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.^[1]  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 29, 2002