CITIZEN PETITION SEEKING TO BAN THE USE OF LINDANE
(GAMMA - HEXACHLOROCYCLOHEXANE) AS TREATMENT FOR LICE AND SCABIES.
David A. Kessler, M.D.
Food and Drug Administration, Room 1- 23
12420 Parklawn Drive
Rockville, MD 2085 7
The undersigned submits on behalf of the Cancer Prevention Coalition,
Inc. (CPC), Samuel S. Epstein, M.D., Chair, Quentin Young, M.D.,
and Peter Orris, M.D., and on behalf of the Center for Constitutional
Rights, Michael Deutsch, Esq. This citizen petition is based on
recent scientific information on risks of brain cancer in children
resulting from the use of lindane shampoo, other evidence of carcinogenicity,
and evidence of haematoxicity and neurotoxicity.
The undersigned submits this petition under 21 U.S.C. 321 (n),
361, 362, and 371 (a); and 21 CFR 740.1, 740.2 of 21 CFR 10.30
of the Federal Food, Drug, and Cosmetic Act to request the Commissioner
of the Food and Drug Administration (FDA) to immediately ban the
use of lindane as a treatment for lice and scabies.
A. AGENCY ACTION REQUESTED
This petition requests that FDA take the following action:
- Immediately ban the use of lindane as a treatment for lice
- Pursuant to 21 CFR 10.30 (h) (2), a hearing at which time we
can present our scientific evidence.
B. STATEMENT OF GROUNDS
Lice and scabies are endemic among the population. An estimated
six million Americans, mainly children, are infested with lice
each year. Most children are treated with pesticide-containing
products marketed as shampoos. Lindane (gamma-hexachlorocyclohexane)
is one of the most widely prescribed treatments for lice and scabies.
In a recent case-control study, Davis, et al. reported a statistically
significant increase of brain cancer in children following treatment
with lindane shampoo. 1
"...use of Kwell®, [lindane] was significantly associated with
childhood brain cancer in comparison to friend controls (OR = 4.6;
95% CI = 1.0 - 21.3)."
These findings are of particular significance in relation to the
striking increase, 38%, in the incidence of brain and nervous system
cancers in children from 1973-1991S.2
Further evidence on cacinogenicity is provided by two epidemiological
studies by the National Cancer Institute.3,4 Statistically
significant increases, up to six-fold , in the incidence of non-Hodgkin's
lymphoma were reported in farmers exposed to lindane.
In addition to these epidemiological data, series of case reports
on blood disorders, including aplastic anemia, with case fatality
rates of some 50%, and leukemia have appeared in the literature
over the last three decades.5, 6 Of related interest
is recent evidence on the high toxicity of lindane to human red
blood stem cells. 7
These epidemiological data are further supported by experimental
evidence on the carcinogenicity of lindane. Lindane is classified
as Group 2B by the International Agency for Research on Cancer 8,
and as 2B/C by the Environmental Protection Agency. The EPA has
restricted lindane's use as an agricultural pesticide.9 Agricultural
and other uses of lindane and other isomers of hexachlorocyclohexane
have been severly restricted or banned by other countries.10
The neurotoxic effects of lindane are well known. A 1976 FDA alert
was issued to warn physicians of such risks.11 Numreous
case reports have documented seizures and brain damage following
lindane exposure.12 Recent studies have emphasized that
recommended dosages of lindane may cause seizures:13
"Therefore, given the extremely narrow range of safety of this
drug and the risk imposed by the kindling effects, which potentiates
convulsive seizures, and that this potentiation may be carried
on for a considerable period of time, there is no good reason to
use lindane in children or adults when other perfectly effective,
safer pediculides are available."
Lindane is readily absorbed through the skin.14 After
topical application to the adult skin without washing for 24 hours,
almost 10% can be recovered from urine.15 Absorption
is further increased when lindane is administered in warm water
or followed by oil-based hair care preparations.
C. CLAIM FOR CATEGORICAL EXCLUSION
A Claim for categorical exclusion is asserted pursuant to 21 CFR
25.24 (a) (11).
The undersigned certifies, that, to the best knowledge and belief
of the undersigned, this petition includes all information and
views on which the petition relies, and that it includes representative
data and information known to the petitioner which are unfavorable
to the petition.
This petition is submitted by:
Jill A. Cashen
Samuel S. Epstein, M.D.
Quentin Young, M.D.
Peter Orris, M.D.
Michael Deutsch, Legal Director,
Center for Constitutional Rights, New York
1. Davis J.R., Brownson RC, Garcia R, Beniz B.J., and Turner A. "Family
pesticide use and childhoodbrain cancer." Arch. Environ. Contam.
Toxicol. 24:87-92, 1993.
2. Reis LAG, Miller BA, Hankey BF, Kosary CL, Harras A, Edwards
BK (eds). SEER CANCER STATISTICS REVIEW, 1973-1991: Tables and
Graphs, National Cancer Institute. NIH Pub. No. 94-2789, Bethesda,
MD, 1994, p. 428.
3. Cantor KP, Blair A, Everett G, Gibson R, Burmeister LF, Brown
LM, Schuman L, and Dick FR. "Pesticides and other agricultural
risk factors for non-Hodgkin's lymphoma among men in Iowa and Minnesota." Cancer
Res. 52:2447-2455, 1992.
4. Blair A, Axelson O, Franklin C, Paynter OE, Pearce N, Stevenson
D, Trosko JE, Vainio H, williams G, Woods J, and Zahm SH. "Carcinogenic
effects of pesticides." In: SR Baker and CF wilkinson (eds.) The
Effects of Pesticides on Human Health, 201-260. Princeton,
NJ: Princeton Scientific Publishing Co., 1990.
5. American Medical Association Council on Drugs. "Registry on
blood Dyscrasias: Report to the AMA Council." JAMA 148-150,
6. Agency for Toxic Substances and Disease Registry. "Toxicological
profile for alpha-, beta-, gamma- and delta-hexachlorocyclohexane
(update). " U.S. Department of Health and Human Services, Pub.
No. TP-93/09, May, 1994, p. 43.
7. Parent-Massin D., Thouvenot, D., rio, B., and Riche C. "Lindane
haemotoxicity confirmed by in vitro tests on human and rat
progenitors." Human Exp. Toxicol. 13:103-106, 1994.
8. International Agency for Research on Cancer. "Hexachlorocyclohexanes " Monographs
on the Evaluation of Carcinogenic Risks to Humans; Overall Evaluations
of Carcinogenicity, Supplement 7:220-222, 1987.
9. Agency for Toxic Substances and Disease Registry. P. 142-149.
10. United Nations. Consolidated list of products whose consumption
and/or sale have been banned, withdrawn, severely restricted
or not approved by governments. 4th Edition, New York, 1991
11. Food and Drug Administration. "Gamma Benzene Hexachloride
(Kwell and other products) Alert" FDA Drug Bulletin: 28,
12. Wheeler, M. "Gamma benzene hexachloride (Kwell) poisoning
in a child." Western J. Med. 127:518-521, 1977.
13. Solomon LM, West DP, and Fitzloff JF. " Lindane " letter, Arch
Dermatol, 126:248, 1990.
14. Agency for Toxic Substances and Disease Registry, 1994, p.
15. Food and Drug Administation, 1976.
FDA Responses (May 13, 1997)
Because lindane is safe and effective if used as directed, the
agency denies your request (1) to ban the use of lindane as a treatment
for lice and scabies, and (2) to conduct a hearing under 21 CFR
10.30(h)(2) so that you can present your scientific evidence.