Sustainable TamAlmonte 215 Julia Avenue Mill Valley, CA Re: IPM Program s Proposed 2016 Allowed Products List, particularly pesticides

Transcription

1 Sustainable TamAlmonte 215 Julia Avenue Mill Valley, CA February 19, 2016 Marin County Board of Supervisors Marin County Open Space District Board of Directors 3501 Civic Center Drive, Suite 329 San Rafael, CA Re: IPM Program s Proposed 2016 Allowed Products List, particularly pesticides Dear Marin County Board of Supervisors acting as the Marin County Open Space District Board of Directors, Residents in our community are greatly concerned about the use of herbicides, particularly Glyphosate, in the County of Marin. We strongly urge you to follow MMWD s lead and support an herbicide-free approach to vegetation management. If MMWD can manage vegetation on 22,000 acres of watershed land without herbicides, then the Marin County Parks Division and the Marin County Open Space District can do the same on the 19,300 acres that they manage. If you are not willing to embrace an herbicide-free approach to vegetation management at this time, then, we urge you, at a minimum, to support a Glyphosate-free approach to vegetation management. In so doing, we request that you direct staff to follow a timeline of tasks that would permanently eliminate Glyphosate-based herbicides from the IPM Program s Allowed Products List Landscape, including the Exemption Required list, within approximately six or seven months. In addition, we urge you to remove Triclopyr from the Special Use list as it is on the Exemption Required list. We further urge you to officially bring the Marin County Open Space District under the Integrated Pest Management (IPM) Ordinance. Below you will find a description of our proposed timeline followed by information that supports our above requests. I. TIMELINE TO ACHIEVE ZERO USE OF GLYPHOSATE-BASED HERBICIDES WITHIN APPROXIMATELY 6 or 7 MONTHS We applaud your Board for stating that you wish to bring the use of Glyphosate down to zero. However, unless there is a timeline with a specific due date, the statement has little meaning. For instance, one of the goals of the County's Integrated Pest Management (IPM) Ordinance is; (6) Expand our IPM and best management practices with the goal of 1

2 eliminating the use of pesticides. Yet, this IPM Ordinance goal has not stopped the County from using various conventional toxic pesticides, including Glyphosate, since the beginning of the IPM Ordinance, Policy and Commission. To the County IPM Program's credit, the County has been slowly reducing its use of Glyphosate. However, with the tremendous harm Glyphosate can cause to health and the environment, the pace has not been fast enough. Therefore, we recommend that you direct Staff to achieve the below timeline. In doing so, we also recommend that you approve any increase in funding that is necessary. TIMELINE: April 1, 2016 to June 30, 2016 (3 months): A. Create a Marin County Glyphosate-Free Vegetation Management Plan (Volunteers, who have successfully managed vegetation without the use of Glyphosate, are available to help Staff with this endeavor.); B. Estimate the cost of the above Glyphosate-Free Vegetation Management Plan. July 2016: A. Tuesday, July 5, 2016: Attend the Board of Supervisors public hearing and present the proposed Glyphosate-Free Vegetation Management Plan and the estimated cost of the plan; B. Make adjustments to the plan in accordance to requests made by the Supervisors. August 1, 2016 to October 31, 2016 (3 months): A. Implement the Marin County Glyphosate-Free Vegetation Management Plan. II. CONCERNS ABOUT USING GLYPHOSATE IN THE COUNTY Glyphosate-based herbicides are now the most commonly used herbicides in the world. They are still promoted as safe, despite scientific evidence of their harm to health and the environment. Attached is a report entitled; The Unintended Consequences of Using Glyphosate (the main ingredient in the herbicide Roundup) by Sharon Rushton, Ann Spake, and Laura Chariton. This report describes Glyphosate s properties, including its persistence, activity and mobility, and herbicidal mechanism of action. It explains how Glyphosate, Glyphosate herbicide formulations with adjuvants, and associated metabolites could contaminate and harm all facets of an ecosystem, including the soil biology and composition, water, and non-target plants, aquatic organisms, amphibians, reptiles, invertebrates, animals, and humans. It demonstrates that glyphosate formulations with extra-added ingredients (adjuvants) are up to 1,000 times more toxic than their isolated active ingredients. It further demonstrates that using Glyphosate could increase the risk of fires, erosion, and herbicide-resistant super weeds. Please read this report, which reveals scientific evidence of Glyphosate-based herbicides harm to health and the environment, in order to understand our grave 2

3 concerns about the use of Glyphosate. III. CONCERNS ABOUT USING TRICLOPYR IN THE COUNTY ** The following information was taken from an article by Scientist Caroline Cox entitled; Herbicide Factsheet - Triclopyr, which was published in the Journal of Pesticide Reform/Winter 2000 Vol. 20, No. 4 and can be found at the following link: Triclopyr is a broadleaf herbicide used primarily on pastures, woodlands, and rights of way. Garlon 3A and Garlon 4 are brand names of common triclopyr herbicides. Two forms of triclopyr are used as herbicides: the triethylamine salt (found in Garlon 3A) and the butoxyethyl ester (found in Garlon 4). A. Hazards of Triclopyr: 1. Toxic Effects of Triclopyr on Humans: The amine salt of triclopyr is corrosive to eyes. Both the amine salt and the ester are sensitizers and can cause allergic skin reactions. 2. Toxic Effects of Triclopyr on Animals and Possibly Humans: In laboratory tests, triclopyr caused an increase in the incidence of breast cancer as well as an increase in a type of genetic damage called dominant lethal mutations. Triclopyr also is damaging to kidneys and has caused a variety of reproductive problems. The major breakdown product of triclopyr (3,5,6-trichloro-2-pyridinol) may be especially hazardous to children. The metabolite disrupts the normal growth and development of the nervous system. In laboratory tests, it also accumulates in fetal brains when pregnant animals are exposed. 3. Toxic Effects of Triclopyr on Fish: The ester form of triclopyr is highly toxic to fish. In laboratory tests with the yolk-sac fry of coho salmon, the median lethal concentration was less than 0.5 ppm. The ester form also affects fish behavior. In laboratory tests with rainbow trout, concentrations of 0.6 ppm resulted in rapid respiration, flared gills, and erratic, disoriented swimming. 4. Toxic Effects of Triclopyr on Frogs: Low concentrations of triclopyr butoxyethyl ester inhibit frogs and tadpoles avoidance behavior, even paralyzing more sensitive tadpoles entirely. This inhibits their ability to avoid predators. 5. Toxic Effects of Triclopyr on Birds: Triclopyr decreases the survival of newly hatched nestlings. 6. Toxic Effects of Triclopyr on Non-target Plants: Triclopyr inhibits the growth of mycorrhizal fungi, beneficial fungi that increase plants ability to take up nutrients. Triclopyr also interferes with one step in the process by which atmospheric nitrogen is transformed by microorganisms into a form that is usable by plants. 7. Triclopyr s High Mobility: Triclopyr is mobile in soil and has contaminated wells, streams, and rivers. Contaminated water has been found near areas 3

4 where triclopyr is used in agriculture, in forestry, on urban landscapes, and on golf courses. B. Hazards of Inerts in Triclopyr Products: Health hazards of inerts used in triclopyr herbicides include the following: 1. Ehoxylated sorbitan monooleate has caused a drop in blood pressure in dogs given the compound for research purposes. It also has caused adrenal gland tumors in laboratory tests of male rats. 2. Ethlenediamine tetraacetic acid causes eye and skin irritation and is also irritating to the upper respiratory tract. In laboratory tests with rats, it caused a variety of birth defects: cleft palate, eye defects, and abnormal skeletons. 3. Kerosene causes severe eye irritation and is also irritating to the upper respiratory tract. Inhalation of kerosene causes fatigue, headache, dizziness, and incoordination. Other symptoms include euphoria, a burning sensation, disorientation, and drowsiness. 4. Petroleum solvent (with Chemical Abstracts Service registry number ) is damaging to kidneys and to the nervous system. These effects have been demonstrated in both exposed workers and laboratory tests. Some neurological effects are long-lasting or irreversible. 5. Triethylamine is damaging to eyes and can cause abnormal vision and irreversible damage. It is extremely destructive to skin and the upper respiratory tract. Symptoms of exposure include coughing, wheezing, headache, and nausea. IV. THE MARIN COUNTY INTEGRATED PEST MANAGEMENT ORDINANCE We wish to bring to your attention the Purpose and Findings section of the Marin County Integrated Pest Management Ordinance. On page 1 of Chapter of the Marin County Code pertaining to the Marin County Integrated Pest Management Program, it states: PURPOSE AND FINDINGS Whereas, the County of Marin recognizes there is an ongoing need to manage pests to protect health and safety, wildlife, our environment and County assets; and Whereas, the County of Marin recognizes that pesticides may be toxic and must be managed appropriately. Therefore, it is the purpose and intent of this chapter to ensure that county departments and all those who deal with these pest problems and apply pesticides to property owned, leased or managed by the county (per the ordinance and IPM policy): (4) Eliminate pesticides which are classified by government agencies, as identified in 4

5 IPM policy Section VII (B 1-6) as known, probable, or possible carcinogens, reproductive toxicants (teratogens, mutagens), endocrine disruptors, carbamates, organophosphates or ground water contaminants; Glyphosate was recently identified as a probable human carcinogen and therefore classified as a Group 2A carcinogen by the International Agency for Research on Cancer (IARC), the specialized cancer agency of the World Health Organization (WHO). Based on that listing and pursuant to state law, the state Office of Environmental Health Hazard Assessment (OEHHA) has issued a notice of intent to list Glyphosate and several other chemical insecticides and pesticides as chemicals known to the state to cause cancer under the Safe Drinking Water and Toxic Enforcement Act of 1986 (Proposition 65). In summary, the Marin County IPM Ordinance requires the elimination of using pesticides that are classified as probable carcinogens, the IARC of the World Health Organization has indeed classified Glyphosate as a probable carcinogen, and the State OEHHA is in the process of listing Glyphosate as a chemical known to the state to cause cancer. Therefore, in order to uphold the intent of the above referenced Marin County IPM Ordinance, you should eliminate Glyphosate-based herbicides from the Allowed Products List, including the Exemption Required list. V. CONCERNS ABOUT THE PROLIFERATION OF DANGEROUS PESTICIDES RELEASED INTO THE MARKET WITHOUT GOVERNMENT OVERSIGHT As demonstrated in Dr. Evaggelos Vallianatos book, Poison Spring 1, the Environmental Protection Agency (EPA) has allowed a multitude of toxic pesticides into the market without proper oversight. As a result, we cannot trust the research studies, descriptions, recommended precautions, application instructions, and the safety of pesticides that Marin County employees are using. Evaggelos Vallianatos PhD worked at the EPA for 25 years, from 1979 to 2004, primarily in the Office of Pesticide Programs, as an analyst of issues relating to pesticides and agriculture. Based on Vallianatos own experience, the testimony of colleagues, and hundreds of documents collected inside the EPA, Poison Spring reveals that pressure from politicians and threats from huge corporations turned the EPA from the public s watchdog into a polluter s protection agency. According to Vallianatos, in its half century of existence, the corrupt agency has repeatedly reinforced the chemicalindustrial complex by endorsing deadly chemicals, often against the continued advice of its own scientists. It has botched field investigations, turned a blind eye to toxic disasters, and swallowed the self-serving claims of industry. Vallianatos states; The truth is, most toxic chemicals enter the market without ever being tested for health and environmental effects. 2 1 Vallianatos E. G., Jenkins M., (2014), Poison Spring. Bloomsberg Press New York 2 Vallianatos E. G., Jenkins M., (2014), Poison Spring. Bloomsberg Press New York, p 6 5

6 The EPA was formed in 1970, under the Nixon administration. Nixon appointed William Ruchelshaus to serve as the first head of the agency. Ruckelhaus made the agency s goal of environmental protection noble and real. He established the EPA s mission: Clean up the country s environment and protect our natural treasures and people s health from the visible and invisible pollution of industry. 3 However, when the EPA banned DDT in 1972, it woke the chemical industry, which began to lobby against the agency. It sent agents to the White House and Congress to undermine and cut funding for the EPA. 4 Such lobbying has continued through the decades. As a result, the EPA moved away from adhering to its founding mandate to protect the environment. Instead, the agency routinely weighs the costs of protecting people and the natural world from pollution against the benefits that unregulated pollution brings to businessmen and manufacturers, with more weight given to the latter. 5 Moreover, each time the EPA s budget is diminished, the EPA then cuts funding for its labs or turns testing over to private labs. The private labs are typically funded and controlled by the chemical/ pesticide corporations. Objective lab tests are critical to protecting people s health and the environment. They are needed to monitor the eighty thousand synthetic chemicals in common use today. Yet, the number of laboratories serving the Office of Pesticide Programs of the EPA dropped from a dozen in 1971 to a half dozen in When Vallianatos retired in 2004, there were only two. 6 With few EPA labs left, a large percentage of pesticide testing is done by private labs that are funded by the chemical industry. According to Vallianatos, EPA staffers routinely cut and paste studies conducted by the very industries they are supposed to be regulating and rubber-stamp industry conclusions with the imprimatur of government. 7 Vallianatos affirms that many pesticides have won approval from the EPA on the basis of fraud, deception, and bad science. 8 When we can no longer trust the Environmental Protection Agency, we can no longer trust the pesticides the agency approved to enter the market. If you want to protect Marin County s environment and public health and safety, then you must discontinue approving poisonous and largely unregulated pesticides for use in the County s vegetation management toolbox. 3 Vallianatos E. G., Jenkins M., (2014), Poison Spring. Bloomsberg Press New York, p 10 4 Vallianatos E. G., Jenkins M., (2014), Poison Spring. Bloomsberg Press New York, p 11 5 Vallianatos E. G., Jenkins M., (2014), Poison Spring. Bloomsberg Press New York, p 40 6 Vallianatos E. G., Jenkins M., (2014), Poison Spring. Bloomsberg Press New York, p 3 7 Vallianatos E. G., Jenkins M., (2014), Poison Spring. Bloomsberg Press New York, p 6 8 Vallianatos E. G., Jenkins M., (2014), Poison Spring. Bloomsberg Press New York, p 32 6

7 VI. CONCLUSION Using toxic herbicides, like Glyphosate, in Marin County could not only harm beneficial vegetation and wildlife but could also jeopardize public health and safety. This risk is unnecessary and unacceptable. In accordance with the Marin County Precautionary Principle, which requires the selection of the alternative that presents the least potential threat to human health and the County s natural systems, we urge you to follow MMWD s lead and support an herbicide-free approach to vegetation management on property owned, managed and leased by the County of Marin. If you are not willing to embrace an herbicide-free approach to vegetation management at this time, then, we urge you, at a minimum, to support a Glyphosate-free approach to vegetation management. In so doing, we request that you direct staff to follow a timeline of tasks that would permanently eliminate Glyphosate-based herbicides from the IPM Program s Allowed Products List Landscape, including the Exemption Required list, within approximately six or seven months. In addition, we urge you to remove Triclopyr from the Special Use list as it is on the Exemption Required list. We further urge you to officially bring the Marin County Open Space District under the Integrated Pest Management (IPM) Ordinance. Thank you for your conscientious consideration. Very truly yours, /s/ Sharon Rushton, Chairperson Sustainable TamAlmonte Attachment 7