Open Letter to Bayer CropScience
CBGnetwork, 09/28/2004
to Emil Lansu, President and CEO Bayer CropScience, LP
Dear Mr. Lansu,
As organizations working to promote and
protect public health and the environment, we are writing to urge you to
voluntarily withdraw registration for all uses of the insecticide lindane. As
you know, seed treatment products containing this persistent, bioaccumulative
and toxic chemical are formulated and distributed in the United States by your
newly acquired subsidiary, Gustafson LLC.
As you will note in the
attached statement and letter, a broad array of public interest groups and
health professionals support the immediate phase out of all uses of this
dangerous chemical. It is currently the focus of a North American Regional
Action Plan being developed under the Sound Management of Chemicals Working
Group of the Commission on Environmental Cooperation. It is also included on the
"Prior Informed Consent" list of the Rotterdam Convention, and it will likely be
one of the top candidates considered for addition to the list of chemicals
targeted for global elimination under the Stockholm Convention on Persistent
Organic Pollutants.
As outlined in the attached documents, lindane
use represents a clear threat to both human health and the environment. We
strongly urge you to consider immediate withdrawal of registration for all Bayer
products containing lindane.
Sincerely,
Kristin S. Schafer
Program Coordinator, Pesticide Action Network North America
Pamela Miller
Executive Director, Alaska
Community Action on Toxics
Jennifer Sass
Senior
Scientist, Natural Resources Defense Council
Karen Perry
Deputy Director, Physicians for Social Responsibility
Statement in Support of the Elimination of Lindane Use in North
America (58 organizational signers)
In June 2002, the environment
ministers from Canada, Mexico, and the United States resolved to develop a North
American Regional Action Plan (NARAP) for lindane through the Commission for
Environmental Cooperation of North America. The Task Force on Lindane will
gather in Montreal, Canada September 28-30, 2004 to draft the NARAP.
We direct the following statement, supported by the undersigned
non-governmental organizations in Canada, Mexico, and the U.S., to the North
American Task Force on Lindane and the ministers of environment and health from
each country.
Background
All three countries continue to
allow pharmaceutical lindane use for pediculosis, lice, and scabies treatment.
In Mexico, lindane is also used on livestock and as a seed insecticide for soil
pest control. The 2002 U.S. Environmental Protection Agency (EPA)
Re-registration Eligibility Decision allows lindane to be used as seed treatment
for six grain crops: corn, wheat, barley, oats, rye, and sorghum. All remaining
agricultural uses of lindane in Canada will no longer be permitted on December
31, 2004.
Lindane is a persistent, bioaccumulative, and toxic
organochlorine insecticide. Lindane is banned by 17 countries. It is harmful to
the environment and human health. Children are particularly vulnerable to the
toxic effects of lindane. Case-controlled research shows a significant
association between the incidences of brain tumors in children with the use of
lindane-containing lice shampoos. The International Agency for Research in
Cancer (IARC) and the U.S. EPA classify lindane as a possible human carcinogen.
Lindane is a potent neurotoxin, with symptoms from small exposures by ingestion
or skin absorption ranging from nausea, dizziness, and muscular weakness, to
tremors and convulsions. Chronic effects include damage to the nervous system
and liver disease. Worker exposures have resulted in blood disorders, headaches,
convulsions, and disruption of the reproductive hormones of the endocrine
system.
Lindane is highly persistent and travels long distances via
atmospheric and oceanic currents. In fact, lindane, with its isomers, is the
most abundant pesticide in Arctic air and water. Indigenous peoples of the north
who rely on traditional diets of marine mammals and fish are particularly at
risk from lindane exposure through foods. Lindane contaminates drinking water
sources. The Los Angeles County Sanitation District estimates that one dose of a
lindane treatment for head lice can pollute 6 million gallons of water to levels
exceeding drinking water standards. This threat to clean drinking water, and the
enormous costs of clean up, prompted California to ban lindane shampoos in 2002.
Lindane is highly toxic to aquatic invertebrates, fish, and bees. It is a
potential endocrine disruptor in birds, mammals, and fish. Safe and affordable
alternatives to the uses of lindane are available for pharmaceutical,
veterinary, and agricultural uses.
The undersigned organizations
call upon the governments of Canada, Mexico, and the United States to specify
the following actions in the North American Regional Action Plan for Lindane,
applicable to the national policies in each of the three countries:
* Immediate elimination of pharmaceutical, veterinary, and
agricultural uses of lindane with substitution of safe, affordable alternatives;
* Commitment to research and education programs that support
alternatives to lindane, giving top priority to preventative and least-toxic
alternatives;
* Delivery of education programs about the risks of
lindane, emphasizing the protection of exposed populations of children,
Indigenous peoples, and workers; and
* Active support for the
expeditious inclusion of lindane among the substances scheduled for elimination
under Annex A of the Stockholm (POPs) Convention.
Coalition against
BAYER-dangers
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