Oyster Bay: Firehose of Funds means a Firehose of Herbicides

This article is reprinted from the website Death of a Million Trees with permission and minor changes.

 

OYSTER BAY: A FIREHOSE OF PUBLIC FUNDING SUPPLIES A FIREHOSE OF HERBICIDES

Oyster Bay is one of several East Bay Regional Parks along the east side of the bay that is a former garbage dump built on landfill. We visited Oyster Bay for the first time in 2011 after a former Deputy General Manager of the park district told us that it is a “beautiful native plant garden” and a model for a similar project at Albany Bulb, another former garbage dump being “restored” by the park district.

When we visited seven years ago, we found a park in the early stages of being destroyed in order to rebuild it as a native plant museum. Since there were never any native plants on this landfill, we can’t call it a “restoration.” We took many pictures of the park in 2011 that are available HERE.

We recently decided it was time to revisit the park when we noticed pictures of it in the recently published annual report of the park district’s Integrated Pest Management program, indicating recent changes in the development of the park. My article today is about what is happening now at Oyster Bay. It is still not a “beautiful native plant garden.”

“RESTORING” GRASSLAND  

Non-native annual grassland. Oyster Bay April 2011

Seven years ago, most of Oyster Bay was acres of non-native annual grasses. Since then, most of those acres of grassland have been plowed up and are in various stages of being planted with (one species?) of native bunch grass (purple needle grass?).

Stages of grassland conversion. Oyster Bay May 2018

On our May 1st visit, there were at least 8 pesticide application notices posted where the native bunch grass has been planted. Several different herbicides will be used in those sprayings: glyphosate, Garlon (triclopyr), and Milestone (aminopyralid).

Herbicide Application Notices, Oyster Bay May 2018

Grassland “restoration” in California is notoriously difficult. Million Trees has published several articles about futile attempts to convert non-native annual grassland to native grassland:

We wish EBRPD good luck in this effort to convert acres of non-native annual grass into native bunch grass. Frankly, it looks like a lot of public money down the drain to us. It also looks like an excuse to use a lot of herbicide.

Redwing blackbird in non-native mustard. Oyster Bay May 2018

Who benefits from this project? Not the taxpayer. Not the park visitor who is now exposed to a lot of herbicide that wasn’t required in the past. Not the wildlife, birds, and insects that lived in and ate the non-native vegetation. (We spotted a coyote running through the stumps of bunch grass. Was he/she looking for cover?)

DESTROYING TREES AND REPLACING THEM 

Pittosporum forest was an excellent visual screen, sound barrier, and wind break. It was healthy and well-suited to the conditions on this site. It was probably home to many animals.
Oyster Bay April 2011

When we visited Oyster Bay in 2011, many trees had already been destroyed, but there was still a dense forest of non-native pittosporum. That forest is gone and the park district has planted one small area with native trees as a “visual screen” of the Waste Management Facility next door. We identified these native trees and shrubs: ironwood (native to the Channel Islands), coast live oak, buckeye, toyon, juniper, mallow, holly leaf cherry, and redbud.

Native trees planted at Oyster Bay, May 2018

Ground around trees is green with dye used when herbicide is sprayed. Oyster Bay, May 2018

We also saw a notice of herbicide application near the trees. The ground around the trees was covered in green dye, which is added to herbicide when it is sprayed so that the applicator can tell what is done. There were men dressed in white hazard suits, driving park district trucks, apparently getting ready to continue the application of herbicides.

Will the trees survive this poisoning of the soil all around them? There are many examples of trees being killed by spraying herbicides under them. Herbicides are often mobile in the soil. Herbicides damage the soil by killing beneficial microbes and mycorrhizal fungi that facilitate the movement of water and nutrients from the soil to the tree roots.

Herbicide sprayed around newly planted trees. Oyster Bay May 2018

NOT A FUN DAY AT THE PARK

It wasn’t a fun day at the park and it isn’t fun to write about it. I decided to tell you about this visit after reading the most recent edition of the Journal of the California Native Plant Society, Fremontia (Vol. 46 No. 1). The introductory article of this “Special Issue on Urban Wildlands” is illustrated with a photo of Oyster Bay. I nearly choked on this statement in that article: “In order to control invasive plants, agencies and volunteers have sometimes resorted to using herbicides as a step in integrated pest control. While use of herbicides is contentious, the use for spot treatments has enabled small groups of volunteers to successfully eliminate invasive weeds in some areas where future herbicide use will not be needed.”

That is a PATENTLY FALSE statement. The California Invasive Plant Council conducted a survey of land managers in 2014. Ninety-four percent of land managers reported using herbicides to control plants they consider “invasive.” Sixty-two percent reported using herbicides frequently. The park district’s most recent IPM report for 2017 corroborates the use of herbicides to eradicate plants they consider “invasive.” The park district report also makes it clear that they have been spraying herbicide for a very long time. For example, they have been spraying non-native spartina marsh grass (in the bay and along creeks) with imazapyr for 15 years!

Attempting to eradicate non-native plants is NOT a short-term project. It is a forever commitment to using herbicides…LOTS of herbicide. To claim otherwise is to mislead, unless you are completely ignorant of what is actually being done.

YOU ARE PAYING FOR THIS

Another reason why I am publishing this article is to inform you that you are paying for these projects. The park district recently published a list of 492 active park improvement projects in 2018 (scroll down to page 71), many of which are native plant “restorations.” The majority of them are being paid for with grants of public money from federal, State, and local agencies as well as a few parcel taxes. Taxpayers had the opportunity to vote for the parcel taxes. They will have the opportunity to vote for new sources of funding for these projects:

  • Proposition 68 will provide $4.1 BILLION dollars for “park and water” improvements. It will be on your ballot on June 5, 2018. Roughly a third of the money will be allocated for “protection of natural habitats.” (1) Although the project at Oyster Bay does not look “natural” to us, that’s how the park district and other public agencies categorize these projects that (attempt to) convert non-native vegetation to native vegetation.
  • Measure CC renewal will be on the ballot in Alameda and Contra Costa counties on November 6, 2018. The park district has made a commitment to allocate 40% of the available funding to “natural resource projects.” Although the anticipated revenue (about $50 million) seems small, it is used as leverage to apply for big State grants, which require cost-sharing funding. Measure CC is essentially seed money for the much bigger federal and State funding sources.

I would like to vote for both of these measures because our parks are very important to me. If voting for these measures would actually improve the parks, I would do so. But that’s not what I see happening in our parks. What I see is a lot of damage: tree stumps, piles of wood chips, dead vegetation killed by herbicides, herbicide application notices, signs telling me not to step on fragile plants, etc.

Stay out of Oyster Bay to avoid unnecessary exposure to herbicides and keep your dogs out of Oyster Bay for the same reason. Unfortunately wildlife doesn’t have that option. They live there. Oyster Bay, May 2018


  1. “States big bond for little projects,” SF Chronicle, May 5, 2018
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San Francisco “Natural Resources” Herbicide Usage Up 57% in 2017

We have recently analyzed the data for herbicide use in the full year 2017 for San Francisco’s so-called “Natural Resources Department” (NRD – formerly Natural Areas Program). It’s up 57% from the previous year.

NRD is a department of San Francisco Recreation and Parks Department (SFRPD). We were greatly encouraged when NRD started reducing herbicide use in 2014. Before that, pesticide use had increased sharply from 2009 onwards. (You can read an article about that here: SF’s Natural Areas Program – more pesticide in 2013.) Another sharp reduction in 2016 was even more encouraging – though it’s never come down to 2008 or 2009 levels. (The graph above shows annual NRD herbicide usage in fluid ounces of active ingredient.)

But this year, it’s up again, almost to 2015 levels. We have been hoping that SFRPD is working to eliminate all Tier I and Tier II herbicides, with leadership from the Department of the Environment (SF Environment).

For the rest of SFRPD (excluding Harding Golf Course, which is managed under a PGA contract), they have actually reduced usage. They use a greater variety of herbicides than NRD, of which more later. But they are using less – across all their parks and golf courses – than the NRD is. NRD forms a quarter of the area of SFRPD.

WHAT’S WRONG WITH THESE HERBICIDES?

NRD uses four herbicides: Two that SF Environment classifies as Tier I (“Most Hazardous”) and two classified as Tier II (“More Hazardous”). The Tier I herbicides are Roundup/ Aquamaster (glyphosate) and Garlon 4 Ultra (triclopyr); and Stalker/ Polaris/ Habitat (imazapyr) and Milestone VM (Aminopyralid) are Tier II. (In the first picture, with the white dog, the sign posted on Mount Davidson indicates they are using Aquamaster, Garlon, and Milestone in March 2018.)

These hazard rankings can change: Roundup/ Aquamaster (glyphosate) was reclassified from Tier II to Tier I when the World Health Organization found it was a probable human carcinogen. Milestone (Aminopyralid) was reclassified from Tier I to Tier II, despite the fact that it is extremely persistent and mobile in the environment.

THE FEARSOME FOUR

As you research these herbicides, you may find – as we did – that much of the research originates with the companies that produce them. It may be unbiased, but the evidence is that it often is not. So we looked for other sources, which are easier to find for well-established herbicides like glyphosate (Roundup or Aquamaster). It doesn’t mean the others are innocuous.

ROUNDUP or AQUAMASTER (Glyphosate)

  • Carcinogenic. In April 2015, the World Health Organization determined glyphosate was a “probably carcinogenic.”  EPA scientist Dr Marion Copley  sent a letter before her death saying it was essentially certain that glyphosate  causes cancer. She also said that as a chelater, it was likely an endocrine disruptor.
  • Associated with birth defects. It’s been associated with birth-defects, especially around the head, brain and neural tube — defects like microcephaly (tiny head); microphthalmia (tiny undeveloped eyes); impairment of hindbrain development; cyclopia (also called cyclocephaly – a single eye in the middle of the forehead).
  • Bad for the soil. Research indicates it kills beneficial soil fungi while allowing dangerous ones to grow.
    It binds to the soil, and acts as a “chelating agent” – trapping elements like magnesium that plants need to grow and thus impoverishing the soil.
  • Bad for other living things. It’s very dangerous to frogs and other amphibians, and quite dangerous to fish.

GARLON (Triclopyr)

  • Garlon is even more hazardous than Roundup. It’s been classified as Tier I for at least as as long as we have been monitoring pesticide use in San Francisco.
  • Garlon “causes severe birth defects in rats at relatively low levels of exposure.” Baby rats were born with brains outside their skulls, or no eyelids. Exposed adult females rats also had more failed pregnancies.
  • Rat and dog studies showed damage to the kidneys, the liver, and the blood.
  • About 1-2% of Garlon falling on human skin is absorbed within a day. For rodents, its absorbed twelve times as fast. It’s unclear what happens to predators such as hawks that eat the affected rodents.
  • Dogs  may be particularly vulnerable; their kidneys may not be able to handle Garlon as well as rats or humans.  Dow Chemical objected when the Environmental Protection agency noted decreased red-dye excretion as an adverse effect, so now it’s just listed as an “effect.”
  • It very probably alters soil biology. “Garlon 4 can inhibit growth in the mycorrhizal fungi…” ( soil funguses that help plant nutrition.)
  • It’s particularly dangerous to aquatic creatures: fish (particularly salmon); invertebrates; and aquatic plants.
  • Garlon can persist for up to two years in dead vegetation .

The NRD uses Garlon extensively against oxalis. If it terminated its war on oxalis, it could stop using Garlon altogether.

POLARIS, HABITAT, STALKER  (Imazapyr)
This is a relatively new pesticide, and not much is known about it — except that it’s very persistent. In Sweden, it was found in the soil 8 years after a single application. It not only doesn’t degrade, some plants excrete it through their roots so it travels through the environment.

It can cause irreversible damage to the eyes, and irritate the skin and mucosa. As early as 1996, the Journal of Pesticide Reform noted that a major breakdown product  is quinolic acid, which is “irritating to eyes, the respiratory system and skin. It is also a neurotoxin, causing nerve lesions and symptoms similar to Huntington’s disease.”
It’s prohibited in the European Union countries, since 2002; and in Norway since December 2001 because of groundwater concerns.

MILESTONE (Aminopyralid)
Milestone is a Dow product that kills broadleaf plants while ignoring most grasses. This is even more problematically persistent than Imazapyr; a computer search yielded warnings of poisoned compost.

What?

It seems that this chemical is so persistent that if it’s sprayed on plants, and animals eat those plants, it still doesn’t break down. They excrete the stuff in their droppings. If those are composted — it still doesn’t break down the chemical. So now the compost’s got weedkiller in it, and it doesn’t nourish the plants fertilized with the compost, it kills them.

The manufacturer sees this as  a benefit. “Because of its residual activity, control can last all season long, or into the season after application on certain weed species,” says the Dow AgroSciences FAQ sheet.
Nevertheless, after an outcry and problems, Dow AgroSciences stopped selling Milestone in the UK for a number of years. It’s also prohibited for use in New York.

IT’S TIME TO STOP

There’s growing evidence that herbicides are more dangerous, more mobile, and more persistent than their manufacturers claim. Glyphosate, for instance, is widely found in all water sources, in the soil – and in people. A UCSF study of glyphosate in urine found: “Glyphosate residues were observed in 93% of urine samples in voluntary public testing in the U.S. general population; this is higher than the frequency observed in Europe using GC-MS (43.9%)”  and “exposure is likely due to dietary intake or environmental exposure.”

With endocrine disruptors, the old theory “the dose makes the poison” doesn’t work. They are potent at very low levels.

These are parks that we visit with our families, including kids and pets. Kids are particularly vulnerable to pesticides because of their low body weight and rapid growth. These are the watersheds that feed chemicals into our groundwater (which is also now being added to our domestic water supply).

The San Francisco Forest Alliance stands for No Pesticides in our Parks.

Pesticides on Blackberry in Fruiting Season

Recently, one of our neighbors was walking on Mt Davidson. It’s the time of the year when the blackberry bushes bear fruit, to the delight of children and the public in general (and not a few animals and birds). She was unpleasantly surprised to find that the bushes were to be sprayed with herbicide.

“It’s the fruiting season!” she noted, wondering if this was legal.

Unfortunately, it is.  In 2016, SF Environment imposed restrictions on spraying blackberry bushes during the fruiting season. But the way the restrictions are written, they apply only to Tier I (“Most Hazardous”) pesticides and not to the Tier II (“More hazardous”) pesticides that the Natural Resources Division (NRD – formerly Natural Areas Program) also uses quite frequently. The NRD commonly uses “the fearsome four” pesticides: Garlon, Roundup, Milestone VM and Polaris (also called Habitat). All of them are toxic in some degree.

The herbicides used in this case are Milestone VM (aminopyralid) and Polaris (Imazapyr). Both are toxic and are classified as “More Hazardous” (Tier II). Imazapyr can damage eyes, and its breakdown product is a neurotoxin, which means it causes nerve damage. Aminopyralid is a newer chemical, but is known to be astonishingly persistent. It’s banned in some places because of that.

 

SF ENVIRONMENT’S PESTICIDE USE RESTRICTIONS

In 2016, the SF Department of the Environment engaged in a lengthy process of trying to improve its restrictions on  some of the most problematic use of pesticides in our parks.

(You can read the entire compliance guidelines here as a PDF. It’s from the SF Environment website. sfe_th_ipm_compliance_checklist – Copy )

Among them, they developed these restrictions:

 Pesticide use

✓ A written recommendation from a licensed Agricultural Pest Control Advisor (PCA) is required for any pesticide use. Departments that do not have PCAs on staff should contact the SF Environment IPM Manager.

✓ Only pesticides on the current SF Reduced Risk Pesticide List may be used. Usage must fall within the “limitations” listed for each product, along with label requirements.

✓ ‘Most hazardous’ (Tier I) herbicides have special limitations:

  • Use is prohibited for purely cosmetic purposes.
  • Use is prohibited within 15 feet of designated paths. If a park map exists, designated paths are those found on the maps. Otherwise, designated paths are those actively maintained by staff.
  • Use is prohibited within 15 feet of schools, preschools, playgrounds, or other areas frequented by children.
  • Use on blackberry bushes is prohibited when fruit are present 
  • If within the City limits, use requires onsite supervision by a licensed person (PCA, QAL/QAC) o No broadcast spraying with a boom is permitted except for golf courses (targeted spraying only)
  • Certain pesticide use is restricted in designated Red-Legged Frog habitat, which includes Golden Gate Park, Lake Merced, and several other areas in San Mateo and Alameda County.

Notification

Posting for pesticide use must be done 3 days before treatment, and remain up for 4 days after treatment, except for least-hazardous (Tier III) products, which require posting only on the day of treatment.

✓ Postings must clearly identify the area to be treated. Signs should be placed at locations most likely to be seen by members of the public using the treated area.

✓ Posting is not required for median strips or rights-of-way when these areas are not intended for public use.

✓ Posting is not required for areas inaccessible to the public. [See our recent article on this: San Francisco Pesticides and Inaccessible Areas]

✓ ‘Most hazardous’ (Tier I) herbicides have special notification requirements:

  • Blue dye must be used, and this must be noted on the posting sign. Blue dye is not required in areas where 1) posting is not required, and 2) staining may occur, such as ornamental stone median strips.
  • When treatment sites that cannot be readily identified by the posting sign alone, a map showing the general location of expected treatment area(s) must be attached to the posting sign.

MORE ACTION REQUIRED

Though the added restrictions in 2016 were a step forward, much more is needed. NRD seems willing to go by the letter of the rules, not the spirit of it. Blackberry should not be treated with persistent herbicides at all, especially not in the fruiting season. It’s going to affect children, wildlife, and anyone who loves picking the berries in season… most parkgoers.

San Francisco Forest Alliance stands for Pesticide-Free Parks – including natural areas.

Glyphosate in Glen Canyon

There’s increasing evidence that glyphosate – the herbicide Monsanto sells under the names Roundup and Aquamaster – is dangerous to human health, doesn’t degrade in the soil as the company claims, and is a dangerous probable carcinogen. Since SF Department of the Environment changed its classification from Tier II (More hazardous) to Tier I (Most hazardous), SF Rec and Parks has nearly stopped using it. Except in “Natural Areas.”

Recently, one of our supporters sent us these pictures:

It warned they would use Aquamaster (glyphosate) and Milestone (an astonishingly persistent herbicide) on the hillside above Islais Creek.

 

SF RPD should stop all use of Tier I chemicals. (Currently, the Natural Resouces Division uses Garlon and Roundup that are Tier I. ) The benefits are not worth the risk – to the public, their pets, and the people who apply herbicides.

We call on SF Rec and Park to stop using herbicides in our parks.

 

Report on San Francisco Pesticides Meeting – Next is Jan 11, 2016

On January 11th, 2016  the San Francisco Department of the Environment (SFDoE) will hold its Policy Committee meeting , to review the rules about which pesticides may be used on city-owned properties (the “reduced risk” list). If pesticide use in our public parks worries you, this will be an opportunity to comment. The meeting is in in City Hall room 421, at 5 p.m. on January 11th 2016.

Spraying pesticides in Glen Canyon March 2013

We think the SF DoE has been attempting to reduce pesticide use. Nevertheless, we still have concerns, which we addressed in a series of recent articles (click on the titles to read the articles).

parent and child with oxalisTHE NATURAL AREAS PROBLEM

SF Recreation and Parks Department continues to use hazardous pesticides such as Roundup (glyphosate), Garlon (triclopyr), Stalker (imazapyr) and Milestone (amino-pyralid) – especially in areas managed by the Natural Areas Program (NAP). These are all Tier II (More Hazardous) or Tier I (Most Hazardous) pesticides. NAP is the most frequent user of Garlon, primarily against yellow oxalis.

The proposed new guidelines will still permit Natural Areas to use Tier I pesticides.

In a discussion papers for the  meeting, Natural Areas are given the highest priority for toxic pesticide use – on par with airports, golf courses, and inaccessible roadway medians. You can see that document here: justifying toxic herbicide use 2016.

dog and frisbeeThe argument is that its risk is low:  “for public due to inaccessibility, dispersal of treatments; low for environment due to dispersed treatments.” This is not true: The Natural Areas are widely used by joggers, hikers, and families with children and pets. Many dog-play areas are in natural areas. And many areas are repeatedly sprayed. Regular users of the parks see pesticide notices quite often. And much of the spraying is on slopes where the pesticides can contaminate watersheds and communities. Many of them are both persistent and mobile in the soil.

REPORT ON EARLIER MEETING IN DECEMBER 2015

The January 11 meeting is the second of three annual meetings. The first, held on December 16th, 2015, was a hearing to get public comment. Nearly everyone opposed to the use of Tier I and even Tier II pesticides in our parks. (The only exception was Jake Sigg, considered the doyen of the native plant movement in San Francisco, who wanted fewer restrictions. Of which more later.)

The meeting ran two and a half hours. An audio recording of the meeting is HERE.

SF DoE made a presentation showing that pesticide use had dropped sharply since 1992, when Integrated Pest Management (IPM) was first implemented. They admitted that their early data may not be complete or accurate, and recent data is much better.

Other points:

  • Roundup has been changed to a Tier I (Most Hazardous) rating from  Tier II (More Hazardous).
  • They’re reducing Roundup amounts per application by changing to a new type of sprayer nozzle that gives better coverage and more targeting.
  • SFRPD is working to reduce usage of Garlon, routinely used by the Natural Areas Program against oxalis, (the pretty yellow flower that children love to nibble). (It’s even more toxic than Roundup.) They noted that a new surfactant should allow them to use less Garlon, and anyway, there was now less oxalis to fight. [However, the very next day, Mount Davidson was being sprayed with Garlon for oxalis.]
  • SF DoE is no longer permitting any use of neonicotinoids (“Neo-nics”), a kind of pesticide that is dangerous to bees and possibly other insect life.
  • No pesticide use within 15 feet of paths, except for poison oak and hazardous trees.
  • No Tier I pesticide for strictly cosmetic use, or on playgrounds.
  • Spikes in pesticide usages (e.g. SF RPD’s spike in 2013) are related to golf tournaments. SF DoE is working to reduce Harding Park’s usage of pesticides. [Harding Park Golf Course, managed under contract by the PGA Tour, uses a lot of pesticide to stay “tournament ready.”]

PUBLIC COMMENT AT THE DECEMBER 2015 HEARING

There was extensive public comment at the hearing. The main themes:

 1) Tier I pesticides should not be used in public parks.  “I would feel safer for myself, my children, my pets if we just didn’t use pesticides,” said one speaker. Many of the speakers also felt Tier II pesticides should be prohibited as well. Said another: “Quit using my tax dollars to poison me and my pets.” Another speaker, who is a long-term resident of the city and an African-American community activist talked about the health hazards of pesticide use and said, “San Francisco is better than this. We’re not living up to what we have been, what we are.” A speaker who is HIV-positive and has a beautiful golden retriever service dog, said, “I worry about my health and my dog’s health. I live down in Mission Bay, where they spray Aquamaster all the time. Monsanto’s own website says dogs should not be allowed in contact with glyphosate.” Another speaker attributed her dog’s death to Roundup.

Only one speaker favored more pesticide. Jake Sigg, trivializing the risks of pesticides in pursuit of open grasslands, said: “I wish I’d brought pictures of San Bruno Mountain where they sprayed whole mountainsides of oxalis.”  He favored fewer restrictions on their use: “I hate to hear all this unwarranted fear about herbicides. I was a gardener all my life, and I’ve used herbicides and I’m 88 now. I’ve used a lot of them, and it would seem if they’re really that bad I would have problems now! Requiring gardeners to wear Tyvek suits sends the wrong message, it’s like you’re applying some dangerous chemical. Most of these herbicides are not that dangerous.” 

Natural Areas Program pesticide notice2) Better notices are needed. Pesticide applications should be prominently noted both before and after pesticides use. However, the notices are on trails or on the perimeter of the park, making it impossible to know where exactly they have been applied.  Other times, the notices are inconspicuous. One commenter – who is an HIV survivor and regularly walks in parks with his service dog, a golden retriever – said he only realized pesticides were being used when he actually saw workers spraying. The notice was inconspicuously posted on a pole that bore dog-control notices.

3) Which plants are of value to the community? The new guidelines provide for pesticide use to kill plants that threaten plants “of value to the community.” This seemed to imply native plants under the Natural Areas Program. But many non-native plants like blackberry and oxalis are valued by the community while many native plant are not. How can the SF DoE accept claims from native plant advocates that their preferences override others’ values? “What is the community and who decides?” asked one speaker.

4) Enforcement: What are the repercussions for abusing or violating guidelines? Commenters were skeptical about monitoring or enforcement.  There were apparently no consequences for violating pesticide use guidelines. One speaker said she was told that pesticide use in Natural Areas was limited spot application – but then she saw recent video of a worker spraying blackberry bushes along a wide area of trail. Another reported seeing pesticide spraying along the banks of Mission Creek and in parks where young children practice soccer. “Nothing is going to change with new guidelines – 20 different land managers will apply it different. How can you stop someone from misusing the guidelines? What are the repercussions when there’s abuse?”

Some of the other  comments:

  • The 15-foot rule is not enough. No one knows what a designated trail is – parks are full of social trails that people use all the time.  Also people do not stay on trails – they explore, especially kids.
  • The playground rule isn’t enough. What’s the difference between a playground and a park when kids play in both places? And we want kids to play outdoors in the parks.
  • SFRPD is not credible about environmental responsibilities. For example, the Natural Areas Program is in full swing despite EIR not yet certified.
  • Anti-tree bias. When the PUC asked for an exemption to treat eucalyptus trees with a chemical (Bonide Sucker-Punch) to prevent suckering after a stem was removed because it intruded in the right of way, SF DoE has instead asked PUC to remove the entire tree and then treat the stump with toxic herbicides to poison its root system. “Why is SF DoE encouraging the complete destruction of eucalyptus trees when only some of their branches are in the way?
  • SF DoE and the IPM program has done a good job reducing rodenticide use, and thus the poisoning of predators who feed on poisoned rodents.  When rat poison must be used for human safety, procedures should be in place to collect the poisoned rodents.
  • Children are especially vulnerable to pesticides. One speaker said: “Today I went with my child’s nursery school, about thirty 3- and 4-year-olds walking through Glen Canyon, and every single one of those kids was picking sourgrass [oxalis] and eating it.”  What should have been an interaction bringing the children closer to nature instead made her nervous because she was worried about Garlon on the oxalis.
  • People strongly oppose pesticide use. A petition against toxic pesticides in our parks now has over 11,000 signatures. [You can sign it HERE if you have not already done so.]
  • Exemptions for “needed objectives” – e.g. Natural Areas – are the problem. Deploying hundreds of workers is not the solution. We need to change the objectives. While 88-year-old Jake Sigg has not been affected by pesticides, others may be adversely affected depending on age, exposure, and chemical sensitivities. NAP applies Tier I and Tier II pesticides on 36 different species of plants. Natural areas cover over 1000 acres.
  • Because of kikuyu weed in Mission Bay, workers spray pesticides on the banks of Mission Creek, a place with abundant birdlife, and in the park close to paths and play areas. This is a place where 4 year-olds learn soccer.
  • Though it’s stated that pesticides are used as a “last resort” – “Last resort” happens all the time, with over 100 applications. 
  • It’s not just Roundup (glyphosate) which is a problem. Garlon (triclopyr) is even more toxic. Stalker/ Polaris (imazapyr) persists for over a year, and moves around in the soil. Milestone (aminopyralid) is so persistent that if an animal eats it and poops it out, the poop still contains active herbicide. All these herbicides are used by the Natural Areas Program.
  • No exemptions are needed. They should prohibit the use of Tier I and Tier II. Sharp Park doesn’t use herbicides even on poison oak. Medians can be dealt with by closing a lane of traffic.
  • Contractors are allowed to experiment with new chemicals – but this should be done with extreme caution.
  • The land managers should co-ordinate with park users before applying herbicides. In 2010 a Clapper Rail – a federally endangered waterbird [now known as the Ridgeway’s Rail] – showed up in Heron’s Head park. A year later, 2011, mated and produced two chicks that became juveniles. Nine months later, with no discussion with park users or the birding community, imazapyr was sprayed to remove cordgrass – and then the Clapper Rail was gone. [The Million Trees blog did a story about this, HERE ]
  • NAP sprays imazapyr under trees – which would damage them – despite the contrary instructions from the company itself. Either NAP is not obliged to follow company instructions, or they actually want to damage the trees – much like when they girdled thousands of trees in San Francisco.
  • SF DoE must recognize the stories of people here, they’re heart-breaking: The bird that disappeared, the dog that died, the kids that nibble on oxalis.
  • Permaculture and organic solutions are preferable. A apeaker’s ranch property had rattlesnakes – but she brought in feral cats, which ate the rodents, and the rattlesnakes disappeared. She didn’t need traps or poisons.
  • Mount Davidson is worse since since Natural Areas Program took over with pesticide spraying and habitat destruction. Natural Areas should be wild and natural – but NAP is trying to turn them into Native Gardens. The roof of the Cal Academy is a native plant garden – which is irrigated, weeded, replanted. Native Plant gardens are not sustainable without intensive gardening, and the use of poisons.
  • Poisons are sprayed without regard to health of parkgoers, wildlife. Blackberries are being sprayed, though they’re eaten by people and also by wildlife.
  • A few speakers supported the NAP. One said that they supported more wildlife. Jake Sigg said, “People love the Natural Areas Program, they like the open areas for views and kite-flying.” (Of course, if people stay on the designated trails as the NAP wants, they cannot fly kites. People do love the Natural Areas. They just dislike the Natural Areas Program, with its tree-felling and habitat destruction, regular use of toxic herbicides, access restrictions, and use of our tax dollars to do these things.)

THE PROBLEMS OF NATURAL AREAS PROGRAM

NAP is one of the largest users of Tier I pesticides in the San Francisco Recreation and Parks Department (SFRPD) .

toddler holding oxalisNAP is a regular user of Garlon (triclopyr), a pesticide that is even more toxic than glyphosate (Roundup). It uses it mainly on oxalis, which is both pointless and dangerous. It’s a plant that is very popular with children. As Jill Fehrenbacher pointed out, preschoolers frequently nibble on oxalis for its sour taste.

Kevin Woolen of SFRPD said they would be reducing their use of Garlon using a new surfactant – and that there was less oxalis this year perhaps because of prior years’ spraying. However the very next day, signs on Mount Davidson indicated that Garlon was sprayed on oxalis.

MtD-Garlon Oxalis 1

MtD-Garlon Oxalis 2

It claims to be for “spot treatment” but since oxalis is a spreading ground cover, we do not understand how this is possible.

NAP also uses Roundup (glyphosate) on a wide variety of plants. In fact, in the time we’ve been following the issue, NAP has attacked over 30 different species of “invasive” plants with Tier I and Tier II herbicides.

There’s only one good way to reduce pesticide use: To change the management objectives for which these pesticides are used. There is no reason to kill oxalis with toxic herbicides, or to use Tier I and Tier II herbicides in a futile effort to create native plant gardens.

WHAT ABOUT THE GOLF COURSE?

Whenever we address pesticide use by NAP, someone raises the issue of golf. Only Harding Park routinely uses pesticides. (Other city golf courses use them less than once a year – or not at all.) Harding is not managed by SFRPD, but under contract by the PGA Tour, which requires herbicide use to keep its fairways tournament ready.

We are not as concerned about this as we are about the Natural Areas. Herbicide use is concentrated on the greens, which are not accessible to children or pets.The surrounding vegetation is better habitat, so wildlife use of the fairways is limited. Golfers can choose to play a different course where chemicals are not usual like Sharp Park which uses none at all.

There are concerns, of course, and we appreciate the SF DoE attempts to reduce pesticide use there. The golf course is beside Lake Merced, which could be affected by pesticide runoffs. The lake attracts wildlife, and hosts nesting cormorants and herons. These chemicals could have adverse effects.

2013-05-142 double-crested cormorants nest

CAN SAN FRANCISCO DO BETTER?

Many cities are working on eliminating the use of glyphosate (Roundup) or all synthetic pesticides in their public parks and in some cases, even on private property. Some examples:

  • Encinitas, California has banned Roundup and other glyphosate herbicides in public parks. It has also got its first “organic park” where no pesticides are permitted except organic ones. Ironically, it’s called Glen Park and contrasts with our own Glen Park where a lot of Tier I pesticides have been used.
  • Boulder, CO has stopped using Roundup and is trying to phase out synthetic pesticides.
    Portland, Maine: “Portland officials are talking about passing an ordinance that would further limit or ban the city’s use of pesticides and possibly extend it to private use.”
  • Takoma Park (suburb of Washington DC): “While a handful of cities in the country have banned certain pesticides for use on public lands, Takoma Park’s City Council charted new territory by restricting what residents can use on their own lawns.”
  • Rotterdam, Nederlands: Dutch City of Rotterdam Bans Monsanto Glyphosate Roundup Herbicide
  • Menlo Park, 4 parks: Menlo Park: City bans spraying of herbicides in four parks
  • Fairfax, CA:  Fairfax law forbids property owners from spraying herbicides and pesticides unless they first notify their neighbors. And Belvedere doesn’t spray herbicides in its public park.
  • Barcelona, Spain: Barcelona bans glyphosate in public parks

kid and pesticides2

People are becoming much more conscious of the risk of pesticides, to adults but even more to children. From an article that dates back to 2001: “Dr. William Rothman of Belvedere, a retired physician, has voiced concerns about the effects on children of popular herbicides such as Roundup, the world’s most popular weed-killer. ‘Children crawl on the ground and put things in their mouth. They’re exposed to more pesticides than adults,’  Rothman said. ‘They have fewer cells in their body, so if they’re exposed to a toxic chemical, they have a greater concentration of it in their bodies. Their cells are growing, so their cells tend to divide more. The cells that multiply more quickly in the body are more susceptible to toxins.'”

There is, in fact, a Roundup cancer lawyer…. “The Schmidt Firm, PLLC is currently [in November 2015] accepting Roundup induced injury cases in all 50 states.”

OUR CALL: NO PESTICIDES IN OUR PARKS

The San Francisco Forest Alliance calls on the city to ban synthetic pesticides in public parks – and especially in Natural Areas, which are places where families recreate, people hike or bike or explore and harvest wild berries and foods, and wildlife abounds. Our parks are no place for pesticides.

glen canyon glyphosate imazapyr 2012 barack doggie

SF’s Natural Areas Program Beats Own Pesticide Record in 2013

This article is adapted with permission from SutroForest.com

UCSF, which owns and manages most of Mt Sutro Forest, recently decided not to use pesticides there. This may make it the only wild land in San Francisco that is reliably free of pesticides. Most of the others  fall under the misnamed Natural Areas Program (NAP) of San Francisco Recreation and Parks Department (SF RPD). NAP is responsible for around 1100 acres in San Francisco in 32 parks. It has a very different attitude to pesticides.

NAP Number of applicns 2008-2013NAP’s RISING PESTICIDE USE

We’ve been tracking NAP’s rising herbicide use, compiling reports we obtain under San Francisco’s Sunshine Act. (The report for 2012 is HERE; and for 2011 is HERE.) For a year or two, we hoped the rise was an anomaly. Apparently not. With the 2013 data in, the best things we can say are that the rate of increase is not as high as in the last four year; and that the number of applications fell.

But the volume of toxic herbicides used still rose.

People have asked us: But why complain about NAP? Surely a garden like Golden Gate Park with all those lawns and golf courses uses lots more herbicide than NAP? This year, we tracked that too. NAP also uses more pesticides than the rest of SFRPD put together.

NAP USES MORE HERBICIDES THAN THE REST OF SFRPD

NAP vs Other SFRPD 2013NAP, which manages one-fourth of the area under the SF RPD, uses more pesticide than the rest of SF RPD put together. That counts all the golf courses except Harding, which is apparently under contract to be tournament-ready.

Also, NAP is the main user of the most toxic pesticides. San Francisco’s Department of the Environment (SF DoE) – which watches out for pesticide use on city-owned property – rates the permitted pesticides into three Tiers. Tier III is the least hazardous; Tier II is more hazardous; and Tier I is most hazardous. NAP is the major user of the Tier I pesticide, Garlon.

VOLUMES UP

As we mentioned earlier, NAP’s pesticide use continued to increase in 2013, though the number of applications went down. The lower number of applications slightly reduces the opportunities for exposure to freshly applied toxins. But this is more than offset by the fact that actual amounts of pesticides continued to rise – and that many of these chemicals are the ones that are most toxic and very persistent.

Volume of pesticide use by NAP 2008-2013

THE FOUR PESTICIDES NAP USES

NAP currently uses four pesticides: Glyphosate (Roundup/ Aquamaster); Triclopyr (Garlon 4 Ultra); Imazapyr (Polaris or Stalker); and Aminopyralid (Milestone VM). They are all of concern. Of these, SF DoE rates Garlon as Tier I (most hazardous); the remaining three are currently rated as Tier II.

Three of the Four on Mt Davidson

Three of the Four on Mt Davidson

Despite the manufacturer’s claims, there is evidence that these herbicides are not safe. Our article summarizing this is HERE: Natural Areas Program: Toxic and Toxic-er.

ROUNDUP/ AQUAMASTER (Glyphosate)

Classified as a Tier II (More Hazardous) chemical by the San Francisco Department of the Environment, this is the most-used pesticide of the four. However, there’s been growing evidence that it’s not a safe herbicide.

  1. Toxic to human cells, particularly embryonic and placental cells. Here’s an article in Scientific American, about the effect of Roundup on human cells – not just the active ingredient, Glyphosate, but the “inert” one, POEA. (Aquamaster does not contain POEA.)
  2. Damage to liver, red blood cells, lymph system. Here’s a series of research articles detailing some of illnesses caused by Roundup.
  3. Link to birth defects. Here’s an abstract of a May 2010 article in the journal Chemical Research in Toxicology.
    heart breaking

    heart breaking

    It indicates that Roundup increased retinoic acid activity in vertebrate embryos, causing “neural defects and craniofacial malformations.” The actual article, which we read elsewhere describes some of the birth defects: microcephaly (tiny head); microphthalmia (tiny undeveloped eyes); impairment of hindbrain development; cyclopia (a single eye in the middle of the forehead); and neural tube defects. Our summary of this article is HERE.

  4. Linked to cancer, specifically, Non-Hodgkins Lymphoma. A 1999 article on research linking Roundup to cancer, specifically non-Hodgkins lymphoma, and HERE is a follow-up published in 2008 in the International Journal of Cancer.
  5. Dangerous to amphibians. This article cites University of Pittsburgh research showing Roundup is highly lethal to amphibians.
  6. Suspected endocrine disruptor. Initial research suggests that it is an endocrine disruptor in human cell lines. It’s on the list of chemicals the EPA is reviewing for endocrine disruption.

GARLON (Triclopyr)

NAP accounts for 96% of the use within SF RPD of this Tier I (Most Hazardous) chemical. Garlon kills broad-leaved plants (not grasses or conifers) by sending them a hormonal signal to grow uncontrollably. This weakens the plant until it dies. Its breakdown products are triclopyr acid and then ‘TCP’ – both of which are, fortunately, somewhat less toxic than Garlon. (Imazapyr, by contrast, has a breakdown product that is neurotoxic.)

Our article is based on the Garlon chapter of Draft Vegetation Management from the Marin Muncipal Water District (which can be found here as a PDF file). It was a pretty thorough multi-source review of what was known about the chemical, and it clarified the risks: birth defects; kidney damage; liver damage; damage to the blood. What stood out, though, was how much is not known, particularly about the effects of repeated low-level exposure. There simply isn’t that much research out there, and few human studies. “Although triclopyr has been registered in the US since 1979, there are still very few studies on triclopyr that are not part of the EPA registration process.” Most of the research that exists is on Garlon 4. What NAP uses is Garlon 4 Ultra. It’s similar but isn’t mixed in kerosine. It’s mixed in a less flammable but apparently equally toxic methylated seed oil.

What is known makes uncomfortable reading.

  • Birth defects. Garlon “causes severe birth defects in rats at relatively low levels of exposure.” The rats were born with brains outside their skulls, or without eyelids. “Maternal toxicity was high” and exposed rats also had more failed pregnancies.
  • Damage to kidneys, liver, blood. Rat and dog studies showed damage to the kidneys, the liver, and the blood. It’s insidious, because there’s no immediate effect that’s apparent. If someone’s being poisoned, they wouldn’t even know it. In a study on six Shetland ponies, high doses killed two ponies in a week, and two others were destroyed.
  • Skin absorption. About 1-2% of Garlon falling on human skin is absorbed within a day. For rodents, its absorbed twelve times as fast.
  • Dogs may be particularly vulnerable; their kidneys may not be able to handle Garlon as well as rats or humans. “The pharmacokinetics of triclopyr is very different in the dog, which is unique in its limited capacity to clear weak acids from the blood and excrete them in the urine.” Dow Chemical objected when EPA said that decreased red-dye excretion was an adverse effect, so now it’s just listed as an “effect.”
  • Insufficient information. There was insufficient information about Garlon’s potential effect on the immune system, or as an endocrine disruptor.
  • Not quite carcinogenic. It isn’t considered a carcinogen under today’s more lenient guidelines, but would have been one under the stricter 1986 guidelines.
  • Probably alters soil biology. “There is little information on the toxicity of triclopyr to terrestrial microorganisms. Garlon 4 can inhibit growth in the mycorrhizal fungi…” (These are funguses in the soil that help plant nutrition.) No one knows what it does to soil microbes, because it hasn’t been studied.
  • Dangerous to aquatic creatures: fish (particularly salmon); invertebrates; and aquatic plants.
  • Some effect on honey bees. It doesn’t generally kill adult honeybees, but there are no studies of other insects. Some studies show slight “acute toxicity” to honeybees.
  • Garlon can persist in dead vegetation for up to two years.

Given all the information we do have on this chemical (and all the information we don’t have ) we have to question why native plant restoration is worth spraying poisons on some of the highest points in our city. Garlon must be used when the weather is wet; if the plants don’t have water, they will not grow and the chemical won’t work. But the runoff from these hills is enormous during the rain – it washes down in rivulets and streams, and it will end in the reservoirs, the groundwater, and the bay.

IMAZAPYR

Classified as a Tier II (More Hazardous) chemical by the San Francisco Department of the Environment, this is another pesticide used mainly by NAP. In 2013, NAP accounted for 97% of the imazapyr used by SFRPD. NAP started using Imazapyr even before the SF DoE had approved its use. Now it’s being used in Sutro Forest. Here’s our article on Imazapyr.

The main issues with it are that plants push it out through their root system, so that it can spread and affect other plants; it is very persistent. Its breakdown product is neurotoxic. It’s banned in Europe.

According to a BASF Safety Data Sheet from Europe, it’s “Harmful to aquatic organisms, may cause long-term adverse effects in the aquatic environment.” However, a BASF Material Safety Data Sheet from the US says, “There is a high probability that the product is not acutely harmful to fish. There is a high probability that the product is not acutely harmful to aquatic invertebrates. Acutely harmful for aquatic plants.”

Interesting.

MILESTONE VM (Aminopyralid)

SF DoE originally classified this chemical as Tier I, Most Hazardous, because of its uncanny persistence. In 2013, it was reclassified as Tier II – More Hazardous. At the time, we protested that the down-classification would increase its use; SF DoE didn’t think so. But this year, NAP’s use of Milestone has risen 200% from 2012. (Only NAP uses Milestone in the SF RPD.)

Milestone is even more persistent that Imazapyr, and can survive being ingested by animals. Thus, if it is used to treat plants and animals eat and excrete them, they spread the poison. It is banned in New York for fear it will get in the groundwater, and was for a time banned in the UK.

STILL RISING

For purists, we also calculated NAP’s pesticide usage based on “Active Ingredient” and based on “Acid Equivalent.” (The post explaining those measure is HERE.) By those calculations, it’s gone up even more.

NAP Pesticide by Active Ingredient 2008-2013NAP Pesticide by Acid Equiv 2008-2013 Index of NAP Pesticide Use 2009-2013

The graph above shows index numbers of the various indicators, with a base of 2008 (i.e, 2008 = 100). After a dip in 2009, NAP’s pesticide use has trended upward for four years. We cannot quite understand the need for the continuous rise in pesticide use in NAP. We can only wonder if it correlates to budget availability.

We call upon SF RPD to stop all Tier I and Tier II herbicide use in Natural Areas. It would make the Natural Areas more … natural. And it would halve SF RPD’s herbicide consumption, and nearly eliminate their use of Tier I pesticides.

NAP vs SF RPD Other 2013

Sutro Forest Herbicide Projections: Bad News for San Francisco’s Natural Areas?

pesticide use number n vol 2008 to 2012Our regular readers will know that we’ve been following the Natural Areas Program’s (NAP) increasing use of pesticides with some dismay. When we got the 2012 data, it was clear that pesticide use had increased by every measure. That story is HERE: Natural Areas Program Uses Even More Pesticides.  Imagine our concern, then, when the Sutro Forest Draft Environmental Impact Report outlined the amounts of pesticides they contemplate using as part of their destructive plan for the forest on Mount Sutro Open Space Reserve. It’s between 5 and 15 times the amount that NAP is using on all its properties. (Sutro Forest has been essentially pesticide-free since 2008.)

NAP’s own DEIR on the Significant Natural Resource Areas Management Plan – SNRAMP or Sin-Ramp – doesn’t quantify the amounts of pesticides it would need to implement its plan. But the Sutro Forest numbers suggest that we’re looking at multiples of their existing levels of use.

Like many, we’re very concerned about this pesticide use. It’s bad for human beings, for pets, for the environment and for wildlife. We recently came upon this excellent article by David Stang. It’s reprinted here with permission. Of the pesticides reviewed, NAP is using Milestone VM, Roundup (or Aquamaster, with the same active ingredient – glyphosate), and Imazapyr.  (Note: All the illustrations are ours.)

————————-

THE LAST ROUNDUP

By David Stang

pacific chorus frog - public domain image (NPS)Recently an agricultural services firm was retained to spray the herbicide Milestone VM on nearby pastures to kill clover and other broadleaf plants. After spraying, rains washed some of the herbicide downhill from the pastures into the ponds below. Before the spraying, the ponds were full of tadpoles. A few days after spraying, there were no tadpoles in the ponds examined.

Because none of the tadpoles had legs before the spraying, they could not have developed into adult frogs and walked off. Nor could any predator have managed to get every single one of them. And a “control group” — waterways not affected by pasture runoff — still had the tadpoles they had before this spraying. Adult frogs may have been killed as well – the evenings at the ponds after spraying were much quieter than just prior to the spraying.

We could suspect that pasture runoff of Milestone VM into our ponds is the culprit. A literature search confirms this hypothesis (see below).

Studies have shown that herbicides and pesticides may have both direct and indirect effects on tadpoles:

  • Very, very low concentrations of pesticides and herbicides have been found to be a major factor in high levels of deformities in frogs and tadpoles1, and studies have shown that herbicides such as Roundup cause DNA damage in tadpoles.2
  • Very low concentrations may kill tadpoles and frogs in just one day.3
  • Those that are not killed outright by herbicides may die of delayed effects. Malathion, for instance, in very low doses destroys zooplankton that eat algae that floats in the water. With the zooplankton gone, the algae grew rapidly and prevented sunlight from reaching the algae at the bottom of the pond, which tadpoles eat. Some tadpoles then starve to death.4
  • Tadpoles that do not starve will mature slowly, or grow so slowly that they may not reach maturity.5
  • If tadpoles reach maturity, and become adult frogs, herbicides may weaken their immune systems, leaving them susceptible to chytrid fungus infections.6

The known dangers of herbicides for frogs and toads is acknowledged by the National Park Service which, for Yosemite National Park, required that “Herbicides will not be applied within 750 meters (2,500 feet) of known breeding habitat for the Yosemite toad.”7

Where pasture runoff flows into streams, ponds, or even ditches, the use of herbicide or pesticide in our pastures should be suspended until the dangers of any proposed substance can be carefully evaluated.

Herbicides that are known to be toxic to wildlife include Milestone VM, Roundup, Powerline and Arsenal, and Tordon K. It seems likely that all herbicides are toxic to wildlife.

2013-03-14 (2)Milestone VM

Milestone VM contains the active ingredient aminopyralid.

Aminopyralid dissolves very easily and is persistent in water. It has high leachability and mobility. It is toxic to algae, oysters, aquatic plants8, fish, honeybees and earthworms9.Aminopyralid is also on PAN International’s List of Highly Hazardous Pesticides10.

Recently aminopyralid was at the center of public and media attention in the United Kingdom. Gardeners discovered that using manure from animals that grazed on or were fed hay from aminopyralid-sprayed roadsides caused their garden crops to fail or develop abnormally. In fact, the University of Minnesota Extension Service describes this problem in their fact sheet, “Use Caution When Harvesting and Feeding Ditch Hay.”11

Aminopyralid is of concern to vegetable growers as it can enter the food chain via manure which contains long lasting residues of the herbicide. It affects potatoes, tomatoes and beans, causing deformed plants, and poor or non-existent yields. Problems with manure contaminated with Aminopyralid residue surfaced in the UK in June and July 2008, and at the end of July 2008 Dow AgroSciences (the manufacturer of Milestone) implemented an immediate suspension of UK sales and use of herbicides containing Aminopyralid. A company statement explained: “Consistent with its long-standing commitments to product stewardship, and in cooperation with United Kingdom regulators, Dow AgroSciences has asked the Pesticide Safety Directorate (PSD) for a temporary suspension of sales and use of herbicides containing aminopyralid. The suspension shall remain in place until assurances can be given that the product and subsequent treated forage and resultant animal wastes will be handled correctly.”12

If it is unsafe to eat vegetables raised with manure from pastures treated with Milestone, how safe can it be to eat plants that themselves have been treated with Milestone? Are the horses in treated pastures safe?

Of concern to all is the 2005 claim by the EPA that “There are no acute or chronic risks to non-target endangered or non-endangered fish, birds, wild mammals, terrestrial and aquatic invertebrates, algae or aquatic plants”13, despite the fact that the EPA report cites studies such as “Acute Toxicity to Larval Amphibians Using the Northern Leopard Frog, Rana pipiens, as a Biological Model.”

Even if Milestone/aminopyralid were safe for tadpoles, it would only be when applied at recommended doses to non-sloping land. The recommended dose is just 7 fluid ounces per acre, according to the EPA.14

Roundup

Three of the Four on Mt Davidson

Three of the Four on Mt Davidson

Other commonly used herbicides also put wildlife at risk. Roundup, for instance, kills birds, fish, tadpoles, bees, worms – at least 76 different species.

Roundup contains glyphosate as its active ingredient. Glyphosate dissolves readily and is very persistent in water. It is toxic to birds, fish, honeybees and earthworms15and is listed by PAN International as a highly hazardous pesticide16. Its maker, Monsanto, was convicted of false advertising in 2007 for its claim that Roundup was “practically non-toxic” to mammals, birds, and fish.17 Some of the scientific evidence for the safety of Roundup comes from studies with falsified results.18

The U.S. Environmental Protection Agency (EPA) has identified 76 species that may be endangered by glyphosate use19.An important study has shown that glyphosate kills tadpoles20. A University of Pittsburgh biologist has found that the herbicide caused an 86-percent decline in the total population of tadpoles.21A recent study found that even at concentrations one-third of the maximum concentrations expected in nature, Roundup still killed up to 71 percent of tadpoles raised in outdoor tanks.22

Out of concern for these issues as well as human health, European Union member states are warned that they “must pay particular attention to the protection of the groundwater in vulnerable areas, in particular with respect to non-crop uses,” when using glyphosate23.According to EPA, short-term exposure to elevated levels of glyphosate may cause lung congestion and increased breathing rates and, in long-term exposure, kidney damage, reproductive effects24. Glyphosate has also been associated with Parkinson’s disease.25Increased adverse neurologic and neurobehavioral effects have been found in children of applicators of glyphosate26.Female partners of workers who apply glyphosate are at higher risk of spontaneous abortion27.Some glyphosate-based formulations and metabolic products have been found to cause the death of human embryonic, placental, and umbilical cells in vitro even at low concentrations. The effects are not proportional to glyphosate concentrations but dependent on the nature of the adjuvants used in the formulation.28

Powerline and Arsenal

glen canyon imazapyr under treesPowerline and Arsenal contain the active ingredient imazapyr, which has been listed for withdrawal from the market in the European Union.29It is highly soluble and moderately persistent in water. It is also toxic to fish, honey bees and earthworms30. Imazapyr’s potential to leach to groundwater is high and surface runoff potential is high31.One field study found that between 40 and 70 percent of applied imazapyr leached down to the lowest depth tested32. If imazapyr leaches down below 18 inches (where microbial activity is limited) the chemical can be expected to persist for more than a year33.EPA cautions that imazapyr-based herbicides can place terrestrial and aquatic plant species in “jeopardy.”34

Tordon K

Tordon K has the active ingredient picloram. Picloram is a persistent herbicide that is highly leachable, very soluble in water and does not degrade readily in water. It is toxic to birds, fish, honeybees and earthworms. It has also been identified as an endocrine disruptor3536and is on PAN International’s List of Highly Hazardous Pesticides37.EPA’s evaluation of picloram states, “eventual contamination of groundwater is virtually certain in areas where residues persist in the overlying soil. Once in groundwater, the chemical is unlikely to degrade even over a period of several years.”38

Anyone who would advocate against herbicides will face the might of organized agriculture, the lawn care business, and even the EPA. A paper on the Environmental Safety of Forestry Herbicides39, for instance, argues that the herbicides named in the present article – imazypyr, glyphosate, and picloram, as well as many others – are “less toxic than caffeine”, “less toxic than aspirin” and “are safe for animals because the biochemical basis for toxicity does not exist.” The article goes on to claim “herbicides positively affect water quality by reducing sedimentation rates.”

I’d like to think that we could send herbicides to the last roundup. But it seems more likely that herbicides will continue to send wildlife to that roundup.

End Notes

1 Fellers G, Sparling D; Wafting Pesticides taint far-flung frogs, Environmental Toxicology and Chemistry, 2001; Science News, Dec 16,2000, Vol 158, p391; Science News, 9-5-98,p150.

3 Even Small Doses of Popular Weed Killer Fatal to Frogs, Scientist Finds http://www.sciencedaily.com/releases/2005/08/050804053212.htm

4 Even Small Doses of Popular Weed Killer Fatal to Frogs, Scientist Finds http://www.sciencedaily.com/releases/2005/08/050804053212.htm

10 PAN International List of Highly Hazardous Pesticides, 2009. http://www.pan-germany.org/download/PAN_HHP-List_090116.pdf

11 University of Minnosota Extension Service, “Use Caution When Harvesting and Feeding Ditch Hay.” http://www.extension.umn.edu/distribution/livestocksystems/components/M1197.pdf

15 Pesticide Properties DataBase http://sitem.herts.ac.uk/aeru/footprint/en/index.htm

16 PAN International List of Highly Hazardous Pesticides, 2009. http://www.pan-germany.org/download/PAN_HHP-List_1101.pdf

18 On two occasions the United States Environmental Protection Agency has caught scientists deliberately falsifying test results at research laboratories hired by Monsanto to study glyphosate. [(US EPA Communications and Public Affairs 1991 “Note to correspondents” Washington DC Mar 1)] [(US EPA Communications and Public Affairs 1991 Press Advisory. “EPA lists crops associated with pesticides for which residue and environmental fate studies were allegedly manipulated”. Washington DC Mar 29)] [(U.S. Congress. House of Representatives. Com. on Gov. Oper. 1984. “Problems plague the EPA pesticide registration activities”. House Report 98-1147)] In the first incident involving Industrial Biotest Laboratories, an EPA reviewer stated after finding “routine falsification of data” that it was “hard to believe the scientific integrity of the studies when they said they took specimens of the uterus from male rabbits”. [(U.S. EPA 1978 Data validation. Memo from K Locke, Toxicology Branch, to R Taylor, Registration Branch. Washington DC Aug 9)] [(U.S. EPA Office of pesticides and Toxic Substances 1983, “Summary of the IBT review program”. Washington D.C. July)] [Schneider, K. 1983. Faking it: The case against Industrial Bio-Test Laboratories. The Amicus Journal (Spring):14-26. Reproduced at [http://planetwaves.net/contents/faking_it.html Planetwaves] ] In the second incident of falsifying test results in 1991, the owner of the lab (Craven Labs), and three employees were indicted on 20 felony counts, the owner was sentenced to 5 years in prison and fined 50,000 dollars, the lab was fined 15.5 million dollars and ordered to pay 3.7 million in restitution. [(US Dept. of Justice. United States Attorney. Western District of Texas 1992. “Texas laboratory, its president, 3 employees indicted on 20 felony counts in connection with pesticide testing”. Austin TX Sept 29) ] [(US EPA Communications, Education, And Public Affairs 1994 Press Advisory. “Craven Laboratories, owner, and 14 employees sentenced for falsifying pesticide tests”. Washington DC Mar 4)] [http://www.mindfully.org/Pesticide/Roundup-Glyphosate-Factsheet-Cox.htm Glyphosate Factsheet (part 1 of 2) Caroline Cox / Journal of Pesticide Reform v.108, n.3 Fall98 rev.Oct00 ] ] Craven laboratories performed studies for 262 pesticide companies including Monsanto. — http://dic.academic.ru/dic.nsf/enwiki/56554

19 U.S. Department of Agriculture, Forest Service, 1997. Herbicide Information Profile: Glyphosate

20 Hileman, B. (2005) Common herbicide kills tadpoles. Chemical & Engineering News. Washington 83(15):11

22 Even Small Doses of Popular Weed Killer Fatal to Frogs, Scientist Findshttp://www.sciencedaily.com/releases/2005/08/050804053212.htm

23 European Commission, Health & Consumer Protection Directorate-General. Directorate E – Food Safety: plant health, animal health and welfare, international questions. E1 – Plant health. Glyphosate. 6511/VI/99-final. 21 January 2002.

25 Barbosa et al., 2001. Parkinsonism after glycine-derivative exposure. Mov. Disorder. 16: 565-568.

26 Garry et al., 2002. Birth defects, season of conception and sex of children born to pesticide applicators living in the Red River Valley of Minnesota, USA. Environ. Health Perspect. 110: 441-449.

27 Arbuckle et al., 2001. An exploratory analysis of the effect of pesticide exposure on spontaneous abortion in Ontario farm population. Environ. Health Persp. 109: 851-857.

28 Benachour Nora; Gilles- Eric Séralini (December 23, 2008). “Glyphosate Formulations Induce Apoptosis and Necrosis in Human Umbilical, Embryonic, and Placental Cells”. Chemical Research in Toxicology 22: 97. doi:10.1021/tx800218n. http://pubs.acs.org/doi/abs/10.1021/tx800218n%5D.

29 “Pesticides coming off EU market. Pesticide News No. 60, June 2003, pp. 8-10.

31 Washington State Department of Transportation. Imazapyr – Roadside Vegetation Management. Herbicide Fact Sheet. February 2006.

32 Vizantinopoulos, S. and P. Lolos. 1994. Persistence and leaching of the herbicide imazapyr in soil. Bull. Environ. Cont. Toxicol. 52:404-410.

33 “Ecological Risk Assessment of the Proposed Use of the Herbicide Imazapyr to Control Invasive Cordgrass (Spartina spp.) in Estuarine Habitat ofWashington State.” Department of Agriculture, Olympia, WA 98504. Prepared by ENTRIX Inc., Olympia, Washington. Project No. 3000901, October 30, 2003.

34 USEPA. Office of Pesticide Programs. 1987. EEB Review of 241-EEO. Washington, DC (April 21 & June 1)

35 Endocrine disruptors interfere with the endocrine glands that produce hormones that guide the development, growth and reproduction in people and animals. Disruption of hormones, which guide growth, development, intelligence, and reproduction, can result in irreversible harm, which is passed on to future generations.

36 Pesticide Properties Database http://sitem.herts.ac.uk/aeru/footprint/en/index.htm

37 PAN International List of Highly Hazardous Pesticides, 2009. http://www.pan-germany.org/gbr.htm

38 U.S. EPA. Prevention, Pesticides, and Toxic Substances. 1995. Reregistration eligibility decision (RED): Picloram. Washington, D.C., Aug.

39McNabb, Ken. Environmental Safety of Forestry Herbicides http://www.aces.edu/pubs/docs/A/ANR-0846/