September 27, 2004

Open Letter to Bayer CropScience

"Lindane: threat to human health and the environment"

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.

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.


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: