April 1st, 2002
Over a thousand comments informed the EPA that the
risk assessment of lindane would be incomplete without the inclusion of
the pharmaceutical use of lindane as a lice and scabies treatment.
The comments are correct, and EPA should pay careful attention to these
comments and take immediate steps to correct the problem. EPA should
be well aware that the greatest exposure of children to lindane comes from
the direct application of the pesticide to their scalp or body for
treatment of head lice or scabies. EPA should be aware that the
greatest current discharges of lindane into the environment come from the
1.41 million applications of lindane shampoo, containing 1.320 pounds of
active ingredient, discharged into the nations sewage systems.
EPA should also be aware that the Food Quality Protection Act (FQPA) was
unanimously passed by Congress in order to prevent this type of
mischaracterization of health risks to children.
Gina Solomon, MD, MPH
Senior Scientist, National Resources Defense Council
1. Sanitation Districts of
Los Angeles County, Comments on Lindane Revised Risk Assessments, March