational exposure.
Alveres and Hyman (1953, Exhibit 14) reached a similar conclusion regarding the absence of toxic manifestations Twenty in workers occupationally exposed to chlordane. workers involved in the manufacture of four male chlordane for periods ranging from 2 months to 5 years were the subject of this laboratory and clinical study. The investigators found no evidence of any abnormality in the liver, kidney, skin and nervous and blood forming It was also the opinion of these investigators organs. that "the good health of 24 men who were daily exposed to chlordane during its manufacture indicates that when it is breathed or placed in contact with the skin it is
innocuous",
2.
3.
Fishbein et.al. (1964, Exhibit 15) examined the health of 15 workers involved in the manufacture of chlordane A complete for periods ranging from 1 to 15 years. out on each individual. physical examination was carried The clinical tests included urine examinations, complete blood counts, bromsulphalein and ceuphalin flocculation liver function tests, x-ray of the chest and Chlordane air concentrations in the electrocardiogram. occupational environment of these workers at the time of this study were reported to be 1.2-1.7^ug/M3. No evidence of injury to any of the organic systems It was the examined was found in any of the workers. exposure of conclusion of the authors that "since the these workers is greater than may be expected in the use of chlordane in the quantity and manner recommended, and since they showed no signs or symptoms of toxicity, it may be stated that there is little, if any, hazard from the use of chlordane when properly employed".
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SUMMARY
The preceding review has revealed that:
1.
The relatively high air concentrations of chlordane in. the U.S. Air Force Military housing units described in the GAO Letter were the result of improper application practices and the direct application of chlordane solutions into heating and air conditioning ducts.
2.
Current labeling prohibits the use of chiordane in plenum housing structures. (See Appendix I and II)
Under recommended application methods as described in the current chlordane labels (Appendix I and II)/ chlordane air concentrations in treated homes are not expected to exceed S^jug/M^.
3.
4.
In human groups with an increased potential for exposure to chlordane, such as plant workers involved in the manufacturing and formulation of chlordane for up to 30 years or more and termiticide control groups, several epidemiological studies had shown no adverse health effects attributable to working with chlordane.
It must be emphasized that the control of air contamination of chlordane treated homes depends on care in application and strict adherence to the label directions.
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REFERENCES CITED
General Accounting Office (GAO), "Letter to Mr. Douglas M. Costle, the Administrator of the Environmental Protection Agency: Need for a formal risk/benefit review of the pesticide chlordane". Comptroller General of the United States, August 5, 1980.
Melvin, W.W., Jr., "Chlordane: Review of the literature", USAF Environmental Health Lab., Kelley AFB, Texas, October 1974. Page 40-80.
1)
2) 3)
Anonymous, "Summary and Comparison of Two-Hour Baseline Chlordane Air Sampling Results From Air Force Military Family Housing", Prepared for Headquarters United States Air Force/SGPA, Prepared by Office of the Surgeon, Headquarters Air Force Logistics Command, Wright-Patterson Air Force Base, Ohio 45433, May 13, 1975.
Mabson, William E., "Chlordane Contamination in Wherry Housing, Scott AFB, Illinois", Department of the Air Force, USAF Occupational and Environmental Health Laboratory (AFSC) Brook Air Force Base, Texas 78235, April 2, 1979.
4)
5)
U.S. Environmental Protection Agency, "Letter to Honorable Abraham Ribicoff, Chairman, Committee on Governmental Affairs", EPA Office of Planning and Management (William Drayton, Jr.) October 6, 1980.
Malina, M.A., Kearny, J.M., and Polen, P.B., "Determination of Chlordane in Air of Habitations Treated for Insect Control", J. Agr. Food Chem. _[: 30-33, 1959. Cahill, W.P., "Applicator and Inhabitant Exposure to Chlordane during and after Termiticide Applications in California", Velsicol Chemical Corporation Report, Project No. 480018, October 8, 1979.
6)
7)
8)
Maddy, Keith, T; Johnston, Lori; Cusick, B.; Schneider, F.; Jackson, T.; Cooper, Catherine; and Frederickson, A.S.; "A Study in Southern California in July 1979 of the potential dermal and inhalation exposure of applicators and other persons who might later enter or occupy areas treated with chlordane used against subterranean termites under houses", California Dept. of Food and Agriculture, Sacramento, California 95814. Report No. HS-683, November 4, 1979.
National Academy of Sciences, "Chlordane in Military Housing", Prepared by the Subcommittee on Chlordane in Military Housing of the committee on
9)
Toxicology, August 1979.
10)
Wang, H.H., and MacMahon, B., "Mortality of Pesticide Applicators", J. Occup.
Medicine
^1(11):
741-744, 1979a.
11)
Wang, H.H., and MacMahon, B., "Mortality of Workers employed in the manufac745-748, ture of chlordane and heptachlor", J. Occup. Medicine 21(11): 1979b.
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12)
Shindell and Associates, "Report of epidemiologic study of the employees of Velsicol Chemical Corporation Plant, Marshall, Illinois January 1946December 1979", Report submitted to Velsicol, July 1980.
13)
Princi, F. and Spurbeck, G., "A study of workers exposed to the insecticides chlordane, aldrin, dieldrin". Arch. Ind. Hyg. and Occup. Med. .3: 64-72, 1951.
Alvarez, W. and Hymen, S., "Absence of toxic manifestations in workers exposed to chlordane". Arch. Ind. Hyg. and Occup. Med. 8: 480-483,
14)
1953.
15)
Fishbein, W.I., White, J.V. and Isaacs, H.J., "Survey of workers exposed to chlordane", Ind. Med. Surg. 33(10): 726-727, 1964.
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APPENDIX I
EomvMnI
*3.2S Ocuctiioro-4, T-inthtiwttTfiyOio
INSECTICIDE FOR USE ONLY BY PROFESSIONAL APPLICATORS
KEEP OUT OF REACH OF CHILDREN
WARNING
STATEMENT OF PRACTICAL TREATMENT If Bwallowed-Call physician immediately. Gastric lavage is indicated if material taken internally. DO NOT INDUCE VOMITING unless other treatment is not available. Vomiting may cause aspiration pneumonia. If it is necessary to induce vomiting, give victim one or two glasses of water and insert finger in back of throat. Repeat until Mn-Wash with vomit fluid is clear. Do not induce vomiting unconscious person. It give anything by mouth to soap and water. t1 In y*-Flush with water for 15 minutes. Contact physician. If Inhitod-Remove victim to fresh air and appty respication if indicated.
SEE SIDE PANEL FOR ADDITIONAL PRECAUTIONARY STATEMENTS.
E.P.A. Reg No. 876-63-AA E.P.A, Est No 876-TN-1
NET COKTEMTS: 30 Oalloru
VELS1COL CHEMICAL CORPORATION
341 East Ohio Street, Chicago, Illinois 60611
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COMPTROl-1-ER GENERAL OF THE UNITED STATES
WASH1NCTON. D.C. XOS4*
B-1&9618
'
AUGUST 5,1980
The Honorable Douglas'M, Costle Administrator, Environmental Protection Agency
-f
Dear Mr. Costle;
SUBJECT:
Need For a Formal Risk/Benefit Review of the Pesticide Chlordane (CED-80-116)
We have been reviewing the adequacy of the Environmental Protection Agency's (EPA's) regulation of pesticides used in and around the home. During our review we found that -chlordane, a pesticide used for subsurface ground injection for termite control, may pose unreasonable risks to man and the environment. We believe EPA should initiate a formal risk/benefit review of chlordane's use for termite control to determine whether the pesticide's registered uses should be limited or canceled. Additionally, we believe EPA should determine whether the health of people living in certain types of homes treated with chlordane is adversely affected and work with other Federal agencies to take appropriate actiul.te to reduce risk to public health.
PESTICIDE REGULATION
.'
EPA is the priiTiary regulator of pesticides. Its authority is contained in the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) (7 U.S.C. 136 et seq.), as amended and the Federal Food, Drug, and Cosmetic Act of 1938 (21 U.S.C. 301 et seq.), as amended* Under FIFRA, a pesticide can generally not be sold, shipped, or delivered unless EPA has registered it. FIFRA further provides that EPA can only unconditionally register a pesticide if it determines, among other things, that the pesticide will perform its intended function without, causing
"* * *any unreasonable risk to man'or the environment, taking into account the economic, social, and environmental costs and benefits of the use of any pesticide."
The 1972 amendments to FIFRA require EPA to insure strict human health and environmental protection from
(089000)
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pesticides. In 1975 EPA began a rebuttable presumption against registration (RPAR) process to weigh the risks and benefits of pesticides suspected of causing serious health or environmental problems.
^'1
1
A pesticide must,meet certain "risk criteria," before it enters the RPAR process. These criteria (40 CFR 162.11) ~_f include short-term and long-term risk levels (whether a pesticide causes cancer or mutation in humans or laboratory animals) and whether an antidote or emergency treatment If EPA determines exists for those exposed to the pesticide. that a pesticide meets at least one of these criteria, it publishes a RPAR notice in the Federal Register announcing Registrants who wish to maintain a risk/benefit review. registration of an existing pesticide or applicants who wish to register the pesticide can then submit evidence rebutting the'presumption. Rebuttals can be based on proof that actual exposure to the pesticide does not cause the effects described or that the study(s) supporting the presumption is not valid*
If the risk presumption is rebutted, EPA terminals the process and does not take regulatory action against the If the presumption is not rebutted, EPA develops pesticide. and gathers risk and benefit evidence for the RPAR pesticide. EPA uses this information for risk and benefit analyses. From these analvsss, EPA determines risks associated with specific uses. If necessary, EPA develops regulatory options, such as cancellation or restricted uses, reduction of trouble-some ingredients or problem contaminants, or new or revised methods of application, to reduce risk associated with the pesticide EPA also analyzes the costs of the various options. use. One, or several, of the options becomes the RPAR decision when approved by EPA's Administrator. Affected parties may appeal the decision through EPA's administrative hearing process, and then, if not satisfied, through the Federal court system.
-
CHLORDANE'S HISTORY
was introduced in 1945 and became one of It the most widely used household and garden pesticides. kills a wide variety of pests. In 1974 about 21 million pounds of chlordane were produced, about half of which was used to control termites and the remainder used for agriculture an<5 home uses, such as controlling insects and
'Chlordane
crabgrass.
2
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Studies by the National Cancer Institute, Department of Health, Education, and Welfare (now the Department of Health and Hunan Services), I/ and other researchers showed that chlordane caused cancer in mice. Therefore, on November 18, 1974, EPA issued a notice of intent to cancel all registered uses of chlordane, except for subsur-
face ground insertion for termite control, its major use,
and the dipping of nonfood plants (such as ornamental ,bL'ishrubs), a minor use. The notice stated that the excepted.: uses "achieve the desired control of insects without apparent
-i
unreasonable environmental contamination*"
EPA's Office of General Counsel, the decision to
According
using chlordane for subsurface termite control on a risk benefit review but was an administrative based on available -information.
continue^ was not abased
decis.ion -^T^. (J.
^Osl;
On December 23, 1974, the Velsicol Chemical Corporation, chlordane's manufacturer, filed objections to the noticeloq and requested a public hearing. After lengthy cancellation proceedings, representatives for Velsicol and other parties involved in the proceedings, signed a "settlement agreement" in early March 1978, which canceled, either immediately or over 5 years, all chlordane uses except for subsurface ground insertion for termite control and the dipping of nonfood plants.
.".Ithougn 21 million pounds of chlordane were produced in 1974, current information on chlcrdane's uses is not available because of confidentiality restrictions on proauction data. However, as a result of the 1978 settlement chlordane's major use according to EPA's techQyi-ccrr.enfc, nical product manager is for termite control by professional exterminators. Chlordane is also available to the public* The 1978 agreement allowed the public to continue using 1.5 million pounds annually for termite control, provided that chlordane products are distributed in minimum one-half
^/"Memorandum
of Alert-The National Cancer Institute, Oct. 21, 1^74." (Preliminary results showing carcinogenic activity ,e livers of mice.) in Final Report: "Bioassay of Chlordane For Possible Carcincgenicity," (DHEW Publication No. (NIH) 77-808, 1977).
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gallon containers and labeled for termite .use only. I/ At the lowest formulation rate of 2 pounds of chlprdane per half gallon, 750,000 half gallon containers could b^ sold to the. public annually. .':
Although chlordane is presently the most widely used' pesticide for termite control, other pesticides are also registered for this use. Additionally the Forest Service, Department of Agriculture, has developed alternative methods and pesticides for termite control which are being. used on an experimental basis. We have not evaluated the.relative risks of other registered or experimental pesticides. We noted, however, that three presently registered alternatives "aldrin, dieldrin, and heptachlor-are chemically related to chlordane and all three have also caused cancer 'in laboratory
animals.
-
~-f
.
CONCERN ABOUT CHLORDA^JE CONTAMINATED HOMES
-..^. :""" '.
:: '.
Since the early 1970s, the Air Force has had problems with chlordane contamination in military housing where' ^. ^.;j.ordane has been used for termite prevention or control. The housing involved homes built on concrete.;slabs with ; eating ducts in or below the slab. According to EPA's oen&ral Counsul, EPA has been aware of some of the Air Force's chlordane problems but did not consider them in reaching the 1978 settlement agreement.;, EPA and others .'.; have also noted similar chlordane problems with plenum^ '...^
bousing construction.
""..'.' i'." '.'... '...'.'. ".. \
...'.-..
Chlordane contamination of housing is a serious matter because chlordane has been determined to.cause..cancer in.^ laboratory animals and is a suspected.human carcinogen..' Also, neither EPA nor the National Academy.'of^Sciences.have been able to determine a safe chlordane exposure level in' houses.
'^
1/Chlordane in smaller containers is allowed for sale until stocks packaged before various cut-off dates are sold.
After these products are sold, no new products will be allowed to be sold to the public in less than one-half
gallon containers.
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Air Force studies on chlordane contaminated homes
The Air Force's first major ch3ordane problem'surfaced In response to an occupant's complaint of an in 1972. '.- -j unusual odor, the Ai-r Force sampled four homes at the The samples -I Wright-Patterson Air" Force Base, Dayton, Ohio. showed that chlordane was present on floors in each of
Complaints and monitoring data revealed widespread -^ chlordane contamination at Wright-Patterson. Therefore, in October 1974, the Air Force sought comments from EPA on^ the toxicologies! significance of the chlordane levels in Wright-Patterson housing and assistance in setting standards for acceptable chlordane levels .in family housing.. According to an Air Force internal document describing inifcial_contacts between Air Force and EPA personnel, EPA officials were primarily concerned with the suspected carcinogenic property of ch3^rdane. Also, EPA officials indicated that no level of could be considered safe for family housing. ;.-,;
exposure
At a November 1974 meeting between EPA and Air Force officials, including the EPA Assistant Administrator responsible for pesticide programs and the Surgeon General of the Air Force, EPA officials indicated they were primarily con..cecried with regulating future use of chlordane and not con'ditions resulting from past use. EPA was also concerned with the risk to the unborn baby and the nursing.infant. EPA suggested mothers occupying these quarters should not breastfeed. Further, both groups aoreed ^hat the Air Force should eliminate additional and reduce existing levels of In 1979 the Air chlordane contamination. air conditioning and heating ducts and .installing new sealing ducts above ground for the 800 new homes at Wright-Pattersonat a cost of about $800,000.
-
;.
Force^finished
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The Air Force encountered a second chlordane problem in Residents of a housing unit at-'the Scott the fall of 1978. Belleville, Illinois, detected objectionable Air Force Base, Subsequently, odors during the start of the heating season. a similar odor in an unoccupied unit. base personnel noticed Both units had been chlordane treated for termites earlier that year.
Base personnel sampled the air in both units and found chlordane. They also sampled nine other houses which had been treated with chlordane during the previous summer and found widespread contamination.
-4
In January 1979 Air Force Surgeon General officials expanded the air sampling at the base. The officials sampled the 11 original houses and 43 randomly selected houses which had been treated for termites in previous years, some about 14 years prior to the monitoring. The study showed that only one unit did not have detectable levels of chlordane. In April 1979 the Air Force Deputy Surgeon General ^or Operations asked the National Academy of Sciences to evaluate the significance of chlordane exposure to persons In August 1979, the Academy living in Air Force quarters.
.-.'.3
*.--,*.
L.
.Li.
"* * *could not determine a 3.evel of exposure to chlordane below which there would be no biological effect under conditions of prolonged exposure of families in military housing."
The Academy recommended that the Air Force should, among
other things, reduce chlordane exposure in contaminated housing by cleaning or.sealing floors, walls, and other surfaces The Academy also recommended and modifying heating systems. that the Air Force perform an epidemiological study of the 'inhabitants of Air Force housing units involved in the 1974 and 1978 episodes and a smaller one in 1970. The purpose of the study would be to determine whether occupants suffered
any acute or chronic health effects from their exposure to As of May 1980, the Air Force had begun cleanthe chlordane. ing and modifying contaminated homes and was considering the recommendation fur a study.
In a May 19, 1980, memorandum to Department of Defense^ housing officials, the Deputy Assistant Secretary of Defense (Installations and Housing) prohibited the use of chlordane
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for buildings with subslab or intraslab ducts. The prohibition applies both to pre-construction soil treatment and post-construction soil treatment. The memorandum stated that chronic human exposure to chlordane may present-,a health hazard and that no sure way is available to use chlordane under buUdings with subslab and intraslab ducting and prevent the entry^of chlordane vapor into the interior of such buildings. In geographic locations where subterranean termite infestations are knowh to exist/ the Deputy Assistant Secretary specifically pro-s*. hibited the use of subslab or intraslab ducts in any new-nuc buildings for which construction contracts had not been let. Furthermore, he ordered that any such buildings now under design or construction be modified to remove subslab or^'-sc; intraslab ducts. il 9; -3d 5; The Deputy Assistant Secretary also directed that where the risk and extent of possible termite damage in existing structures is considered unacceptable, because of the pro-. hibition on the use of chlordane, studies should be undertaken to determine the feasibility of sealing subslab or infcraslab ducts and renovating heating and cooling systems to use aboveground/above slab ducts, p
~-f
._.
Plenum housing construction may also allow chlordane contamination
^.
In addition to housing constructed on slabs with air -. ducts encased or under the slab, another type of construction may also allow chlordane applied to the subsoil to enter the house. Commonly referred to as plenum housing or plen-wood construction, this type of construction uses the area under the subfloor (the crawl space) as a heat-cooling duct. The National Pest Control Association estimates that 12,000 .plen-wood houses were built in 1978. EPA has conducted limited monitoring (12 homes, 1 experimental house, snd 1 office building) of plenum structures where the subsoil was treated for termite control. Chlordane and related chemicals were found in the indoor air, During a 1975-3.976 review of the Department of Housing and Urban Development's (HUD*s) Minimum Property Standards including plenun; type home construction, the Forest Service also found that preconstructaon soil treatment for termite control, as well as remedial treatment, could create problems.. The subsequent February 1977 report noted that, where used under slab foundations with unencased ducts below the slab,
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termite control chemicals "ere introduced into the living quarters, sometimes in such quantities that the occupants Therefore, the Forest Service recommended to become* ill. KUD that in hi9h and moderate termite hazard zones, the heating ducts be encased in concrete. This action would restrict the use of'plenum construction.
.'
-1
The National Pest Control Association has also recognized the problem of potential contamination of plenum On December 20, 1979, the association constructed housing. advised its members not to treat plenum housing for termite control with presently registered pesticides, including chlordane, because of evident problems with vapors entering housing areas.
POTENTIAL NATIONWIDE HOUSING CONTAMINATION PROBLEM
In July 1975 the Air Force notified HUD that measurable airborne chlordane levels were found in housing treated for. As noted previously, the Air Forc5 traced termite control. the contamination to chlordane used under the floor slab.^ Because Air Force housing is constructed in accordance with' HUD minimum property standards, the Air Force recommended that HUD reevaluate its minimum property standards for
Leriiil Lei Ll. fca Lmd'it
-.
officials.to determine (1') the number
We contacted HUD
of civilian homes which may be susceptible to chlordane contamination because of the type of construction used and (2) the action taken in response to the Air Force's recommenda-
tion for a reevaluation of HUD's minimum property standards for termite control. A HUD official responsible for architecture and engineering standards told us that HUD had not' initiated any studies or actions on the Air Force recommendation other than a general study with the Forest Serviceabout wood protection from termites and other pests. This official and a HUD research official stated that they did not determine the number of homes nationwide which may be susceptible to chlordane contamination because of the type of construction used*
To determine the magnitude of this potential problem nationwide, we tried to obtain estimates on the number of homes built on slabs with heating ducts in or under the slab, .as well as the number of plenum constructed homes. We also tried to determine the number of homes which would have been treated, for termites. While we were not totally successful,
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